State - Legislative

• Encourage state and local jurisdictions to establish clear scope requirements in their boiler and pressure vessel codes that specifically exempt HVACR and water heating equipment.
• Support building performance standard (BPS) program metrics that are fuel and technology neutral and compliance targets that permit the installation of minimum efficiency appliances.
• Support adoption of the most recent edition of building energy codes.
• Oppose legislative efforts that restrict or prohibit code making bodies from revising building codes and adopting energy conservation and efficiency updates.
• Support enabling the use of next-generation refrigerants through safety standards adoption into codes for all applications.
• Support energy conservation and efficiency building code updates that are fuel and technology neutral.

• Establish the greenhouse gas emission reduction goal, or desired end-state (e.g., emission reduction goal – how much, by when, considering the importance of incremental gains) by engaging with all stakeholders to identify and address opportunities and concerns.
  • The goal and steps to achieve that goal must be evaluated as being technically feasible and economically justified.
• The initial carbon reduction policies should focus on:
  • Reducing the heating and cooling load by improving structures and providing incentives to help those who cannot afford the cost of these improvements, especially in existing building stock.
  • Encouraging pro-active replacement of lower efficiency equipment and, where appropriate and cost effective, the installation of dual fuel systems, including incentives for low- and medium-income households and small businesses. 
• Establish different policies for new construction and replacements 
  • For new construction: 
    ▪ Reflect current best construction practices. 
    ▪ Recognize that none of us knows what the future of technology will hold; therefore, all policies should be performance-based and allow for adaptability.
     
  • For existing structures:
    ▪ Require cost-effective improvements to reduce heating and cooling loads and encourage installation of energy efficient equipment.
    ▪ Set policies with the understanding that most replacements occur in emergency situations -- no heating, cooling, or hot water – so consumers will demand the most expedient solution, usually a like-for-like replacement, unless they can make changes with minimal additional upfront costs.
• Address equity and environmental justice concerns through tax credits and utility rebates.

• Oppose regulatory and legislative efforts to ban the use of chlorocarbons as a refrigerant feedstock or where trace amounts of the chlorocarbon remain in a refrigerant after it is consumed or transformed in a closed system.
• Oppose policies that limit refrigerant choice.
• Monitor policies impacting refrigerant chlorocarbon emissions in manufacturing.
• Monitor hazardous waste definitions to ensure recovered refrigerant and reclaim are excluded.
• Oppose state legislation and policy that defines PFAS as containing a single fully fluorinated carbon atom, due to inadvertently including short-lived chemicals, including some refrigerants and the use of this definition in requirements related to articles.
• Support an exemption for U.S. Environmental Protection Agency (EPA) approved refrigerants. 
• Support exempting fluoropolymers, and embedded articles for HVACR and water heating appliances from PFAS phaseout and reporting legislation.
• Support indefinite currently unavoidable use (CUU) exemptions for HVACR and water heating products and equipment
  • Support a risk-based (hazard + exposure) approach to bans and reporting requirements and encourage states to focus regulatory efforts on Persistent, Bio-accumulative, and Toxic (PBT) chemicals in high-exposure products.
• Support PFAS exemptions for HVACR and water heating replacement parts, large-scale manufacturing equipment, and de minimis exemptions for articles containing less than 0.1% (by weight) of PFAS.
• Support targeted PFAS identification by its unique Chemical Abstract Service Registry Numbers (CASRN).
• Support “reasonably ascertainable” supply chain reporting requirements with minimum 24 months to create a tracing program and a list CASRN- identified covered chemicals. 

• Monitor legislative proposals that may impact corporate Environmental, Social, and Governance (ESG) commitments or Sustainable Development Goals (SDGs), including climate or emissions disclosure policies.
• Support state legislative proposals to harmonize policies across states and global trading partners that may impact corporate ESG commitments or sustainable development goals including climate or emission disclosure policies.

• Encourage consistent state data privacy policies and practices that ensure the proper handling of data through inclusion of industry best practices, self-regulation, and market-based solutions.
• Oppose state cybersecurity policies that do not include clear compliance pathways and those that expose manufacturers to undue liability.
• Support state cybersecurity policies that encourage innovation among manufacturers and rely on voluntary, industry-led best practices aimed at ensuring products are secure and safe from the threat of hacking or malfeasance.
• Support defining “reasonable security feature” as compliance via any one of the following: (1) consensus standards, including ANSI/UL/CSA 2900 or ANSI/CTA 2088; (2) a security rating from a certified body; (3) design features based on recognized guidelines, or NIST standards or guidelines.
• Oppose inclusion of a private right of action. 
• Support harmonization with existing state laws and include federal preemption provision. 
• Support exempting systems that are used in commercial buildings for building heating, ventilation, air-conditioning, control, automation, energy efficiency, and/or sustainability applications from Artificial Intelligence (AI) legislation.

• Support demand response programs and policies that encourage innovation and preserve the ability of manufacturers and consumers to utilize the best available technology.
• Support harmonization of demand response programs and policies with existing regulations and requirements at both the state and federal level, including the ENERGY STAR program.
• Support inclusion of AHRI Standard 1380 – Demand Response through Variable Capacity HVAC Systems in Residential and Small Commercial Applications and AHRI Standard 1430 – Demand Response for Electric and Heat Pump Water Heaters when states or utilities implement demand response programs and policies that target residential and/or small commercial HVAC or water heating systems, as applicable.

• Support state funding for utility-run energy efficiency programs.
• Work with state legislators, regulatory bodies, and the utility industry to support programs that would incentivize consumers to replace older, less efficient HVACR and water heating equipment with newer, more efficient equipment.
• Support legislative and regulatory actions seeking to provide financial incentives for the purchase and/or installation of energy efficient products and equipment.

• Promote the responsible development and use of all energy sources and encourage energy efficiency measures aimed at meeting future energy demands.
• Support state policies that encourage clean, reliable energy sources that provide the power necessary for AHRI members’ equipment to operate efficiently and as intended, with minimal impact to the environment, and on an affordable and consistent basis for customers.
• Support state policies that promote energy storage (electric, thermal, et al) that will enable the electric grid to continue to manage costs, encourage clean energy use, add flexibility, and maintain reliable electric service to customers.
• Support legislation increasing research and incentives for hydrogen in methane supply to improve the natural gas grid.
• Support policies that increase research and incentives for biodiesel to decarbonize the operation of liquid-fuel heating appliances.

• Ensure that energy efficiency standards and building codes for HVACR and water heating equipment are uniform throughout the United States.
• Ensure that energy efficiency standards and building codes for HVACR and water heating equipment do not conflict with federal requirements and do not violate the Energy Policy and Conservation Act’s preemption provision.
• Encourage state and local jurisdictions to update legislative and regulatory language that accurately reflects current energy efficiency standards and performance metrics being used to measure product efficiency.
• Support administrative requirement harmonization on state and local efficiency and emissions requirements for equipment not conflicting with federal requirements.

• Support and promote policies that eliminate state legislative and regulatory requirements for hydrofluorocarbons (HFCs) that are regulated by the U.S. Environmental Protection Agency, including administrative requirements such as labeling, recordkeeping, and reporting.
• Support harmonization of state disclosure and reporting requirements. Maintain flexible disclosure options and limit to self-reporting and recordkeeping for audit only.
• Support harmonization of regulations involving HFCs.
• Support and promote harmonized federal and state actions that enhance the of refrigerant gases.

• Maintain a neutral position on any proposed policy that encourages the replacement of gas-fired appliances with their electric counterparts, or that are otherwise not technologically neutral.
• Monitor state proposals that mandate indoor air quality requirements.
• Monitor indoor air quality policies that reference and propose harmonization with ASHRAE Standard 62.1, ASHRAE Standard 62.2, ASHRAE Standard 241, and/or ASHRAE Standard 170.
• Support incentives for adoption of best available technologies for improving indoor air quality.
• Support funding incentives for ventilation and HVACR and water heating upgrades for buildings, including schools and government buildings.
• Support policy proposals that require the installation, and placement of building carbon monoxide monitors within occupied spaces when gas appliances are installed.
• Support policy proposals, and other efforts, to actively educate the public on proper maintenance of building carbon monoxide monitors, as well as appropriate actions to take when these monitors alarm.

• Support statewide online permitting systems that streamline the permit application process and reduce barriers to permitting compliance.
• Oppose the collection of manufacturer’s serial numbers via a serial number tracking, digital tracking, or state registry as a method of attempting to increase permitting compliance.
• Support proper installation and maintenance of HVACR and water heating equipment. 
• Encourage states to adopt and provide a uniform training program that reviews applicable laws and regulations, permit compliance process, and contractors’ and technicians’ duties and responsibilities to the consumer.
• Support incentives for homeowners to use licensed contractors that are compliant with permitting requirements.
• Support continuing education requirements for licensed contractors that includes training on permitting compliance.
• Support consumer education on the value of quality installations and the importance of requiring permits for all HVACR and water heating installations. 
• Support allocating additional resources for enforcement of existing permitting regulations.

General Plastics and Recycling Requirements

• Support policies that expand recycling infrastructure and programs that encourage viable and sustainable reuse and recycling.
• Support plastics and packaging policies that are limited in scope to business to consumer sales.
• Support policies that take holistic view on plastic reduction and elimination.
• Support proposals that include exemptions for single-use packaging that is used to protect, store, or transport products.
• If there are no technically feasible alternatives, and if recycling options are limited, oppose proposals that require 100% recyclable content in non-consumer-oriented packaging, as some single-use plastics and packaging materials are necessary for the protection of products.
• Support exempting product material from scope of plastics and packaging policies.
• Encourage policies that include reasonable source reduction requirements that differentiate between point-of-purchase and non-consumer-oriented packaging.

Extended Producer Responsibility

• Scope and Funding Mechanisms
• Support EPR proposals that share the financial and management responsibilities of implementing EPR programs across the distribution chain.
• Support exemption of packaging not left at the curbside.
• Support language that preempts local laws and ordinances that are inconsistent with, more restrictive than, or exceed the requirements of a state EPR law, and support federal preemption if a national EPR framework is implemented.

Regulatory Flexibility and Critical Use Exemptions

• When developing recycled content and post-consumer recycled content targets, support inclusion of language that allows for regulatory flexibility based on factors such as availability of recycled content, suitability of recycled content for necessary uses, and the environmental impacts of material substitutes.
• Support inclusion of language that creates a process for requesting an exemption for specific materials that are critical to the safe and efficient storage and transport of products.
• Support inclusion of exemptions for de minimis and integral packaging components.
• Support inclusion of a low volume producer category and exemption based on packaging shipped into the state.
• Support inclusion of an alternate compliance pathway for producers that can demonstrate they have programs or practices in place that achieve the same policy objectives or can demonstrate packaging is handled through a separate process.
• Support legislation distinguishing between non-consumer-oriented packaging and point-of purchase packaging.
• Support harmonization of administrative and reporting requirements.
• Oppose material bans and/or recycled/post-consumer recycled content requirements that are imposed any sooner than five years from the effective date.

• Support exemptions for HVACR and water heating products from right to repair legislation due to safety and environmental concerns.
• Support protection of trade secrets and confidential information from right to repair legislation requirements.
• Support liability protections for manufacturers in right to repair legislation.
• Educate policymakers on the complexity of HVACR and water heating products and the need for quality installation and maintenance by a trained workforce.

• Oppose state policies that interfere with or eliminate manufacturers’ warranty processes and programs and/or their relationships with contractors.
• Oppose state policies that limit a consumer’s ability to choose the warranty coverage that meets their personal and financial needs.
• Oppose legislation that would require HVACR and water heating product warranties to be applicable to the address where they are installed and not to the individual who occupied that address when the product was installed.
• Educate policymakers about the importance of manufacturer warranty registration requirements.

• Support state and local policies that encourage schools to offer a diverse array of career and technical education (CTE) programs, including industry-recognized certification programs.
• Support state and local policies aimed at developing and expanding a skilled workforce through Science, Technology, Engineering, and Mathematics (STEM) retention programs for students who indicate an interest in a STEM career field. 
• Work with industry partners at the state level to promote quality installation and maintenance of HVACR and water heating equipment.
• Ensure that repairs and maintenance are completed by qualified, licensed contractors. 
• Support proposed policies that would adopt licensing reciprocity for credentials and certification in relevant skilled trades.