Every day I hear people talk about ways to reform Congress — whether it’s campaign finance reform, term limits, cuts to the federal government, or even changing House and Senate rules.
While much of what people say may be true, I can’t help but feel that the real way to reform Congress is to help guide it with direct communication from constituents and interest groups (yes, PHCC is an interest group). The only real way to have a voice on Capitol Hill and partner with lawmakers is with communication. Face-to-face talks are best because, folks, it’s all about relationships.
PHCC continues to build and maintain strong relationships on Capitol Hill that enhance our credibility as the "go-to" organization for industry information (you can’t buy credibility). This is the most important dynamic of advocacy. When a Congressional office (or federal agency) has a question or needs to understand an issue, it is critical that PHCC is on their speed dial.
Does relationship-building work? Absolutely.
In April of this year, PHCC held its annual Legislative Conference. One of the true pleasures about working for this organization is that PHCC members are eager to engage with their respective Member(s) of Congress. At the conference, more than 110 PHCC members held meetings on Capitol Hill to educate lawmakers and offer PHCC’s views and concerns about the recent furnace, air conditioner, heat pump rule.
Attendees were provided with current information needed to go up to Capitol Hill. Other associations and industry groups also held conferences and visited Capitol Hill to talk about the rule. Creating a groundswell like this is the best of all worlds.
Though it’s tough to measure success when it comes to advocacy, let’s step back for a moment to measure the success PHCC members had with their face-to-face meetings on the Hill and to give an update on the rule. I also need to mention that along with the Legislative Conference, PHCC has been a part of several important meetings and research-gathering initiatives that focused on making sure that the regulations were realistic and not burdensome and costly to contractors and consumers.
Shortly after the conference, a letter was circulated on the Hill for Members of Congress to sign onto which voiced concerns about the rule to the U.S. Dept. of Energy (DOE). One hundred twenty one Members of the U.S. House of Representatives signed on urging the agency to reconsider its recently proposed 92 percent AFUE residential furnace standard.
Twenty-eight legislators who signed the letter were contacted by PHCC members during the Legislative Conference. The fact that so many legislators signed the letter is a positive indication that PHCC and the industry have had an impact representing and communicating the problems associated with the proposed rule.
Typically, advocacy is also about patience. The effect of advocacy cannot necessarily be measured on a daily basis. Yet, its cumulative effect can be awesome over a period of time.
Furnace, air conditioner, heat pump rule: As part of the Final Furnace, Air Conditioner, Heat Pump Rule, on Jan. 1, 2015, new energy efficiency standards for residential HVAC equipment went into effect. This included a regional approach to split system central air conditioners. Other components of the proposed rule are being reviewed as part of the regulatory process. The latest updates appear below.
92 percent AFUE: PHCC has participated in discussions with the U.S. Dept. of Energy (DOE) regarding a proposed rulemaking to increase residential gas furnace efficiency levels to a minimum 92 percent. PHCC has also met with other industry stakeholders to develop a compromise position on this furnace issue as well. At this time, no compromise has been reached, but efforts are still ongoing.
PHCC files comments on the proposal during a public comment period that closed Friday, July 10. PHCC supports installing high efficiency heating equipment, equipment that best fits specific applications. DOE is encouraged to consider postponing implementation of this proposal until other options can be explored by a joint stakeholder working group.
Air conditioner, heat pump regional standards enforcement: PHCC participated last fall with other stakeholders on a DOE working group to recommend an enforcement strategy for A/C and Heat Pump regional efficiency standards. The regional standards aspect focused the enforcement strategies mainly at the installing contractor. There were many difficulties to developing the strategy, some posing issues for all parties, including DOE.
The enforcement strategy was to have been reviewed by the working group and published for public comment; at this time, the review and comment period has not happened. Regardless of the lack of an enforcement strategy, the Regional Standards went into effect Jan. 1 of this year.
Residential split system central air conditioning equipment sold and installed in the southern states region must meet a minimum SEER 14 (also higher EER values in the southwest states) if manufactured after Jan. 1, 2015. Equipment manufactured prior to that date may still be installed until July 1, 2016. SEER 13 Residential Split System Air Conditioners may still be sold and installed in the Northern states.
Air conditioner, heat pump standards: The DOE is planning a public meeting to begin establishing a negotiated rulemaking working group under the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC).
This group will negotiate proposed amended energy conservation standards for central air conditioners and heat pumps, which may be nationally or regionally based. This is an opportunity to voice concerns over the previously agreed to Regional Standards. PHCC will submit an application to participate with the working group. The working group is expected to make a concerted effort to negotiate a proposal by Dec. 31, 2015.
Residential gas furnaces: PHCC members participated in a joint PHCC-ACCA-AHRI survey to examine installation costs for residential gas furnaces and compare them to costs used by the DOE in their Furnace Rule statistical model.
DOE must demonstrate that the proposed rule is economically justified; installation costs would be a basic building block of the statistical model. The information collected suggests DOE underestimated costs related to installation of residential gas furnaces.
DOE residential boiler AFUE increase: PHCC filed comments on the DOE Proposed Rulemaking for residential boiler products. One of the proposed changes would be to raise gas-fired hot water boilers to a minimum 85 percent AFUE.
PHCC believes that high efficiency equipment is beneficial in many but not all applications. PHCC supports DOE’s maintaining of the non-condensing category of equipment as an economical way to providing heating equipment to venting issue applications and economically challenged consumers.
PHCC has voiced concern that the proposed minimum 85 percent gas boiler and 86 percent oil-fired boiler may be too close to the border where condensing may occur. In some common applications, condensation may form in the boiler or vent system seriously impairing the life of the installation. PHCC recommends modest increases to these efficiency levels as the boiler market is driving to higher efficiency products in suitable applications.