2012-02-06 Comment on different approaches for enforcement of this rule.

Approach 1 to the enforcement of this rule would be least intrusive and have minimal cost to the consumer. If contractors are educated to the proper equipment to be installed by the distributors, proper installations will result. Manufacturers should already be tracking serial numbers for equipment delivered to the distribution chain. A non-compliant unit could be tracked from the manufacturer to the point of distribution. The additional requirements of Approach 2 would add traceability from the distributor. Contractors will have to increase their record keeping if they are not tracking equipment. Approach 3 adds significant expense and asks for private information. Contractors are not willing to share the confidential locations of their customers with outside organizations unless problems arise. Distributors are similarly disinclined to share market information. We would prefer Approach 1 as least cost but believe Approach 2 is economically feasible, Approach 3 is excessive.