By Michael J. Salmon
President, Anderson Air Corps
The city of Albuquerque's proposed energy conservation code is seriously flawed as it relates to existing home heating and air conditioning equipment. This is a good example of a well meaning effort that has run amok and will ultimately be a costly and needlessly painful experience for many citizens of Albuquerque with existing homes.
The code was developed, in part, to help ease the energy crunch by eliminating less-efficient appliance choices when it comes to heating and cooling the home. Among other things, the code calls for a minimum of 90 percent furnace efficiency (AFUE rating) and an air conditioner rating of 15 SEER (seasonally adjusted energy efficiency rating).
Applied to new home construction, this is not a bad idea. While under construction, accommodation for the requirements of these ultra high efficiency units and installation techniques can easily be made. The extra costs are recouped in a reasonable period of time.
But, when you apply these equipment regulations to existing homes, without exception, whether recently built or very old, you run into potentially expensive application and installation problems that were not fully thought out.
Ultra-high efficiency appliances do not always make economic sense when applied to older homes and should be used only where they make sense. In some cases, equipment is not even made in the desired configuration, necessitating a costly switch to an alternative system design. For instance, not one manufacturer makes a 90-percent AFUE rated heating section in a rooftop combination unit. In other instances, the problem of finding a suitable drain for the furnace (yes, these ultra high efficiency furnaces require a water condensation drain) may entail expensive plumbing modifications.
Adding refrigerated air conditioning has become a popular option as homeowners replace the traditional evaporative cooler for better comfort and control. Federal standards mandate a minimum SEER rating of 13. These air conditioners are very miserly with energy use and are a 30 percent improvement over the previous standards of just a few years ago.
Moving up to the 15 SEER rating, as required by the new code, brings a whole new set of installation and furnace-compatibility issues to the table. The furnace must be the more deluxe (and expensive) variety of 90 percent model incorporating a modulating speed blower in order to attain the required matched rating. You likely won't be able to use your existing furnace, even if it was recently replaced.
And how much will a 15 SEER air conditioner save in operating costs over the 13 SEER? By one calculation we ran on a 20-year-old, 1800-square-foot home, $26 a year.
Since in this instance a relatively new furnace had to be replaced in conjunction with the air conditioner installation to meet the 15 SEER standard, there was no economic payback.
Another real concern is enforceability. The code mandates equipment in excess of current federal minimum efficiency standards. These mandates are not performance-based codes and are unenforceable without a waiver of federal pre-emption from the U.S. Department of Energy. This waiver has not been applied for so the code certainly will be challenged in court.
Establishment of unenforceable building codes will discourage proper permitting opening the door to unlicensed, unsafe and improper installations. Many installers will simply try to "fly under the radar." In California where Title 24 (a similar code) is in effect, compliance is estimated at less than 10 percent.
Like all good citizens I am in favor of using energy-saving appliances. Roughly 70 percent of the equipment we sell to add-on and replacement customers already meets the proposed requirements.
But these high efficiency systems need to be applied intelligently. To rigidly stick with arbitrarily high standards in applications where there is no hope of a reasonable return is just plain silly.
The code is not all bad, but as it is currently written, is seriously flawed, will likely be challenged and is in need of reasoned review.
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