Advocacy

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.

NAFEM is actively involved in the following issues on behalf of its members. If you have questions, or need help with issues not listed, please let us know. Visit this site for updates as new information is available.

Advocacy updates

U.S. Court of Appeals Vacates EPA HFC Rule

The United States Court of Appeals for the District of Columbia Circuit has vacated the Environmental Protection Agency’s 2015 Rule, which is based on Section 612 of the Clean Air Act. 42 U.S.C. § 7671k, “to the extent it requires manufacturers to replace HFCs” and remanded the Rule to EPA for additional work.

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The opinion, decided August 8, is in response to a petition filed by Mexichem Fluour, Inc. EPA still has several statutory options to regulate HFCs, which include gases used in commercial refrigeration equipment.

Manufacturers are strongly encouraged to continue to explore alternative refrigerant options while waiting for EPA’s response.

NAFEM will continue to monitor this situation and provide future updates as appropriate.

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NAFEM comments to USDOE on ways to reduce regulatory burden

As required by Executive Order 13777 offsetting the number and cost of new regulations, the U.S. Department of Energy (USDOE) is seeking input on regulations that may be appropriate to repeal, replace or modify. On behalf of its members, NAFEM recommended that USDOE:

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  • Collaborate with the U.S. Environmental Protection Agency (USEPA) to eliminate duplicative or conflicting regulations.
  • Create achievable energy reduction standards by relying on expert insights rather than computer modeling.
  • Test proposed standards to measure the potential energy savings before requiring industry to redesign product lines.
  • Better align regulation changes with the industry’s product development cycle.
  • Create an efficient waiver process with a timely conclusion.

NAFEM also recently responded to a similar request from the USEPA.

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NAFEM Comments to EPA on SNAP and ENERGY STAR

As required by Executive Order 13777 offsetting the number and cost of new regulations, the U.S. EPA is seeking input on regulations that may be appropriate for repeal, replacement, or modification. On behalf of its members, NAFEM requested that EPA extend the current 2021 deadline to at least 2025 for changes to permissible refrigerants addressed under the Significant New Alternatives Policy (SNAP). The extension would allow the time needed to introduce new, safer refrigerants. NAFEM also recommended the agency revisit the ENERGY STAR program to make it less burdensome and more effective.

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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 vice president, regulatory & technical affairs, +1.312.821.0212; csouhrada@nafem.org.

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California Air Resources Board Adopts Short-Lived Climate Pollutant Reduction Strategy

On Thursday, March 23, the California Air Resources Board (CARB) adopted a plan to curb pollutants including black carbon, fluorinated gases and methane.

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The plan, California’s Short-lived Climate Pollutant Reduction Strategy (SLCP), maps the route to more rapid greenhouse gas reductions by clamping down on pollutants. The strategy also reduces hydrofluorocarbons, traditionally used in refrigeration, air conditioning, insulation and propellants. CARB’s efforts are expected to result in HFC reductions of 25 percent below business-as-usual emissions by 2020. CARB is currently preparing a detailed analysis of future HFC emissions which will undergo a third-party review. https://www.arb.ca.gov/newsrel/newsrelease.php?id=906

For information on this issue, visit https://www.nafem.org/resources/california-air-resources-board-carb. Or, contact: Charlie Souhrada, CFSP, NAFEM vice president, regulatory & technical affairs, +1.312.821.0212; csouhrada@nafem.org.

 

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Proposed Los Angeles-area regulation to reduce nitrogen oxide emissions could impact fuel-burning appliances

March 10, 2017

The Orange County, Calif.-based South Coast Air Quality Management District (SCAQMD) has completed its 2016 Air Quality Management Plan – a regional blueprint for achieving federal air quality standards primarily through reductions in nitrogen oxide (NOx) emissions across the greater Los Angeles area..

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The plan must now be approved by the California Air Resources Board (CARB) for inclusion in its State Implementation Plan, which, in turn, will be submitted to the U.S. Environmental Protection Agency (EPA) for approval. The SCAQMD plan calls for a 17 percent reduction in NOx emissions by 2022; a 43 percent reduction by 2023; and a 55 percent reduction by 2031. Among the reduction standards to be created to comply with the plan are those for measuring and reducing NOx emissions from charbroilers and other appliances with burners used in commercial foodservice equipment. Until now, there have been no standards for regulating NOx emissions from these types of appliances.

For questions on this topic, please contact Charlie Souhrada, CFSP, NAFEM’s vice president, regulatory & technical affairs: csouhrada@nafem.org or +1.312.821.0201.

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Seventh Circuit Court Denies NAFEM Challenge to Commercial Refrigeration Efficiency Standards

August 8, 2016

On Aug. 8, 2016, 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 &amp EERE-2010-BT-STD-0003).

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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; csouhrada@nafem.org.

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about us

Agencies & issues

  • California Environmental Protection Agency Air Resources Board (CARB)
  • California Office Of Environmental Health Proposition 65/Bishpenol A (BPA)
  • California South Coast Air Quality Management District (SCAQMD)
  • Department of Energy Automatic Commercial Ice Makers (DOE/ACIM)
  • Department of Energy Commercial Refrigeration (DOE/CRE)
  • Department of Energy Import Data Collection (DOE  IDC)
  • Department of Energy Walk–In Coolers / Freezers (DOE/WIC/WIF)
  • Environment Canada – Proposed Regulatory Measures on Hydrofluorocarbons (Hydrofluorocarbons Canada)
  • Environmental Protection Agency Significant New Alternatives Policy (EPA SNAP)
  • National Motor Freight Transportation Association Commodity Classification Standards Board (CCSB)
  • Natural Resources Canada (NRCan)

Get involved

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 csouhrada@nafem.org for outside inquiries related to advocacy efforts or use the Contact us form linked below.

Contact us

advocacy