AHRI’s comments stressed that residential condensing units and outdoor units are and have always been products covered by EPCA that must, as part of a system, comply with federal minimum energy efficiency standards for residential central air conditioners and heat pumps. AHRI believes that the imposition of separate efficiency requirements on condensing units and outdoor units would constitute unwarranted and unlawful double regulation of central air conditioners and heat pumps, and would increase the regulatory burden on manufacturers contrary to President Obama’s Jan. 18, 2011, executive order to reduce regulatory burden. AHRI urged DOE to withdraw its proposed determination to treat condensing units and outdoor units as new or separate EPCA-covered products.
Publication date: 02/27/2012