11 Nov 2022

The looming deadline for HVAC compliance with new U.S. Department of Energy minimum performance requirements could cause disruptions in the construction trade as builders struggle to install existing stock and resolve other ‘logistical issues’ before time runs out.

The new performance standards for all newly manufactured residential and commercial air conditioners, heat pumps and gas furnaces will take effect Jan. 1, 2023. Revised testing protocols will also apply.

Supply chain disruptions

In Arizona, for example, there is a chronic housing shortage and an affordability crisis. Builders seeking to increase the housing inventory face challenges in navigating supply chain disruptions and labor shortages, in addition to the regulatory hurdles.

The letter asks that the DoE extend the installation date requirement until July 1, 2023

[T]he current installation deadline [to use equipment that meets the new standards] will present serious logistical issues to constructing and delivering homes and create unreasonable disruption in the lives of home buyers,” states a letter from Arizona’s Congressional delegation to Secretary of Energy Jennifer Granholm. The letter continues: “We cannot have people living with this uncertainty for the sole purpose of checking a bureaucratic box on a deadline we knew in advance was unworkable.” The letter asks that the DoE extend the installation date requirement until July 1, 2023, to address ‘the on-the-ground reality of these changes.’

External static pressure

The letter points to the need to install HVAC components at various stages in home construction; for example, some components are installed at the ‘rough-in’ stage and others at the ‘trim’ stage. In effect, compliant equipment must be available now to enable homebuilders to meet the DoE requirements in January.

Builders cannot move ahead today using current equipment that will not be compliant at the beginning of the year. Supply chain issues are aggravating the problem. A new testing procedure for equipment increases external static pressure (ESP) by 60%, from 0.3 to 0.5, which more accurately reflects field conditions.

Minimum energy conservation

New nomenclature will reflect the new metrics, including SEER2, EER2 and HSPF2

New nomenclature will reflect the new metrics, including SEER2, EER2 and HSPF2. Air conditioners and heat pumps installed in the Southeast and Southwest must achieve a 15.0 SEER rating or a 14.3 SEER2. (Higher SEER numbers equate to better energy efficiency.)

HVAC professionals can avoid accidental non-compliance by familiarizing themselves with the specific DoE regulations and by keeping accurate, up-to-date records of products sold per DoE requirements. The Energy Policy and Conservation Act (EPCA) of 1975 first gave the U.S. Department of Energy (DoE) authority to develop, revise, and implement minimum energy conservation standards for appliances and equipment. EPCA requires DoE to periodically amend energy conservation standards for certain equipment to be more energy-saving, technologically feasible, and economically justifiable.

Central air conditioners

The National Appliance Energy Conservation Act of 1987 established the first minimum efficiency requirements for central air-conditioning and heat pump equipment sold in the United States. These standards went into effect in 1992, and earlier updates went into effect in 2006 and 2015.

The U.S. Energy Information Administration estimates that 76 million primary occupied U.S. homes (64% of the total) use central air-conditioning equipment, and about 13 million homes (11%) use heat pumps for heating or cooling. When defining the new standards, DoE calculated that, in total, households using central air conditioners or heat pumps would collectively save $2.5 billion to $12.2 billion on energy bills during the 30-year period following implementation of the standards.