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The United States Environmental Protection Agency (EPA) issued a Discussion Draft 1 for ENERGY STAR® Residential Air Source Heat Pump (ASHP) and Central Air Conditioner (CAC) Equipment Version 6.0 on April 23, 2019.

Collectively, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and HRAI submitted comments to EPA and shared these comments with Canada’s Office of Energy Efficiency on May 23rd , following several consultations with members. The proposal included increasing residential air source heat pumps and central air conditioners to a minimum level of 16 SEER, including prescriptive requirements, regionally specific labels and connected criteria.

Due to the complexity and timing of the version 6.0 proposal, we reported that the industry cannot support Draft 1 as written. In addition to the significant testing burden on manufacturers and certification bodies, we foresee difficulty explaining the value of version 6.0, particularly the cold-climate metric as proposed, to customers. Program participation has dropped over the past decade and this trend is likely to continue unless substantial updates to content and timing are made.

The timing of this proposal was concerning due to the major changes the industry is preparing for, both on the residential and commercial side.  In the United States effective January 1, 2023 new efficiency metrics (SEER2, EER2, and HSPF2) and levels will be in effect for residential central air conditioners and heat pumps; new efficiency levels for small, large, and very large commercial package air conditioners and heat pumps are air-cooled, water-cooled, evaporatively-cooled, and water source unitary air conditioners and heat pumps; as well as new, mildly-flammable refrigerants in certain states, which require the development of a second product line for all products using refrigerants. Another potential challenge is that Natural Resources Canada have yet to determine if and when new efficiency metrics and levels for residential central air conditioners and heat pumps would be adopted, and if they will be harmonized with the U.S.

For more information contact Caroine Czajko at HRAI, e-mail: cczajko@hrai.ca