Oppose the New York State Proposal to Require Unsafe AC and Refrigeration Technologies

The New York State Department of Environmental Conservation (NYSDEC) is proposing an amendment that, if enacted, would ban the repair of any existing air-conditioner or heat pump that needs refrigerant and ban the installation of current technologies used for air conditioning and refrigeration systems for its businesses and residents starting on January 1, 2025.

This amendment is too aggressive and does not allow enough time to appropriately phase out, or even phase down, to the stated GWP requirements. NYSDEC Amendments to Part 494 use the Global Warming Potential for 20 years (GWP20). Their desire, generally, is to have all regulated refrigerants (virgin and reclaimed) used in New York State have GWP20 of under 10. This radical GWP20 requirement would make the most common refrigerants unusable throughout New York State.

NYSDEC Amendments to Part 494 would force the industry to use alternative refrigerants. Alternative refrigerants require ultra-high pressures like CO2 or high-flammability refrigerants like propane, which are hard to retrofit into existing buildings and require major changes to safety standards and building codes that are unlikely to be achieved in time for the proposed prohibitions (the earliest prohibition begins January 1, 2025).