State - Legislative

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State legislatures continue to play a critical role in the development of policy affecting the HVACR and water heating industry. The Government Affairs staff at AHRI works year-round to engage on a multitude of state legislative topics, including energy efficiency, renewable energy, air quality and greenhouse gases, warranty changes, and building codes updates.

AHRI’s Government Affairs staff works with the State Government Relations Committee to set legislative priorities at the state level each year that drive the association’s stance and strategy on state legislation. AHRI builds relationships with state officials, testifies before legislative committees, and collaborates with other industries, putting it at the forefront of policy deliberations in state capitols. We are committed to combining environmental stewardship with protecting the priorities of our members.

AHRI State Legislative Priorities

    • Encourage state and local jurisdictions to adopt, implement, and advance national consensus building energy codes that permit flexibility at the local level, while at the same time do not conflict with federal energy conservation standards.
    • Encourage state and local jurisdictions to adopt and implement building codes that include updated references to federally mandated performance metrics and consensus standards.
    • Support enabling the use of next generation refrigerants through safety standards adoption into codes for all applications.
    • 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.
    • Support defining PFAS in state legislation and policy as meaning non-polymeric perfluoroalkyl and polyfluoroalkyl substances that are a group of man-made chemicals that contain at least 2 fully fluorinated carbon atoms, excluding gases and volatile liquids. “PFAS” includes Perfluorooctanoic Acid (PFOA) and Perfluorooctyl Sulfonate (PFOS) or defer to the U.S. Environmental Protection Agency’s (EPA) definition.
    • 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.

    Monitor legislative proposals that may impact corporate Environmental, Social, and Governance (ESG) commitments or Sustainable Development Goals (SDGs), including climate or emissions 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 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 product and equipment, including low global warming potential refrigerants in 2023 and 2024.
    • 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 that will make better use of the electric grid and lower costs to customers.
    • Support legislation increasing research and incentives for hydrogen in methane supply to improve the natural gas grid.
    • 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 HVAC 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 and promote policies that eliminate state legislative and regulatory requirements for hydrofluorocarbons (HFCs) that are regulated by the 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 and promote state actions to increase the use of recovery and reclaim.
    • Monitor state proposals that mandate indoor air quality requirements.
    • Support harmonization for minimum indoor air quality requirements with current ASHRAE Standard 62.1, ASHRAE 62.2 and ASHRAE 170 where applicable.
    • Support incentives for adoption of best available technologies for improving indoor air quality.
    • Support funding opportunities for ventilation and HVACR upgrades for buildings, including schools and government buildings.
    • 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.
    • Ensure right to repair legislation is limited in scope and does not include HVACR and/or water heating products in the definition of eligible equipment.
    • 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.
    • 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 being completed by qualified, licensed contractors.

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    AHRI State Summit

    AHRI State Summit

    Kimpton Sawyer | Sacramento, CA | April 16 - 17, 2024

    The AHRI State Summit is a unique opportunity for AHRI members to represent our industry before state government officials and to communicate its positive impact on jobs and the economy, energy efficiency, innovation, health and safety, and the environment. 

    The AHRI Government Affairs team puts association members in touch with representatives from legislative offices, regulatory agencies, and environmental and other organizations to engage in constructive dialogue and networking.

    Learn More