|Received:||12/12/2005 5:45:25 PM|
|Agency:||Federal Trade Commission|
|Rule:||Energy Policy and Conservation Act - Appliance Labeling Rule|
|Docket ID:||To Be Added|
|Attachment:||519870-00003.pdf Download Adobe Reader|
Comments:Central air conditioning and heat pump EnergyGuide labels should include a footnote indicating that conditions which restrict airflow will immediately and perhaps significantly reduce energy efficiency below the levels stated on the label. See the Oakridge National Laboratory study of February 2003: ORNL/CON-489, page 21. Quote: A 50% reduction in airflow could result in a drop of more than 50% in system energy efficiency. End Quote. Soiling of the air filter is most often thought of as the reason for reduction in airflow, which would put it in the realm of routine maintenance and thus beyond the scope of this rulemaking process. But in fact, a new market emphasis on HIGH PERFORMANCE filters has placed air filters on retail shelves which have airflow resistance that is routinely .22 inches water gauge when brand new and clean. Or even as high as .36 inches w.g. That is nine times higher than the airflow resistance of an old fashioned spun glass furnace filter when clean at .04 inches water gauge. It is not at all far fetched to think that a person who had just invested $7000 in a new high SEER central air system would then go to the store and buy what they thought were the BEST filters for that system. In fact, those perceived BEST filters may be the ones with .36 inch w.g. resistance, thereby negating much of the energy efficiency that they had carefully planned to achieve.