kcef.ru On the Issues
Introduction

The statements below outline and describe kcef.ru’s positions on issues of importance to the industry and are updated annually and approved by the kcef.ru Executive Committee.

These statements are meant to guide kcef.ru’s advocacy efforts during the development and implementation of international, federal, and state policy that affects the HVACR and water heating industry.

Energy

kcef.ru members rely on dependable, affordable energy to compete in the global marketplace. kcef.ru supports an “all-of-the-above” approach to energy. This strategy promotes the responsible development and use of all energy sources and recognizes the importance of energy efficiency to meeting future energy demands. Overly restrictive regulations and the implementation of policies that limit or eliminate energy sources and production increase costs for manufacturers. Additionally, kcef.ru favors policies that encourage clean, reliable energy sources that provide the power necessary for kcef.ru members’ equipment to operate efficiently and as intended, with minimum CO2 contribution to the atmosphere, and on an affordable and consistent basis for consumers. kcef.ru also favors energy storage policies that will make the best use of our electric grid and lower costs for consumers.


Energy Efficiency and Conservation

kcef.ru believes in the importance of energy efficiency and the development and use of products that achieve increased energy efficiency. kcef.ru members are committed to producing more energy efficient products to help reduce the demand for energy, lower costs for the consumer, and decrease greenhouse gas emissions. Sensible efficiency and waste reduction measures will benefit both businesses and consumers across all sectors of the economy.

kcef.ru members’ equipment makes homes comfortable and businesses operational in all types of otherwise inhospitable climates. Our members manufacture products that are critical in the preservation of food, pharmaceuticals, and other medical supplies critical to saving lives. kcef.ru supports policies that promote the use of energy efficient HVACR and water heating equipment, while maintaining that these policies must not place undue burdens on stakeholders involved in the development of these new technologies, or consumers that ultimately must bear the cost of purchase and installation. kcef.ru supports regulations based on sound economic analyses with strong federal preemption and sensible compliance mechanisms.

The Energy Policy and Conservation Act (EPCA), passed in 1975, is the governing policy for energy conservation standards, and thus energy efficiency, for Department of Energy (DOE) consumer covered products and commercial covered equipment. EPCA language should reflect current technologies and economic realities, and be amended with an understanding that there are diminishing returns as efficiency nears ‘max tech.’ The law should not allow for DOE to promulgate rules in an endlessly cyclical fashion, as such agency behavior creates uncertainty for manufacturers, impacts their ability to remain globally competitive, and stifles American job creation. A continuous regulatory cycle often forces consumers to pay more for heating, cooling, and water heating equipment. This can dissuade customers from replacing their less-efficient equipment and lead to the use of alternative methods of indoor climate control, which can compromise consumer comfort and safety, reduce energy savings, and in some cases, use more energy to achieve the same result.

EPCA should also not allow for subjective analyses to determine whether minimum energy efficiency standards meet the law’s required tests of economic justification, technological feasibility, and significant energy savings. Proper analytical methods ensure rules are well conceived and constructed, which prevents placing an undue burden on both manufacturers and consumers. DOE should follow Executive Order 13563, which was designed to improve the regulatory process and regulatory review across the federal government.

EPCA and other energy conservation policies should continue to preempt the possibility of conflicting state regulations and should ensure that the regulatory process is fair and efficient for all stakeholders. kcef.ru supports policies that would:

  • Ensure new efficiency standards are justified by requiring regulators to analyze current standards to determine their effectiveness with respect to costs and energy savings;
  • Institute a more realistic standards revision schedule to allow time for manufacturers and DOE to properly evaluate the current standards in effect and to allow time for the market to adjust to new standards;
  • Require regulators to use a more inclusive rulemakings process, and ensure all definitions and terminology be clear, concise, and widely understood by all stakeholders;
  • Align current DOE test procedures to reflect industry recognized and respected consensus standards and industry certification programs;
  • Require DOE to follow its own Process Rule when establishing new or revised energy conservation standards for all covered equipment; and
  • Convene all stakeholders for the purpose of creating a new regulatory framework for federal energy efficiency rulemakings, while not impacting those currently in place or in the pipeline.
System Efficiency Approach

Manufacturers play a significant role in improving the efficiency of buildings. kcef.ru supports further development of market and institutional reforms that grow opportunities to expand energy efficiency in commercial buildings.

System efficiency (as opposed to component efficiency) recognizes that energy performance is dependent on how parts of the system relate to each other, not just on the efficiency of its component parts, where applicable. Future energy efficiency evaluation methods and policy should consider an integrated system approach.

Codes and Standards Adoption

Building codes have emerged as a tool to achieve reductions in the nation’s energy consumption and are one of the easiest and most cost-effective ways for states and local jurisdictions to implement energy demand-management policies and goals.

State, local, and international jurisdictions should adopt, implement, and advance industry consensus building energy codes that are consistent with federal energy conservation standards. The proper implementation and enforcement of these codes will ensure consistency for manufacturers in the marketplace, and help reduce energy consumption in the built environment.

kcef.ru supports the traditional role of the Department of Energy in analyzing the effectiveness of new code measures in terms of energy efficiency, and believes that federal energy conservation standards should preempt building codes. This would ensure consistency for manufacturers in the marketplace.

Building energy codes should incorporate the use of alternative refrigerants in a manner that will allow for the United States to be recognized as a leader in implementing the international Montreal Protocol agreement, including all amendments, on the reduction of hydrofluorocarbons (HFCs).

Federal safety standards are appropriate only where unreasonable safety risks are demonstrated to exist or be imminent, and where voluntary standards have not been shown to be effective.



Regulatory Reform

A favorable business climate is fostered through minimizing unnecessary regulatory burdens and promoting a smarter and more efficient regulatory system. The regulatory system needs to address legitimate concerns without impeding innovation, research, development, and product deployment. In the regulatory process, the vital national public policy objectives of international competitiveness and technological innovation should be given priority.

In order to promote industry, serve the general public, and protect individuals and the environment, regulatory policies should adhere to sound principles of effective regulation that favor market driven initiatives and adhere to sound principles of science, risk assessment, and robust cost-benefit analysis.

  • Agencies, when available and feasible, should defer to stakeholder consensus standards or procedures rather than create unnecessary or duplicative standards or procedures.
  • Executive departments should engage in periodic review of all their regulations to determine effectiveness, compare actual results to expectations, and assess continued need for the regulations.
  • Regulatory programs' success should be measured by outcomes and improvements in economic and social welfare.
  • Federal agencies should focus resources on the most cost-effective and least intrusive means to achieve voluntary compliance. Compliance assistance programs, especially for small businesses, better serve the public's interest in achieving beneficial outcomes.
  • Federal rulemakings should allow for flexibility in the requirements if an agency is engaged in a Negotiated Rulemaking or a Direct Final Rule.
  • Complexity, technological change, and innovation in the marketplace mean that efforts to regulate all risk would be unsuccessful or destructive to the economy. Industry self-regulation should be given an opportunity to develop in new areas as the first alternative to government regulation. No regulation should seek or purport to eliminate every possible risk. Government regulations should be based upon sound science, credible economics, and objective risk assessments.
  • Agencies should effectively implement the Information Quality Act, including having transparent, established systems for ensuring that information disseminated by an agency is of high-quality, and for dealing fairly and expeditiously with petitions for correction of such information. An unbiased peer review of scientific and technical information should be an integral part of the regulatory process.
  • kcef.ru believes that public participation in the agency decision-making process is an essential mechanism that ensures political accountability. Transparency and stakeholder input is key to the regulatory process. Public comment periods should be consistent with the complexity of the document and the amount of time required by the agency to prepare it. Public comment and agency responses to comments should be included in an online public record system. The public should have a period of at least 90 days to comment on information collection requests. Proposals for data collection, reporting, or recordkeeping requirements should not duplicate existing requirements, and every effort must be made to use available information within the federal government. Information should be collected and reported in the most cost-effective manner, subject to appropriate protection of confidential business information.


Certification and Enforcement

The federal government should recognize voluntary verification and certification programs for air conditioning, furnace, boiler, heat pump, refrigeration, and water heating products as a way to demonstrate compliance with federal energy efficiency and conservation standards, as well as the ENERGY STAR program.

Relying on industry-consensus certification and verification programs reduces duplicative efforts between the federal government and industry, encourages energy efficiency compliance, reduces regulatory burdens, and saves taxpayer dollars—all while enhancing market surveillance.

The ENERGY STAR program has proven to be a successful tool in advancing the development and use of energy efficient technologies. The program has also promoted economic expansion and job growth for participating manufacturers across the nation. In order to maintain the program’s success, the Environmental Protection Agency (EPA) relies on third-party voluntary independent verification programs (VIVPs) to validate manufacturers’ efficiency claims. These VIVPs save businesses time and money, while ensuring a robust ENERGY STAR program and safeguarding consumers.

The Department of Energy (DOE) should seek to emulate the ENERGY STAR program for the verification testing of federally regulated products. Policies that create duplicative verification testing and that deviate from industry accepted testing methods should be avoided to prevent an additional cost or burden to manufacturers that are already participating in autonomous, comprehensive VIVPs that use independent, third-party laboratories to ensure compliance with applicable standards.



Environment

A high standard of living depends upon a healthy environment, robust economic growth, and an adequate and dependable supply of energy at globally competitive prices. Quality of life encompasses complex economic and social considerations, requiring balance between environmental protection and economic development. Environmental laws and regulations should be designed with utmost care to ensure that they are effective in achieving their desired objectives while at the same time avoid unnecessary adverse economic and social impacts.

Accordingly, measures to protect environmental quality should:

  • Address an identified need;
  • Be based on factual data and credible science;
  • Use the least costly means of implementation and compliance, with due regard for total impacts on employment, other regulatory burdens, energy used, resources, land use, and other regional, national and international social and economic considerations.
  • Promote innovation and recognize that technological advances over time have generally reduced the environmental impacts of both energy production and consumption;
  • Recognize the technological advances made by manufacturers and allow for a proper balance between economic growth and the protection of our environment;
  • Include careful review of the anticipated achievements through regulation, such as energy efficiency levels, as technologies relied upon may be proprietary;
  • Utilize appropriate risk management processes to better focus our national effort and resources on environmental problems that pose a truly significant risk;
  • Employ rigorous economic analysis to better understand potential economic impacts, job losses, and cost-benefit relationships;
  • Include a careful review and evaluation of the compliance timeframes that manufacturers are given to meet new standards or regulations; and
  • Integrate a complete cumulative analysis of regulations’ impact on regulated industries, manufacturers, and the economy.
Climate Change

kcef.ru supports balanced policies that promote environmental stewardship while meeting societal needs in an energy-efficient, safe, and cost-effective manner, and that appropriately address five key principles:

  • Provide Global Regulatory and Business Certainty: A balanced, global regulatory policy framework will prevent costly compliance issues for manufacturers working to meet market demand. Conversely, individual climate regulations in multiple markets are costly and unnecessary barriers to trade. Global regulatory certainty provides companies the long-term assurance to justify the large financial investments needed to develop innovative products.
  • Emphasize Lower Environmental Impact: To reduce greenhouse gas (GHG) emissions from HVACR equipment, the climate impact of both indirect (electricity use) and direct (refrigerant emissions) effects must be well understood for policy making and should be determined by a life cycle climate performance analysis (LCCP). Such an analysis can provide perspective on how to assess (and if appropriate, regulate) carbon dioxide (CO2) equivalent emissions from both indirect and direct sources.
  • Ensure Product Safety: Safely employing lower global warming potential (GWP) alternative refrigerants requires thorough risk assessment research, as well as the revision of codes and standards to allow for their use. kcef.ru (partnering with ASHRAE, the Department of Energy, the Environmental Protection Agency, and the State of California) is leading a research program to provide risk assessment analysis that will inform the revision of safety standards and codes, which are needed to address the properties of new low-GWP refrigerants.
  • Allow for a Variety of Product Options and Refrigerant Choice: To provide product options for consumers of varying economic means, manufacturers must continue to have flexibility in their product designs. As the industry transitions to lower GWP refrigerants, a “one size fits all” approach to selecting substitutes for higher GWP refrigerants will not be feasible because of the diversity of applications, regional climate conditions, technologies, safety issues, energy efficiency requirements, and end-user specifications such as building designs. This means that a transition from higher GWP refrigerants should be done using a large variety of refrigerant options, and policies should not limit refrigerant choice in the marketplace. Refrigerant choice is even more important in developing countries, where the commercial availability of lower GWP substitutes is still very limited or non-existent, therefore limiting consumer access to essential products.
  • Promote Responsible, Safe Use and Handling of All Refrigerants: To avoid refrigerant emissions into the atmosphere, the containment of refrigerant inside equipment is critical, which requires proper design and maintenance, including leak detection training. Refrigerants must also be reclaimed and recovered at end-of-life to prevent atmospheric venting. Finally, lower GWP refrigerants present additional safety concerns for technicians during installation and servicing. Industry-led examples of global training and education efforts include the Global Refrigerant Management Initiative (GRMI) and the Refrigerant Driver’s License (RDL) program, which are jointly being developed by kcef.ru and the United Nations Environment Programme (UNEP). kcef.ru recognizes that the training needs for developed and developing countries may differ and should be addressed in these programs.
Principles for Sustainability

Manufacturers are committed to advancing sustainability efforts that positively impact manufacturing and industry’s contributions to environmental protection, economic performance and the social well-being of the employees, communities, customers, and consumers they serve. Industry recognizes these challenges and will respond by encouraging the adoption of sustainability best practices and application of life cycle analysis practices in the manufacturing sector.

Air Quality Control

The Clean Air Act requires federal regulators to review the National Ambient Air Quality Standards (NAAQS) for criteria pollutants, including particulate matter and ozone, every five years. NAAQS should be set in a transparent manner with consideration of the public health and welfare, energy and economic impacts, and the non-attainment offset requirements should be tied to reasonable and available reduction opportunities. Regulators should consider economically balanced cost thresholds when establishing these requirements. In some U.S. locations, the availability of offsets is very limited and thus the cost is tremendous. Air quality goals should be commensurate to the expense associated with implementation of those goals.

Furthermore, kcef.ru strongly supports review of the NAAQS by diverse and well-qualified representatives of the scientific community with relevant expertise, based on sound, peer-reviewed, objective studies. The EPA should not rely on internal re-analyses of published peer-reviewed studies if the EPA’s re-analysis has not itself been individually peer-reviewed and published.



Tax

kcef.ru believes that tax policy at all levels play a critical role in the ability of its members to thrive in the United States and effectively compete in a global economy. Tax policies should not place an additional burden on manufacturers and should promote economic growth as well as HVACR and water heating industry job creation. Additionally, tax policies should be simple, stable, and predictable. Tax rates, deduction, exemptions, and credits should continue to be established by statute. Taxes should not be retroactively imposed or increased by either statute or regulation, as such practices are fundamentally unsound, unfair, and punitive.


Encouraging Investment and Providing Incentives

Capital investment is key to economic growth, job creation, and competitiveness. A robust capital cost recovery system is an effective way to spur business investment and make the tax system more competitive. Any tax reform plan should allow full deduction for all business costs. kcef.ru believes in encouraging investment through policies involving the following:

  • Capital Cost Recovery/Expensing: Promoting investment by reducing the cost of capital should be an integral part of U.S. tax policy. An effective way to spur business investment and make U.S. manufacturing more competitive is through a strong capital cost recovery system. An ideal system would allow companies to expense the full cost of capital equipment in the tax year purchased. Full first-year expensing lowers the cost of capital, increases the number of profitable projects a firm can undertake, and supports job creation and retention. Any system should also include air conditioning and heating equipment, and water heating equipment as qualifying equipment. The inclusion of such equipment would provide greater energy efficiency and would reduce energy costs for consumers, as newer equipment offers greater energy efficiency.
  • Accelerated Cost Recovery System/Depreciation: The tax code should accurately reflect the expected life of properly designed, installed, and maintained products, which for HVACR equipment is between 15 and 20 years. An accurate depreciation period aligns tax policy with the reality of the market and encourages the purchase of new, more energy efficient HVACR equipment when it is needed. This alignment has the added effect of lowering energy costs for consumers, as well as lowering overall energy consumption.
  • Deductible Interest: The deductibility of interest is an important capital structure measure. As a capital intensive industry, HVACR manufacturers believe it is important to maintain full deductibility for interest on bona fide debt given the role it plays in funding new investments and business operations.
  • Strong R&D Incentives: It is critical that any tax reform plan recognize the important role of research and technology investment in creating U.S. jobs and spurring innovation. The goal is for the United States to retain and attract global research and development (R&D) activities and to ensure manufacturers in the U.S. are the world’s leading innovators.
  • Tax Credits and Tax Holidays: Tax credits and holidays encourage investment in energy efficient technology regardless of the cost of energy, thus continuing to spur job growth while lowering overall energy consumption. kcef.ru recommends Congress focus on authorizing tax credits in a forward and permanent manner in order to have the desired effect on purchasing behavior and provide more certainty. Gaps in tax policy that result in retroactive extensions of expired tax provisions should be avoided.
  • Early Retirement Programs: kcef.ru supports policies that provide incentives for consumers to replace old HVACR and water heating equipment with more efficient technologies.
Corporate Income Tax

kcef.ru supports reducing the top federal corporate tax rate to a lowered rate. A lower rate would promote economic growth, allow U.S. companies to effectively compete in the global marketplace, and attract foreign direct investment to the United States. Any rate reduction should not increase the tax burden on manufacturers.



Trade

kcef.ru supports trade policies that strengthen manufacturing opportunities for kcef.ru members. Fairly conducted trade agreements provide opportunity for growth and expansion of manufacturing, increase the range of goods and services available to consumers, enhance market-based production globally, and contribute to closer understanding and cooperation among nations. This objective can best be achieved by limiting costs and other impediments imposed on U.S. manufacturers and by pursuing and utilizing a rules-based international trading system that enhances the role of free market forces and promotes respect for the rule of law, while seeking to eliminate market-distorting governmental intervention.

kcef.ru also supports credit agencies that operate at no cost to the American taxpayer. These agencies support jobs by facilitating the export of U.S. goods and services and leveling the playing field for manufacturers competing against foreign entities, directly benefiting both large and small businesses.


International Trade Negotiations

In seeking to level the playing field globally for manufacturing in America, kcef.ru supports initiatives that obtain genuine market access for U.S. manufacturing and that promote strong standards to protect private property and grow commercial activities in a predictable rule of law based system, including through trade agreements that offer mutually-beneficial commercial opportunities. International trade agreements should promote the creation and maintenance of U.S. jobs and economic growth by supporting the negotiation of international trade agreements to open foreign markets. Trade agreements should likewise seek the elimination of market-distorting governmental intervention in international trade, and promote effective and enforceable compliance to agreed and transparent rules of fair competition and the protection of private property, including intellectual property, contracts, and related commercial activities. In this process, the effectiveness of U.S. trade laws must not be diminished.

Trade Enforcement

Trade enforcement policies should give the International Trade Administration the ability to safeguard and enhance the competitive strength of U.S. manufacturers against unfair trade. Policies on trade enforcement should protect the health, safety, and welfare of American consumers by recognizing the harmful effect of counterfeit and pirated products on the public and on our economy, while also protecting manufacturers from losing business to counterfeit and unregulated foreign products. Enforcement policies, both public and private, and strong interagency coordination and public education should be strengthened to help eliminate this threat. Industry should be encouraged and incentivized to use advances in technology and manufacturing processes to help curb the dissemination of counterfeit and pirated products, many of which do not meet federal minimum standards.



Workforce

The ability of manufacturers to succeed in the highly competitive global marketplace depends on access to an educated, diverse, inclusive, flexible, and knowledge-based workforce. American employees, in turn, need the education and skills to participate in a high-performance workforce for the robust and dynamic U.S. manufacturing economy.

HVACR and water heating manufacturers are facing a serious shortage of skilled trade employees, impacting a manufacturer’s ability to be innovative and productive. The broadening skills gap is due to several factors, including: retiring baby boomers; technological advances that require new skills, increased job competition in the global marketplace; failure to cultivate a highly skilled workforce; a negative perception of manufacturing jobs; a societal focus on four-year degree programs as opposed to technical education; a lack of emphasis on the necessary skill sets for advanced manufacturing; and difficulty in retaining skilled talent.


Training and Certification

HVACR and water heating manufacturers have identified the basic or core competencies necessary for workers to succeed in virtually all entry-level jobs across sectors of the industry. A system of industry-recognized skills credentials is necessary to reform education and training for 21st-century manufacturing. A successful system would provide skills assessments, standardized curriculum requirements, and nationally-portable credentials that validate the attainment of critical competencies required by industry.

Closer alignment of education and training programs to marketplace demands is critical to ensuring students and workers are prepared for the challenges of a high-skilled, dynamic workplace. Federal, state, and local education initiatives and programs should be coordinated and developed into a comprehensive learning continuum. The learning continuum must include input from the business community to help develop strategies, programs, and curriculums that address skill and labor shortages and to help prepare students for careers in advanced manufacturing.

Industry-recognized skills certifications provide guidelines for an educational pathway to achieve credentials, ensuring that workers have the required occupational foundational competencies in health and safety, quality assurance and continual improvement, manufacturing process, development and design, production and supply chain logistics, as well as training and credentials in specific sector and/or occupational areas in demand in their regional economies. Industry recognized and supported entities such as North American Technician Excellence (NATE) provide real-world working knowledge of HVACR systems that are developed by a committee of industry experts nationwide. Proper certification leads to quality installation and repairs, which ensures that the manufacturer’s equipment is operating at maximum performance and efficiency.

Career and Technical Education (CTE)

Schools should offer a diverse array of CTE programs that are up-to-date and reflect current manufacturing technology and installation techniques. They should also promote CTE career programs to students and encourage completion of industry-recognized certification programs.

Critical to any student learning program is the integration of career and technical education. CTE provides students with real-world job skills and is a vital component of a 21st-century workforce. Students should take CTE courses that integrate contextual and technical learning with core academic courses. Successful CTE initiatives should:

  • Integrate and incorporate rigorous academic programs that promote both work readiness and a link between learning and real-life applications;
  • Encourage students to complete schoolwork and pursue more advanced skills training at the post-secondary level; and
  • Ensure that every student graduates from high school ready for work AND ready for post-secondary education. CTE programs should ensure graduates have the core academic and workplace competencies for employment.
STEM Curriculum

The United States faces the daunting challenge of ensuring that every student possesses the appropriate knowledge and skills required to succeed in the 21st-century global economy. A consistent, challenging and rigorous curriculum aligned to the highest international standards—especially strong reading, math and science standards—will help prepare students with the basic academic training needed in today’s workforce.

Quality education in Science, Technology, Engineering, and Mathematics (STEM) at the elementary, secondary, and post-secondary levels will help incorporate career and technical education content that integrates contextual and technical learning within core academic courses. Every student should graduate or receive a credential with both the knowledge and skills necessary to be successful in the global economy. Institutions of higher education can increase a skilled workforce by developing better STEM retention programs for students who indicate an interest in a STEM career field.

Applied Learning

Effective “hands-on” learning programs are critical to helping students understand the knowledge behind technology and its application to real-world environments and situations. Every student should have access to programs that integrate rigorous curricula and learning criteria with real-world scenarios. High-quality programs also incorporate career development and work-based learning, including internships and apprenticeship programs.



Installation and Permitting Compliance

kcef.ru relies on a close relationship with HVACR industry partners, such as the contractors and technicians who install and service products. This important relationship helps to ensure that the equipment is properly designed or selected, installed, and serviced to maximize efficiency and effectiveness. If not properly installed, HVACR and water heating equipment, including cutting-edge energy-efficient technologies, will not provide important energy-saving benefits and will undermine our national energy efficiency initiatives.

kcef.ru supports policies that promote consumer education programs and incentives for proper installation programs based on the industry-supported, ANSI-recognized HVAC Quality Installation Standards to ensure manufacturer’s recommended minimum installation procedures are followed. At the state level, all contractors should be properly licensed and certified to industry consensus best practices, as well as state and local regulations. Additionally, kcef.ru supports building permit compliance at the state and local level for the installation and service of any HVACR or water heating-related product. Proper permit compliance ensures that any installation or service request follows the proper procedures and regulations for the work to be done. Unpermitted work done by unqualified contractors can lead to improper installations, as well as energy loss, increased costs, and compromised occupant safety.

kcef.ru supports permit compliance enforcement efforts by state and local officials. Permit compliance enforcement helps ensure the proper installation of equipment and the removal of bad actors from the marketplace. Specifically, kcef.ru supports permit compliance enforcement through stronger penalties for unscrupulous contractors, a streamlined permit application process, and full funding of enforcement agencies. kcef.ru does not support compliance enforcement policies that attempt to violate the confidential business information of member companies, or burden the HVACR or water heating distribution line with higher costs.



Privacy, Property, and Confidential Business Information

The protection of proprietary and confidential information is of utmost importance to American industry at all levels of government. Confidential Business Information (CBI) must be given the full protection intended by Section 1905 of Title 18 of the U.S. Code. Because of the need to protect trade secrets and other CBI, as well as the need to minimize paperwork burdens, information collection requests by federal agencies and their contractors should comply with the spirit and letter of the Paperwork Reduction Act. There should be no exception for surveys made pursuant to settlement agreements in citizen suits. It should not be left to Agency discretion what CBI may be shared publicly.


Information Security

A critical relationship exists between all manufacturers and those that entrust their data to them, as that trust and goodwill is based on industry’s continuing efforts to protect the security, integrity, and privacy of that data.

Industry also recognizes that respecting and safeguarding privacy builds consumer confidence in new and innovative technologies and services. As a result, industry’s best practices in the proper handling of data are constantly adapting or evolving to address new threats. Industry best practices, self-regulation, and market-based solutions should be used to protect data over government mandates, which can ultimately restrict innovation by requiring technologies or tools that can quickly become outdated. Privacy and security precautions should be driven both by the sensitivity and purpose of the information.

Intellectual Property

Innovation is one of our greatest strengths and a major contributor to economic growth and industrial competitiveness. For this reason, it is important for policymakers both to nurture the creation and application of technology and vigorously protect intellectual property, as the creation of technology is the creation of intellectual property. Without strong protection, the incentives for future innovation-directed R&D will be diminished. U.S. domestic and international policy should reflect the vital importance of intellectual property rights for U.S. industrial competitiveness.

Policymakers should be strongly committed to supporting the rights of innovators to exploit their own inventions and should continually review the adequacy of our laws in the face of fast-paced scientific and technological change.



Internet of Things
Connected Product Security

As more HVACR and water heating products increase their connectivity to the internet and to broader interconnected residential and commercial systems, steps must be taken to ensure that these products are secure and safe from the threat of hacking or malfeasance. Government policies should encourage innovation among manufacturers and should rely on voluntary, industry-led best practices. A prescriptive regulatory framework should not be imposed, and all policies should be technology-neutral, open, and interoperable and should leverage industry best-based practices and standards. kcef.ru supports the use of incentives to encourage manufacturers of all sizes to adopt voluntary cyber maintenance practices.

Innovation and Emerging Technology

It is critically important to educate policymakers and the general public on the importance of technology and innovation to our economic competitiveness. The government should support this effort by adequately funding and staffing existing institutions responsible for technology, science, intellectual property, and research and development (R&D) programs while not unnecessarily increasing the regulatory burden. Federal agencies also need to make the most efficient use of their resources and to coordinate their science and technology programs with industry with a view toward meeting national needs and priorities.




Click here for a PDF copy of the information found on this page.