On June 24th, GCCA submitted comments to the State of New York in response to the recently published Request for Feedback Amendments to 6 NYCRR Part 494 Hydrofluorocarbon Standards and Reporting. The proposed rule would create HFC phase down policies even stricter than those advanced in California and other states. The proposal comes as EPA is moving forward with the process for implementation the AIM Act, which will establish federal policies regarding HFCs. GCCA’s comments assert that implementation and compliance are complicated when federal and state regulations differ or reference different criteria and/or metrics. Consistency provides clarity and enables industry to better achieve compliance. Because the federal EPA process is ongoing and anticipated to be completed by the fall of 2023, GCCA recommends that the State of New York wait to finalize its rulemaking until the EPA process is complete. This would enable a full analysis of the federal rules and allow for harmonization and consistency. GCCA also recommends that the State consider establishing incentives to assist with conversions which can ease the burdens of the transition process and improve compliance.
