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ACCA and MACC Submit Joint Comments on NY Refrigerant Rule 

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ACCA employees

ACCA 2024 provided a timely venue to develop a unified response to New York State’s precedent setting Part 494 Hydrofluorocarbon Standards and Reporting rule. ACCA generally defers to its ACOs on matters of state policy, but MACC is a smaller metropolitan association without a lobbyist of its own and ACCA was glad to lend a hand in the fight against this onerous regulation. 

The proposed New York rule is a perfect example of why ACCA sought federal pre-emption as part of 2020’s federal American Innovation and Manufacturing (AIM) Act. The AIM Act already caps the manufacture and import of HFCs, so New York’s attempt to accelerate that phase down does nothing for the environment and penalizes law-abiding contractors relative to those who will surely cross state lines for lower prices. 

The regulation then goes a step further to ban even lower GWP refrigerants like R-32 and R-454b as soon as 2030. Manufacturers have told us that residential and light commercial equipment using highly-flammable ultra-low GWP refrigerants like propane will not be widely available in time. They’ll have no choice but to pull out of the New York market entirely while alternatives are developed, equipment is certified, and building codes are updated. 

ACCA welcomes opportunities to lend a hand wherever precedent-setting regulations like this one threaten the viability of our industry.

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