Citing poor cost predictions made during past rulemakings for central air conditioners and heat pumps, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) called on the U.S. Department of Energy (DOE) to be more "thorough and vigorous" during its next rulemaking process that began early June. DOE will use the rulemaking process to determine whether the minimum efficiency standards, which were increased in 2006, should be revised again by 2016.

AHRI's Vice President for Regulatory Policy and Research Karim Amrane testified June 12, during a public meeting in Washington, D.C., that DOE severely underestimated the cost increase from a 10 SEER to a 13 SEER system and cited a 9% drop in equipment sales since the 13 SEER mandate took effect. “This fact, combined with an increase in parts sales and room air conditioners is evidence that the new standard is not economically justified for many consumers.” He also said the energy savings estimated by DOE were probably overstated as well.

Furthermore, Amrane asked the energy department to "carefully study the impact of climate change legislation on the availability and price of HFC refrigerants." He said there is a real possibility prices will skyrocket and not enough refrigerant will be available to meet the new energy conservation standards, reveals the institute’s press release. Amrane explained that higher efficiency products require more refrigerant charge because they have larger evaporators and condensers.