To Whom it May Concern,
On behalf of the Florida Refrigeration and Air Conditioning Contractors Association (FRACCA), we write to express our strong support for H.J. Res. 38, a Congressional Review Act (CRA) resolution sponsored by Representative Neal Dunn (R-FL-2), and S.J. Res. 14, sponsored by Senator Roger Marshall (R-KS). These critical resolutions aim to overturn the 2023 Environmental Protection Agency (EPA) Final Rule: Management of Certain Hydrofluorocarbons (HFCs) and Substitutes Under the AIM Act (Management Rule) and direct the EPA to develop a new regulation that is consistent with congressional intent.
We are deeply concerned that the current Management Rule constitutes signicant regulatory overreach, imposing excessive and unworkable compliance costs— especially on small businesses such as ours. We believe these resolutions would allow for a more balanced and feasible regulatory approach that still aligns with the environmental goals of the AIM Act, without imposing disproportionate burdens on American businesses and consumers.
While some special interest groups may try to confuse the issue, we want to make clear that our industry remains committed to the responsible phasedown of HFCs. However, the Biden-EPA’s current rule exceeds the scope of authority granted by Congress, introducing unnecessary compliance hurdles and billions of dollars in added costs to industries such as food service, manufacturing, HVAC, data centers, IT infrastructure, and automotive— costs that will ultimately be passed along to American consumers.
Compliance Timeline Concerns
The following EPA-imposed compliance dates are unrealistic and burdensome given current industry challenges:
- January 1, 2025: Stationary A/C and heat pumps, chillers, vending machines, refrigerated transport, and food retail refrigeration systems.
- January 1, 2026: Commercial ice machines, cold storage warehouses, and industrial process refrigeration (non-chiller).
- January 1, 2027: IT cooling equipment, data centers, and high-capacity ice machines.
- January 1, 2028: Motor vehicle air conditioning systems and certain UL 621 Edition 7 equipment.
Considering current refrigerant shortages, equipment backlogs, technician workforce constraints, and ongoing global supply chain disruptions, these deadlines are not feasible. The burdens created by this rule will risk triggering higher costs, reduced equipment availability, and even business closures across multiple sectors of the economy.
We urge you to support and cosponsor H.J. Res. 38 to protect small businesses and ensure EPA regulations remain within their lawful limits.
If you would like to join this important effort or require additional information, please contact Molly Buening in Representative Dunn’s office at (202) 225-5235 or Molly.Buening@mail.house.gov, or Lacy Pitts in Senator Marshall’s office at (202) 224- 4774 or Lacy_Pitts@marshall.senate.gov.
Thank you for your continued leadership and support of American industry.
Sincerely,
Paul Stehle
President
Florida Refrigeration and Air Conditioning Contractors Association (FRACCA)
