2026-06-12 Comment response to the published Notification of petition for waiver and grant of an interim waiver; request for comments
Heatcraft Refrigeration ProductsOpposeBusiness
Summary: Heatcraft, a manufacturing company, opposes specific modifications to test conditions and tolerances in the proposed alternative test method. They argue that these changes would weaken measurement rigor and should instead be developed through a formal industry-wide process.
Heatcraft does not support the part of the proposed alternative test method that allows modifications to the test conditions and tolerances in sections 3.1.1 and 3.1.4. These modifications would materially weaken measurement rigor and risk inflating AWEF values in ways that do not translate to field performance. Modifications to the test conditions and tolerances should be developed through a formal, industry wide process rather than through a one-off waiver that could compromise comparability across manufacturers.