State Advocacy

State legislatures continue to play a critical role in the development of policy affecting the HVACR and water heating industry. The Government Relations 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 Relations 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.

Our state level priorities, as identified by the SGAC are listed below:

Building Decarbonization
  • Encourage market-based approaches to decarbonization, where such initiatives are under consideration, and oppose electric-only policies.
  • Promote policies that prioritize the following factors: consumer choice, consumer costs, and consumer comfort and safety.
  • Promote the responsible development and use of all energy sources and encourage energy efficiency measures aimed at meeting future energy demands.
  • Ensure that state proposals to modify buildings or restrict energy sources do not impose on the ability of AHRI members to do business in that state. Specifically, federal preemption is not violated, and products are not forced out of the market due to energy source.
Chlorocarbon Refrigerant Feedstock Bans
  • 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.
Codes and Standards
  • Encourage state and local jurisdictions to adopt, implement, and advance industry consensus building energy codes that are consistent with federal energy conservation standards and are technology neutral.
  • Encourage state and local jurisdictions to adopt and implement construction codes that include updated references to federally mandated performance metrics.
Corrugated Stainless Steel Tubing Safety Campaign
  • Support state level efforts to ensure that homeowners and home inspectors are made aware of the need to have properly grounded equipment when connecting gas sources to appliances.
Cybersecurity and the Internet of Things
  • Encourage consistent state policies and practices that ensure the proper handling of data through inclusion of industry best practices, self-regulation, and market-based solutions.
  • Oppose cybersecurity policies that do not include clear compliance pathways and those that expose manufacturers to undue liability.
  • Support state 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.
Demand Response
  • Support demand response programs and policies that encourage innovation and preserve the ability of manufacturers to utilize the best available technology.
  • Support inclusion of AHRI Standard 1380 – Demand Response through Variable Capacity HVAC Systems in Residential and Small Commercial Applications – when states or utilities implement demand response programs and policies that target HVAC systems.
Efficiency Program Funding
  • Support state funding for utility-run energy efficiency programs.
  • Work with state legislators and other policy makers to support programs that would incentivize consumers to replace older, less efficient HVACR and water heating equipment with newer, more efficient equipment.
Energy Standards/Programs
  • Ensure that efficiency standards for HVACR and water heating equipment are uniform throughout the United States and 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.
Hydrofluorocarbon Phase Down Legislation and Rulemakings
  • Support the adoption and harmonization of state level prohibitions on HFCs in all end uses in EPA SNAP Rules 20 and 21.
  • Oppose disclosure and reporting requirements. Maintain flexible disclosure options and limit to self-reporting and recordkeeping for audit only.
  • Support the allowance of reclaim in existing equipment and promote state actions to incentivize the use of reclaim.
  • Support enabling the use of next generation refrigerants through safety standards adoption into codes for all applications. Educate state elected officials and regulatory agencies on the need for next generation refrigerants.
Permitting Compliance
  • Support statewide online permitting systems that streamline the permit application process and reduce barriers to permitting compliance.
  • Oppose serial number tracking or digital tracking as a method of attempting to increase permitting compliance.
Plastics and Single-Use Packaging
  • Support policies that expand recycling infrastructure and programs that encourage viable and sustainable reuse and recycling.
  • Oppose efforts to ban single-use packaging that is used to store or transport manufacturers’ products.
  • Oppose proposals that place the burden of reducing or eliminating plastics and single-use packaging only on manufacturers.
Right to Repair
  • Work with legislators to 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.
Warranty
  • Oppose state policies that interfere with manufacturers’ warranty processes and programs and/or their relationships with contractors.
Workforce
  • Support state 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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