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Federal Register / Vol. 86, No. 180 / Tuesday, September 21, 2021 / Proposed Rules
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TABLE II1WRITTEN COMMENTS RECEIVED IN RESPONSE TO 2018 NOTIFICATION OF PETITION FOR RULEMAKING
Continued Commenters
Abbreviation
Pacific Gas and Electric, Southern California Edison, and San Diego Gas and Electric collectively the California Investor-Owned Utilities.
Plumbing-Heating-Cooling Contractors
Regal Beloit America, Inc
Rheem Manufacturing Company

CA IOUs

Utilities.

PHCC
Regal Beloit
Rheem

Trade Association.
Manufacturer.
Manufacturer.

In general overview, furnace manufacturers supported the AHRI
petition, stating that a combined metric would lead to benefits for both manufacturers and/or consumers.
Lennox, No. 34 at pp. 15; Carrier, No.
33 at pp. 1, 34; Rheem, No. 45 at pp.
12; Ingersoll Rand, No. 43 at p. 1 More specifically, manufacturers referenced the fact that there are currently three different energy conservation standards and three different test procedures related to consumer furnace efficiency i.e., AFUE, FER, and standby mode/off mode power consumption and that each of these regulations is subject to separate regulatory review schedules.
Lennox, No. 34 at pp. 34; Rheem, No.
45 at pp. 12 Lennox further stated that having so many separate regulatory schedules places manufacturers, distributors, contractors, and DOE in a constant state of change and adjustment.
Lennox stated that every time DOE
amends standards, manufacturers must redesign equipment, make capital investments to update manufacturing facilities, republish marketing literature, and educate distributors, contractors, and consumers about the changes.
Lennox also asserted that the costs associated with these activities are ultimately passed on to consumers.
Lennox, No. 34 at pp. 35
Manufacturers stated that adopting the AFUE2 metric, consolidating certification and testing requirements, and streamlining rulemaking and redesign cycles could allow for more effective utilization of manufacturer resources by reducing this regulatory burden. Lennox, No. 34 at pp. 34;
Carrier, No. 33 at p. 3; Rheem, No. 45
at p. 1; Ingersoll Rand, No. 43 at p. 1
Manufacturers also generally asserted that the simplified ratings could reduce design constraints or otherwise increase opportunities for innovation. Carrier, No. 33 at p. 3; Rheem, No. 45 at p. 2;
Ingersoll Rand, No. 43 at p. 1 Lennox suggested that setting requirements for individual furnace components restricts design choices between various aspects of a residential furnace. Lennox stated that the AFUE2 test method would promote innovation by enabling manufacturers to develop the most
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effective solution for overall product efficiency at the lowest cost. Lennox, No. 34 at p. 5 In its petition, AHRI
estimated that the total reduction in regulatory burden resulting from implementation of AFUE2 would save manufacturers more than $250 million over thirty years. AHRI, No. 2 at p. 4 7
Manufacturers also stated that a combined metric would make it easier for consumers to compare the overall efficiencies of furnace models. Carrier, No. 33 at pp. 34; Lennox, No. 34 at pp.
3, 4 More specifically, Lennox suggested that consumers and selling contractors often do not understand that the energy consumption associated with the FER metric generally is less than 5 percent of the total energy consumed in the operation of a product, or that standby mode represents a miniscule amount of energy use compared to the amount of energy used to create heat via combustion. Lennox, No. 34 at p. 3
Lennox also commented that the AFUE2 metric would also have the benefit of reducing the need for government intervention and saving government resources by reducing the quantity of regulations. Lennox, No. 34
at pp. 2, 5 Finally, several furnace manufacturers commented that although a crosswalk has not yet been completed, further work in this area should continue and suggested that revised energy efficiency standards in terms of AFUE2 could reflect the overall system energy efficiency already required by the AFUE, PWSB and PWOFF, and FER
metrics. Ingersoll Rand, No. 43 at p. 1;
Rheem, No. 45 at p. 2; Lennox, No. 34
at pp. 2, 4
In contrast, efficiency organizations, State agencies, and utilities generally opposed the petition, asserting that the combined metric would obscure the efficiencies of separately regulated elements which often use different energy sources and could potentially lead to backsliding. These commenters also asserted that a combined metric 7 AHRIs calculations of burden reduction are included in Exhibit 3, which was submitted with the original petition and can be found at www.regulations.gov/document/EERE-2018-BTPET-0017-0002.

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Commenter type
could reduce the amount of future energy savings potential. NEEA, No. 35
at pp. 1, 4; Joint Commenters, No. 42 at pp. 13; CEC, No. 38 at pp. 16;
Earthjustice and the Sierra Club, No. 31
at pp. 1, 34; NRDC, No. 39 at pp. 1, 4
5; NYSERDA, No. 30 at pp. 12; CA
IOUs, No. 27 at pp. 14; NEEP, No. 36
at p. 1; CT DEEP, No. 46 at p. 1; NEMA, No. 26 at pp. 58
Consumer Groups stated that AHRIs petition relies on the assumption that a crosswalk can be generated to translate the three current standards to a single standard that relies on AFUE2 without:
a Diminishing the energy savings that would otherwise be achieved, b harming consumers, or c violating EPCA. These commenters stated that it is unproven that such a crosswalk is possible and further argued that such approach would not be permissible under EPCA. Consumer Groups, No. 31
at pp. 24
The Joint Commenters stated that AHRIs requested change to the test procedures and subsequent changes to the energy conservation standards, if adopted by DOE, would violate the specific directive from EPCA that requires DOE to set air circulation efficiency standards; illegally combine the required air circulation standard with a standards based on fuel use;
improperly apply the EPCA provision regarding adjustment to standards based on test procedure changes to an amendment merging standards; 8 and adopt an approach for standby mode and off mode power consumption that DOE has previously found is not technically feasible. Joint Commenters, No. 42 at p. 7 Earthjustice and the Sierra Club and NRDC similarly stated 8 DOE understands the Joint Commenters to be referencing 42 U.S.C. 6293e, which provides that in the case of any amended test procedure, the Secretary shall determine to what extent, if any, the proposed test procedure would alter the measured energy efficiency, measured energy use, or measured water use of any covered product as determined under the existing test procedure and that if the Secretary determines that the amended test procedure will alter the measured efficiency or measured use, the Secretary shall amend the applicable energy conservation standard as prescribed by certain provisions specified in 42
U.S.C. 6293e during the rulemaking carried out with respect to such test procedure.

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