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# !.'!Iii Air-Conditioning, Heating, and Refrigeration Institute

September 23, 2011 The Honorable Steven Chu Secretary of Energy U.S. Department of Energy 1000 Independence Ave., SW Washington, DC 20585 Dear Dr. Chu: 211 i Wllsor1 Boulevrm.i. Suit(;. hDU Arilnqton VA 2Z!UL USA www.ohrlnnt.orc:; PH /O:l52AJl800 FX /03h28.38l6

I am writingto request thatThe U.S. Department of Energy (DOE) finalize its consideration of new residential heating and cooling energy efficiency standards priortoJanuary 15, 2012. While AHRI will file full comments on the directfinal rule, we are writing nowto emphasize the importance ofmaking a timelyfinal determination. DOE published a directfinal rule in theJune 27, 2011, Federal Register adopting consensus amended federal minimum efficiency standards for residential central airconditioners and heat pumps and residential furnaces submitted to DOE in January 2010 by theAir-Conditioning, Heating and Refrigeration Institute (AHRI), the State ofCalifornia and numerous leading energyconservation advocacy groups. The directfinal rule is to be effective October 25, 2011, unless DOE decides to withdraw it in response to significant adverse comments submitted to DOE by October 17, 2011. The consensus amended standards applyto residential non-weatherized gas furnaces, mobile home gas furnaces and non-weatherized oil furnaces manufactured on or after May 1, 2013, and to residential central airconditioners and heat pumps and residential weatherized gas furnaces manufactured on or afterJanuary 1, 2015. The Energy Policy and Conservation Act (EPCA) recognizes that manufacturers must be provided adequate lead times for compliance with new or amended standards to allow for product redesign and engineering, plant retooling, product planning and promotion, and modification ofproduct distribution. EPCAthus provides statutory lead times foramended standards compliance. In negotiatingthe consensus furnace/air conditioner/heat pump standards morethan twoyears ago, AHRI agreed to compressed lead times forcompliance with the amended standards, in the case of non-weatherized furnaces much shorterthan the minimum lead time prescribed by statute. While AHRI members have been preparingto meetthe dates set forth in the consensus agreement, twenty months have passed since the agreementwas submitted to DOE. Subsequently, the lead time for compliance with the non-weatherized furnace standards has been further compressed tothe point where any substantial additional delay on afinal decision beyond the end ofthisyearwill make timely industry compliance with the standards infeasible. AHRI cannot support standardsthat do not provide adequate lead timefor compliance given required investments in factorytooling and product planning. Therefore, final adoption ofthe newstandards afterJanuary 15, 2012 would force the involved partiesI I The Honorable Steven Chu U.S. Department of Energy September 23, 2011 Page 2

to reconsidertheirsupportforthe compliance dates contained in the agreement. AHRI urges DOE to confirm its adoption ofthe consensus standards as soon as possible afterthe period for public comment on the directfinal rule has expired. Sincerely,

Stephen R. Yurek President and CEO Tel: 703-524-8800 Email: syurek@ahrinet.org

cc: Steve Nadel, ACEEE

### Secretary Chu From: Sent: 

### To: Cc: Subject: Attachments:

Dear Dr. Chu: Amrane, Karim [KAmrane@ahrinet.org] Friday, September23, 2011 6:33 PM Secretary Chu Cymbalsky, John Letterfrom AHRI
- Direct Final Rule Central AC and Furnaces AHRI Letterto 

## DOE 9-23-11 Final.pdf

Please see attached letterfrom Stephen Yurek, President and CEO ofthe Air-Conditioning, Heating, and Refrigeration Institute regardingthe Department's directfinal rule on minimum energy conservation standards for residential central air conditioners, heat pumps and furnaces. A hard copy will follow by mail.
Best Regards, Karim Amrane 

### Vice President, Regulatory 

### & Research Air-Conditioning, Heating, and Refrigeration Institute 2111 Wilson Boulevard, Suite 500 Arlington, VA 22201-3001 Tel: 703/600-0307 Fax:703/562-1942 e-mail: Kamrane@ahrinet.org 

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