AHRI Wants DOE’s Commercial Boiler Rulemaking Suspended
The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) is requesting the U.S. Department of Energy (DOE) to follow its own procedures when notifying of laws and wants to seek suspension of a present rulemaking for revising boiler efficiency standards until its established method is followed.
Frank Stanonik, the Chief Technical Advisor of AHRI, condemns DOE’s continuing method of “violating its own procedures” in the Process Rule (10 CFR 430) that is meant to govern how it goes about setting and amending regulations in a letter to DOE’s Office of Energy Efficiency and Renewable Energy.
He also noted that DOE is currently in the process of knowing or accepting comments on its notice of proposed rulemaking (NOPR) for commercial boilers while it is also getting comments on its NOPR for the test procedures for that particular equipment. The Process Rules also especially indicates that “Final modified test procedures will be issued prior to NOPR on proposed standards,” that definitely did not happen in this case.
Stanonik also stated in the letter that “proceeding with the standard rulemaking prior to finalization of the test procedure creates confusion for stakeholders and an inability to effectively comment on the standard rulemaking.” He also questioned, “If stakeholders, and DOE, do not know the exact procedure for testing equipment to determine compliance with the standard, how can they adequately comment on and evaluate the impact of the efficiency standard?” He also cited that the Process Rule was put in place in order to avoid further confusion.
AHRI called the decision to go on with the two rulemakings on a parallel track “arbitrary and capricious,” and also called upon the DOE to put on hold the commercial boiler rulemaking “until the final rule on the revised test procedures for commercial boilers is finalized.”
Statonik also emphasized that finishing the test procedure rulemaking should not keep DOE from meeting its target deadline to complete the boiler rule on March 24, 2018.
AHRI is the trade association that represents manufacturers of HVACR and water heating equipment within the global industry. It has 315 member companies that manufacture quality, efficient, and innovative commercial and residential air conditioning, water heating, space heating, and commercial refrigeration components and equipment for sale in North America and across the globe.