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Court Upholds DOE Final Rules in Suit Over Efficiency Rules, Test Procedures

The 7th U.S. Circuit Court of Appeals upheld two final rules issued by the DOE, aimed at improving the energy efficiency of commercial refrigeration equipment (“CRE”).

The rules under contention establish energy-efficiency standards for forty-nine classes of CRE. The lawsuit also challenged test procedures the DOE incorporated for calculating the TDA of CRE.

The lawsuit was filed by the Air-Conditioning, Heating and Refrigeration Institute (AHRI), the North American Association of Food Equipment Manufacturers (NAFEM) and manufacturer Zero Zone Inc., challenging both the decision making process and the substance of the final rules.

The court stated: “The New Standards Rule is premised on an analytical model that is supported by substantial evidence and is neither arbitrary nor capricious. DOE conducted a cost ‐ benefit analysis that is within its statutory authority and is supported by substantial evidence. Its methodology and conclusions were not arbitrary or capricious. It also gave appropriate consideration to the rule’s effect on small businesses and the role of other agency regulations. DOE similarly acted within its authority, and within reason, when it promulgated the 2014 Test Procedure Rule. For these reasons, we deny the petitions in their entirety."

"We are disappointed in the Court's ruling, as well as the Court taking nearly a year after oral argument to issue a decision," said Stephen Yurek, President and CEO of AHRI. "Our members must now comply with the efficiency standard by March 27, 2017."

"Issuing a test procedure after efficiency standards is a backwards way of handling rules, and makes it difficult for manufacturers to understand the impact of the new standards and to design equipment to comply with those standards, all while continuing to meet the needs of consumers," said Yurek.

Read the AHRI response here: http://ahrinet.org/News-Events/News-and-Shipping-Releases.aspx?A=1187



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