By Bradford White Corporation
At the beginning of this year, the New York State Department of Environmental Conservation (DEC) proposed amendments to how the state regulates HFC refrigerant gasses that are contained within appliances. While other states have been content to largely follow the lead established by the U.S. Environmental Protection Agency (EPA) on regulating these substances, DEC’s proposal represents an ambitious approach towards regulating these gasses that threaten regulatory stability in our industry.
HFCs, or hydrofluorocarbons, are refrigerant gasses that are vital to the operation of heat pump equipment such as air conditioners, refrigerators, and heat pump water heaters (HPWH). Their impact on the environment is measured by a metric known as Global Warming Potential (GWP), the higher a refrigerant’s GWP, the more impactful it is on the environment. EPA and others have recognized challenges that HPWH manufacturers would have in utilizing lower GWP refrigerants in the near future, which include product safety recertifications, as well as building and product redesigns. For that reason, these regulatory bodies have chosen not to regulate the GWP of HFCs in HPWHs at this time, instead allowing the market for these products to grow and mature before introducing additional complexities.
While Bradford White Corporation (BWC) understands the importance for a well-measured and responsible transition to lower-GWP refrigerants, DEC’s proposal would disrupt the stability of this transition in many ways, perhaps most seriously by including HPWHs in its scope. By doing so, DEC is bringing themselves out of alignment with EPA and others by compelling manufacturers of these products to utilize low GWP refrigerants as early as January 1, 2025, and then utilize what essentially amounts to a carbon dioxide refrigerant by January 1, 2027.
This would significantly limit the number of products that contractors and installers would be allowed to make available to individuals, families and job providers throughout New York State. Not only would these changes mean many manufacturers would need to engage in the actions discussed above (a process that would take well over the amount of time provided by DEC in this proposal), they would also drive higher prices for consumers on products that already have challenging upfront costs for low-to-medium income households.
BWC is working with PHCC and other trade associations to make the arguments above to DEC so that they will better understand the challenges inherited in their proposals and be convinced to take a more responsible regulatory approach. You can read the DEC’s proposal, and learn more about it on this webpage.
In the meantime, if you have any questions or would like any additional information about the DEC’s proposal, please do not hesitate to reach out to BWC’ government and regulatory affairs team directly and we will do all we can to supply you with the information you seek.
Furthermore, if you become aware of any legislative or regulatory proposals in your area that you believe our government and regulatory affairs team should know about, please contact us directly at BWCGovReg@bradfordwhite.com.
