The Air Conditioning Contractors of America (ACCA) provided an in-depth response to a proposed "California Energy Efficiency Strategic Plan."

The strategic plan was proposed by the California Investor Owned Utilities, which includes Pacific Gas & Electric, San Diego Gas and Electric, Southern California Edison, and Southern California Gas. The plan came about due to dissatisfaction with California's Title 24 energy code verification plan on the part of the California Public Utilities Commission, and followed a series of stakeholder meetings around the state in which ACCA participated representing California contractors.

While generally supportive of the goals of the strategic plan, ACCA offered several insights into the practical realities of the hvacr marketplace and urged the utilities to embrace the national consensus on quality hvacr installation rather than create standards of their own.

Among ACCA's key recommendations regarding the strategic plan:

•         ACCA encouraged the utilities to immediately create an HVAC industry task group to assist in planning and implementation.

•         ACCA urged adoption of national "Quality Installation" and "Quality Maintenance" standards.

 •         ACCA asked California to embrace and incorporate training and education efforts of the HVACR industry in its plan, including baseline contractor training, contractor technician and sales staff training, code official training, and consumer education.

•         ACCA told the utilities that their proposal for an "internet-based tracking system that tracks the status of equipment from the initial sale ... to the final quality check" is impractical and not cost-effective.

•         ACCA said that any new requirements must have consistent, fair, and strong enforcement provisions in place. Otherwise good businesses will be placed at a competitive disadvantage against shirkers.

•         ACCA said that the plan did not address a fundamental issue, which is the need to strengthen California's contractor licensing laws to require continuing education and license reviews.

•         Finally, ACCA said that, while the plan did not specifically state a desire for the state to develop its own standards and equipment specifications, it alludes to it, and ACCA strongly urged the state to avoid creating its own standards and instead leverage existing national movements within the HVACR industry to improve energy efficiency and contractor quality.

ACCA's complete response may be read online at www.acca.org/testimony. The original proposal from the California Investor Owned Utilities is available at www.californiaenergyefficiency.com.