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Refrigeration and Air Conditioning Institute of Canada

HRAI is the national trade association for manufacturers, wholesalers and contractors in the Canadian heating, ventilation, air conditioning and refrigeration (HVACR) industry. HRAI member companies provide products and services for indoor comfort and essential refrigeration processes. HRAI has over 1,350 company members, including over 80 manufacturer members that sell their product in the Canadian marketplace. and Canadian federal agencies under Phase I. HRAI supports these initiatives and is committed to the North American harmonization of product standards, product testing and certification requirements and federal and provincialHRAI supports the recommendations captured in the RCC's previous summary of findings1 as well as the broad themes sketched out in the Request for Comment:

Effective regulatory cooperation is about more than just regulations. It is possible that identical regulations could still contain duplicative requirements and verifications that hinder trade and increase costs. Regulatory cooperation must consider all facets of the regulatory system including regulatory policy, related programs and guidance, inspection and testing methods, and compliance and enforcement activities.2

HRAI considers the intervention of the RCC critical to the success of any regulatory alignment efforts relating to the HVACR industry. and Canada, we are committed to a bi national alignment of policies and regulations in the areas of energy Equipoise Ethics efficiency and product safety. We would welcome the opportunity to see these issues considered for Phase II of the RCC Action Plan.

Attached to this letter is a copy of a submission that was filed by HRAI in conjunction with the Air Conditioning, Heating and Refrigeration Institute (AHRI) in April, 2013. In those comments, we reported what we believe is a "disturbing trend" in which regulations for the HVACR and water heating industry are diverging, at both the national and provincial levels, and forming a patchwork of standards that imposes a significant non tariff barrier to trade. The effects of this

de harmonization include longer design cycles, potentially more expensive products and fewer choices for consumers within the affected regions. Please refer to Table 1 of the attached document for a listing of products affected.

The StakeholderRequest for Comments identified some key areas where stakeholder insights would helpful. Accordingly, we offer some "Anaboliset Aineet" commentary in on several of those key areas. regulators on regulatory cooperation opportunities and the Action Plan implementation. regulators in discussions about how to harmonize regulations, both between countries and among provinces within Canada. First and foremost, however, the regulatory bodies of interest must be prepared to engage with their counterparts across the border. Environmental Protection Agency (EPA), Natural Resources Canada (NRCan) Health Canada, Environment Canada, and all the Provincial ministries responsible for regulating energy, the environment, product safety and building codes.

As noted in the HRAI/AHRI submission in April, there are troubling examples of products for which NRCan and the DOE separately and independently develop energy efficiency regulations, which are then added to by provincial regulators. In Gensci Jintropin addition to the costs of duplication to manufacturers, the current lack of harmonization puts the burden on industry groups like ours to maintain political engagement in multiple arenas. Our manufacturer members create products for all markets in North America, so it would be very constructive for RCC to compel cooperation between these agencies to develop regulations jointly and to align their implementation timelines so that they do "Anabolika Definition" not adversely affect industry. Processes need to be developed that will facilitate cooperation among these groups, and these processes must include consultation with the affected industries. trade.

Recommendations on how to augment standards cooperation between our respective countries both public Anavar Que Es and private sectors to support and build on the RCC work.

There is a need to establish clearer rules, or to better enforce existing rules, for standards writing bodies so that they avoid duplication and redundancy. The current model for standards development often allows the process to be driven by government and utility agendas (with industry left scrambling to keep up). On occasion, the standards writing and review process has become a de facto government funded tool for energy efficiency regulation, with little regard for cross border harmonization or the impacts on industry.

There are a number of elements to this problem. For example, while CSA 4-chlorodehydromethyltestosterone Technical Sub committees (TSCs) are required to have a balanced membership matrix, CSA Technical Committees (TCs), which actually vet the standards that are to be reviewed by the TSCs, lack the same mix of interests and expertise (and therefore may be vulnerable to the specific agendas of regulatory bodies, utilities, or others with a specific commercial interest).

Furthermore, while "Project Proposal Forms" (PPFs) are required to initiate a standards review, and while this form requires that some consideration be given as to whether there are already existing standards that suit the purpose, TCs can and sometimes do ignore this requirement, or they simply exploit existing standards as "seed documents".

HRAI recommends that more stringent control processes should be applied by the Standards

Council of Canada (SCC) to ensure that this sort of unnecessary duplication is minimized.

Recommendations on how to institutionalize regulatory cooperation between our two countries.

As noted above, it is critical to the harmonization of standards and regulations that national regulatory bodies engage constructively with their counterparts across the border. Towards this end, HRAI recommends that the RCC commit to the development of a "working group" between NRCan and the DOE, specifically to compare and align their regulatory agendas and implementation timelines in a way that will not adversely affect industry.

HRAI Deca Durabolin Effet Secondaire also notes that there is clearly interest on the part of the Canadian Government to address the regulatory burden on industry, through initiatives like the Red Tape Reduction Commission, which include requirements for "regulatory burden analysis" to be conducted when enacting new regulations. HRAI applauds this approach but recommends that all such analysis should include consideration of how to avoid new regulations unnecessarily contradicting existing regulations from other jurisdictions where these contradictions result in additional burdens to industry, (except Buy Viagra Berlin where there is some defensible policy rationale).

Opinionson moving forward on the next phase of Canada United States regulatory cooperation through mechanisms such as agency to agency cooperative arrangements. We welcome ideas on how to advance them where they already exist and create them where they are non existent.

As noted previously, the HVACR industry has concerns not only about the lack of harmonization between our two countries, but also among provinces and territories within Canada. In particular, there is a need to build better processes for ensuring consistency of energy efficiency regulations. There are, however, some existing tools that may be of assistance in overcoming the discrepancies. The Canadian Advisory Council on Energy Efficiency (CACEE), a committee of representatives from provincial ministries, addresses some of these matters, but nothing that comes out of their discussions is binding on provinces. With appropriate federal funding and a

clear mandate to develop model regulations for provinces to consider, this process might be more effective. Short of recommending that provinces be bound by these sorts of collaborative processes, there are some constructive ways to maximize the likelihood of harmonization. A useful model that might be considered is the Provincial/Territorial Policy Advisory Council (PTPAC) of the Canadian Commission on Building and Fire Codes (CCBFC) which oversees code development and the writing of the model national building code (NBC). Because provinces are faithfully consulted and have a say in its development, they are more likely to buy into, and less likely to deviate from the model national building code that comes out of this process.

This process should be emulated in the development of provincial energy efficiency regulations. Constitutional jurisdiction issues preclude a national "one size fits all" approach, but through meaningful collaboration among provinces in the development of national "model" regulations and policy, a greater level of harmonization might result.

Details on measurable benefits for industry, government, and/or consumers that can be quantified and shared, which occurred as a direct result of a current RCC initiative.