Advocacy with an eye on the details.
Before acts are passed and regulation enforced, we pay close attention to how legislation could impact our members’ business – and make their voices heard. NAFEM’s advocacy efforts present our members’ point-of-view to lawmakers, government agencies and other stakeholders, playing an active role in shaping key initiatives.
Seventh Circuit Court Denies NAFEM Challenge to Commercial Refrigeration Efficiency Standards
August 8, 2016
On Monday, Aug. 8, the U.S. Court of Appeals for the Seventh Circuit issued its decision denying industry’s petition for review of DOE’s commercial refrigeration test procedure and efficiency standards published in 2014 (EERE-2013-BT-TP-0025 & EERE-2010-BT-STD-0003).
The decision means manufacturers must be ready to comply with the new standards by March 27, 2017.
NAFEM maintains that at every step, the court deferred to the agency. “Arguing against an agency is always an uphill battle, but the amount of deference the court exhibits in the opinion is much greater than what we have seen in other cases,” says Jeff Longsworth, NAFEM Legal Counsel. According to Longsworth, the court seemed reluctant to grasp the technical integrity issues raised by NAFEM and the Air-Conditioning, Heating and Refrigeration Institute (AHRI), which collaborated on the filing. “We knew this was a risk, but we had faith that the court would do their job – especially given the excellent help from members in breaking the information into bite-sized pieces for a lay person to understand. It’s disheartening that the court did not look beyond the DOE’s words and into the substance and technical impact of the case.”
NAFEM’s advocacy efforts present its members’ point-of-view to legislators and regulators making decisions that potentially impact the industry. NAFEM works with allied industry partners, law makers, government agencies and other stakeholders to actively advocate for its members’ interests.
For details on these initiatives, members can login with your NAFEM site credentials. All others should contact: Charlie Souhrada, CFSP, NAFEM director, member services, +1.312.821.0212; firstname.lastname@example.org.
EPA Releases SNAP Final Rule
July 2, 2015
On July 2, the U.S. Environmental Protection Agency (EPA) released the final rule – Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy (SNAP) program. The rule restricts the use of certain refrigerants and foam-blowing agents currently used by NAFEM members and other industries. See EPA’s Fact Sheet
NAFEM has been working closely with members, government agencies, House and Senate representatives and other trade groups for two years to communicate how the proposed rule will affect commercial foodservice equipment and supplies manufacturing. We welcome your input on the final rule and its impact on your business. We’re particularly interested to gain input on the effective date for delisting currently-used refrigerants and foam-blowing agents tabulated by category in the attachment, EPA Alternative Refrigerants for SNAP, starting on page 44.
To share your thoughts in confidence, login to your NAFEM member account for contact information; non-members can contact us here.
*To view the public docket, visit www.regulations.gov and search for docket number EPA-HQ-OAR-2014-0198.
NAFEM Responds to USEPA Request for Input on Regulations, Processes
April 8, 2015
Periodically, U.S. government agencies – including the Environmental Protection Agency (USEPA) – are required to seek input from constituents to “identify and reduce regulatory burdens,” as well as to modernize regulations and processes. USEPA recently requested information of this nature and NAFEM, on behalf of its members, provided input.
Specifically, NAFEM recommended that USEPA:
- Better understand and calculate the impact of its regulations on manufacturers, their supply chain partners and their end users;
- Establish a meaningful dialogue with stakeholders and subject matter experts prior to developing proposed regulations. NAFEM believes this step could result in more transparent, realistic and achievable proposals, as well as a more efficient rule-making process; and,
- Coordinate more closely with other agencies to, at a minimum, ensure their rules don’t contradict one another and, ideally, harmonize their rules.
To reinforce its above recommendations, NAFEM spotlighted the recent EPA proposed rule around alternative refrigerants, as well as the U.S. Department of Energy’s recent Final Rule on energy conservation standards for commercial refrigeration.
Agencies & issues
- Bishpenol A (BPA) and California Proposition 65
- California Air Resources Board (CARB)
- Commodity Classification Standards Board (CCSB)
- Department of Energy Automatic Commercial Ice Makers (DOE/ACIM)
- Department of Energy Commercial Refrigeration (DOE/CRE)
- Department of Energy Walk–In Coolers / Freezers (DOE/WIC/WIF)
- Department of Energy Import Data Collection NOPR (DOE NOPR)
- Environmental Protection Agency Significant New Alternatives Policy (EPA SNAP)
- Environment Canada – Proposed Regulatory Measures on Hydrofluorocarbons (Hydrofluorocarbons Canada)
- South Coast Air Quality Management District (SCAQMD)
If you’re a NAFEM member, log in to your account and visit the “Important links and documents” tab of your member portal. There you’ll find information on providing input on recent issues, as well as a member advocacy toolkit. Contact Charlie Souhrada at email@example.com for outside inquiries related to advocacy efforts or use the Contact us form linked below.