A: !.'!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 writing to request that The U.S. Department of Energy (DOE) finalize its consideration of new 

residential heating and cooling energy efficiency standards prior to January 15, 2012. While AHRI will 

file full comments on the direct final rule, we are writing now to emphasize the importance of making a 

timely final determination. 

DOE published a direct final rule in the June 27, 2011, Federal Register adopting consensus amended 

federal minimum efficiency standards for residential central air conditioners and heat pumps and 

residential furnaces submitted to DOE in January 2010 by the Air-Conditioning, Heating and 

Refrigeration Institute (AHRI), the State of California and numerous leading energy conservation 

advocacy groups. The direct final 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 apply to 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 air conditioners and heat pumps and residential weatherized gas furnaces manufactured on or 

after January 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 of product distribution. 

EPCA thus provides statutory lead times for amended standards compliance. In negotiating the 

consensus furnace/air conditioner/heat pump standards more than two years ago, AHRI agreed to 

compressed lead times for compliance with the amended standards, in the case of non-weatherized 

furnaces much shorter than the minimum lead time prescribed by statute. 

While AHRI members have been preparing to meet the dates set forth in the consensus agreement, 

twenty months have passed since the agreement was submitted to DOE. Subsequently, the lead time for 

compliance with the non-weatherized furnace standards has been further compressed to the point 

where any substantial additional delay on a final decision beyond the end of this year will make timely 

industry compliance with the standards infeasible. AHRI cannot support standards that do not provide 

adequate lead time for compliance given required investments in factory tooling and product planning. 

Therefore, final adoption of the new standards after January 15, 2012 would force the involved parties 
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The Honorable Steven Chu 

U.S. Department of Energy 

September 23, 2011 

Page 2 

to reconsider their support for the compliance dates contained in the agreement. AHRI urges DOE to 

confirm its adoption of the consensus standards as soon as possible after the period for public comment 

on the direct final 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, September 23, 2011 6:33 PM 

Secretary Chu 

Cymbalsky, John 

Letter from AHRI - Direct Final Rule Central AC and Furnaces 

AHRI Letter to DOE 9-23-11 Final.pdf 

Please see attached letter from Stephen Yurek, President and CEO of the Air-Conditioning, Heating, and 

Refrigeration Institute regarding the Department's direct final 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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