The bill's introduction came after an October 8 letter to House and Senate Committee leadership from the CEOs of 32 HVACR and water heating manufacturers urged support for such a phase down. That letter noted that, "U.S. companies that produce and use fluorocarbons have been preparing for a transition from HFCs for more than a decade, investing billions in R&D to be the first to bring to market next-generation fluorocarbon products and equipment," the letter expressed concern that while "American companies have led the world in fluorocarbon technology development for decades...that leadership – and the advantages it confers to the U.S. economy – is jeopardized by the lack of a federal policy for HFCs.” The letter warned that inaction on the part of federal policy makers would result in "foreign competitors...poised to fill the technology void and displace American companies in a global fluorocarbon market expected to reach $1 trillion in size."

"Federal legislation phasing down HFCs represents a chance to put America first, and to keep American workers at the forefront of this important global industry," the letter stated, noting that, "A recent industry economic study showed that a new federal standard for the phase-down of HFCs would create 33,000 new U.S. manufacturing jobs, add $12.5 billion per year to the U.S. economy, and expand U.S. exports in this sector by 25 percent. Failure to do so will cost U.S. businesses and jobs."

Separately, ACCA also supports the Senate legislation, noting that it is a good start for a more uniform HFC phasedown schedule. ACCA has been advocating for federal legislation, because many states – led by California - are working to create their own HFC phasedown plans. According to ACCA, this will lead to a confusing patchwork of phasedown schedules, regulatory schemes, and other complications when dealing with new refrigerants – which will include ASHRAE designated mildly flammable A2L refrigerants. A state-by-state approach to the HFC phasedown could also lead to the sale of products to consumers, because the Environmental Protection Agency (EPA) may not have authority to regulate new products since they are non-ozone depleting.

ACCA states that this legislation contains important safety, training, and certification language that would safeguard its members and allow for a safe introduction of mildly flammable refrigerants, which was ACCA’s highest priority in the Senate legislation. ACCA is also working with the House of Representatives on improvements to the Senate legislation, noting that it would like to see more explicit language that grants the EPA the authority to prohibit the sale of refrigerants to non-certified individuals. ACCA also supports including language that would protect contractors from liability involving accidents caused by new refrigerants. ACCA’s goal is to include language that would enable contractors to verify they properly designed and installed a system and through this verification they would be protected in the event of an accident.

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