FROSTlines
Riding the (De)Regulation Rollercoaster
As federal priorities change under the Trump administration, states may enact stricter rules
“Life moves pretty fast,” Ferris Bueller famously said. “If you don’t stop and look around once in a while, you could miss it.” The same could easily be said about HVACR regulations -- especially now, as the Trump administration signals a significant shift in direction. With promises to roll back or reconsider a number of environmental and efficiency regulations, the regulatory landscape for the HVACR industry is once again in motion. From refrigerant rules to energy standards, what seemed like a settled path just months ago is now up for debate, leaving many in the industry scrambling to keep up.
Already, Congress has passed a resolution that would rescind Biden-era energy efficiency rules for walk-in coolers and freezers. And that could just be the beginning. The Department of Energy’s Technology Transition Rule, which restricted the use of higher-GWP HFC refrigerants in new refrigeration, air conditioning, and heat pump equipment, is also under scrutiny. In addition, EPA’s proposed refrigerant management rule under the AIM Act -- which would require leak repairs on certain systems and automatic leak detection for large refrigeration equipment -- could be scaled back or eliminated altogether.
However, even if the federal government rolls back or delays regulations, that doesn’t mean the HVACR industry is off the hook. States still have the authority to implement their own environmental policies -- and many are already doing just that. California, for example, has been a leader in phasing down HFCs and enacting aggressive greenhouse gas reduction targets. New York and Washington have followed suit with their own regulations on refrigerants, energy efficiency, and emissions.
Much of this state-level momentum is being driven by organizations like the U.S. Climate Alliance, a bipartisan coalition of 24 governors committed to “securing America’s net-zero future by advancing state-led, high-impact climate action.” The Alliance has repeatedly pledged to “protect America’s progress and to sustain and advance climate action,” underscoring how state governments are stepping up to lead in the absence of stronger federal action.
Formed in 2017 by the governors of California, New York, and Washington, the Alliance was created in direct response to President Trump’s announcement that the U.S. would withdraw from the Paris Agreement on climate change. The founding governors sought to demonstrate that, despite the federal government’s shift in climate policy, states could continue to pursue broad climate action. This includes encouraging the adoption of policies to reduce HFC emissions -- such as regulations modeled after the EPA’s former SNAP (Significant New Alternatives Policy) rules.
Another organization, Climate Xchange, also aims to accelerate the transition to a zero-emissions economy by advancing state-level climate policy. The group offers guidelines for how states can fill the gaps left by the EPA’s climate deregulation. Regarding the HFC phasedown, the organization noted that “states have the power to regulate HFCs, by meeting or exceeding regulations established under the EPA’s SNAP program; incentivizing sustainable alternatives to HFCs; regulating the management, recycling, and disposal of HFCs; and by setting procurement targets for state agencies.”
Unhappy with the fact that states can often enact their own environmental policies, President Trump recently signed the "Protecting American Energy From State Overreach" executive order, directing the Attorney General to identify and challenge state laws that may be unconstitutional or preempted by federal law. This order specifically targets state policies addressing climate change and carbon emissions, aiming to prevent what the administration views as regulatory overreach that could hinder national energy objectives.
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In response to the President’s executive order targeting state authority, the U.S. Climate Alliance issued the following statement: “The federal government cannot unilaterally strip states’ independent constitutional authority. We are a nation of states — and laws — and we will not be deterred. We will keep advancing solutions to the climate crisis that safeguard Americans’ fundamental right to clean air and water, create good-paying jobs, grow the clean energy economy, and make our future healthier and safer.”
The next few years promise to be anything but dull, as states prepare to fight back against a Trump administration that is determined to reassert federal control over environmental policy.
