May 14, 2019
NAFEM submits DOE Process Rule comments; encourages more refinement
On behalf of its members, NAFEM submitted comments May 6 that support work to-date on the Department of Energy (DOE) Process Rule but encourage the agency to continue to focus on efforts to determine if a standard or rulemaking needs to be revised.
“Our comments support the overall, proposed process,” says Charlie Souhrada, CFSP, vice president regulatory & technical affairs, NAFEM. “But stress that the process must support the Energy Policy and Conversation Act (EPCA), which requires an amended standard only if that work results in significant energy conservation that is technologically feasible and cost-effective. Through experience, we’ve found this hasn’t always been the case.”
In addition to the association’s comments, NAFEM also participated in joint comments with the Air-Conditioning, Heating and Refrigeration Institute (AHRI); Association of Home Appliance Manufacturers (AHAM); American Lighting Association (ALA); Hearth, Patio and Barbecue Association (HPBA); Heating, Air-Conditioning Refrigeration Distributors International (HARDI); and the National Electrical Manufacturers Association (NEMA). The joint commenters also support the Proposed Rule and encourage the agency to strive for greater certainty, transparency and predictability.