200408 hfcphasedown senateepw


April 08, 2020


Re: The Business Community’s Comments on HFC Phasedown Legislation

Dear Chairman Barrasso and Ranking Member Carper:

The U.S. Chamber of Commerce is pleased to provide our feedback on S. 2754, the “American Innovation and Manufacturing (AIM) Act of 2019,” a bill to phase down hydrofluorocarbons (HFCs) over a 15-year period.

We appreciate the significant economic and environmental goals of this legislation and the committee’s commitment to engage all stakeholders. We are committed to working cooperatively with you, your committee, and all interested parties to develop a consensus compromise that enjoys broad bipartisan support. By engaging with our member companies and fellow trade associations, we believe such an outcome is possible, allowing for quick approval by your committee, the full Congress, and the president.

Preemption is one area that lacks agreement. We urge a solution that would provide the business community with a predictable environment in which to invest and plan, and ensure a consistent national program that takes into account existing state programs that support the transition to alternatives. There are several creative preemption models for federal-state environmental partnerships that could be used.

The HFC phase down envisioned by this bill is achievable, as these compounds have many useful industrial applications for which substitutes are readily available. However, there are a limited number of uses, which may not have readily available substitutes, such as for onboard fire suppression agents on commercial and military aircraft, metered dose inhalers, and personal defense spray applications. While the legislation already provides an exemption process for essential uses, we want to emphasize the importance or retaining this critical language in the bill and to ensure essential uses that have no commercial substitutes receive an exemption. We also want to recognize the language in the bill that encourages the continuing recovery of HFCs for reuse in existing equipment during the transition.

Developing HFC replacement technologies is well underway and is critical to creating U.S. manufacturing jobs. A report published in April 2018 by two trade groups—the Air-Conditioning, Heating, and Refrigeration Institute and the Alliance for Responsible Atmospheric Policy—found that phasing down HFCs would by 2027 increase jobs by 33,000, grow U.S. exports by $5 billion, and reduce imports by nearly $7 billion. Additionally, phasing down HFCs would avoid more than 70 billion metric tons of carbon dioxide equivalent emissions by 2050. Solutions are available to replace HFCs in many sectors and reduce emissions.[1] U.S. companies have traditionally led the development of refrigerant products used in air-conditioning, appliances, and other important sectors, as well as the products themselves. The bill would create new demand for such expertise and products across the globe. If the U.S. does not pass the legislation, other countries could surpass the U.S. as the global leader in the sector.

We welcome the opportunity to discuss these issues with you further. For more information, here is a link to our previous coalition letter. I will be following up with your staffs. Thank you for your leadership.


Chuck Chaitovitz

Vice President, Environmental Affairs and Sustainability

cc: Members of the Senate Committee on Environment and Public Works


200408 hfcphasedown senateepw