State and Local Policy

We’re working at the state and local levels to strengthen New York’s efforts on refrigerants.  On the local level we help communities learn how to purchase, maintain and dispose of appliances, research local policies, talk to experts and develop public education campaigns, templates, and presentations. We advocate for State policies as strong as California’s to quickly phase in safer refrigerants and make polluters responsible for preventing emissions.

Key areas for policy:

  • Adopt a stricter phase down schedule, such as the European F-Gas law or the regulations California recently adopted.


  • Provide incentives to companies and individuals to implement alternative refrigerants more quickly.


  • Improve end-of-life recovery rates.


  • Enhance leak monitoring and sequestration.

NEW YORK STATE POLICY

CLIMATE LEADERSHIP AND COMMUNITY PROTECTION ACT (CLCPA)

Our focus is on New York State laws, and we are pleased with how HFCs are treated in the Climate Action Council’s final Scoping Plan, which was approved on December 19, 2022. The final plan shows a good deal of responsiveness to the many public comments on the draft plan. Our suggested priority actions for implementing the Scoping Plan in regards to HFCs include:

  • Providing incentives to install automatic leak detection equipment in grocery stores, especially for disadvantaged communities

  • Establishing utility incentives and other grants for promoting natural refrigerants in food stores, especially for disadvantaged communities

  • Prioritizing programs for appliances with HFCs among the other Extended Producer Responsibility programs called for by the Climate Action Council

  • Hiring more DEC staff to focus on refrigerants and implement a statewide refrigerant management program

The letter we circulated to our supporters spells out these priorities in more detail.

In May and June 2022 we submitted letters to New York’s Climate Action Council with comments on the Draft Scoping Plan. One letter explained how for every 100 tons of HFC emissions counted in the current greenhouse gas inventory, New York was probably emitting an additional 67 tons of HCFC emissions and 13 tons of CFC emissions that are not included in the inventory. The calculations are available in this spreadsheet. We believe policymakers should be aware of these emissions. 

In October 2020 we submitted a sign-on letter to the Climate Action Council to express our concern that none of the advisory panels was charged with comprehensively addressing HFCs. We specifically referenced the goal of reducing refrigerant emissions 40% from 2018 levels by 2030, in accordance with the United States Climate Alliance Short-Lived Climate Pollutants Road Map, which calls for action following the three pillars of refrigerant management:  transitioning to new refrigerants and doing it quickly with incentives; capturing refrigerants at end of life; and improving leak detection and sequestration practices. Read our sign-on letter. As of January 2023, New York still has not established a target for HFC emissions.


O&R UTILITY RATE CASE

Reducing refrigerant leak rates can contribute to energy savings. In May of 2021, New Yorkers for Cool Refrigerant Management became an intervenor in the Orange & Rockland Rate Case. As part of the rate case, we filed the Direct Expert Testimony of Ali White Regarding Refrigerant Management Programs. The testimony provides broad recommendations for policies that promote energy efficiency in grocery stores, including energy savings through converting to systems that run on natural refrigerants and from reducing refrigerant leaks. It points out how enhanced refrigerant management practices in grocery stores reduce emissions of super greenhouse gases while improving energy efficiency.

On April 14, 2022, the final order was approved by the Public Service Commission. During 2022, O&R will: 

  • Investigate the cost effectiveness of the refrigerant management issues suggested by our expert testimony

  • Confer with representatives of the Public Service Commission, New Yorkers for Cool Refrigerant Management and other interested parties

  • Implement any measures found to be cost effective in 2023 and 2024.

DEC REGULATIONS

We submitted a letter in support of Part 494 to New York’s DEC. Part 494  phases out HFCs in specific applications and mandates the use of lower-GWP refrigerants. While this is a good step to take, our letter pointed out the great need to focus on capturing refrigerants at end of life and improving refrigerant monitoring standards. Read our Part 494 letter.

We submitted a letter in support of Part 496 to New York’s DEC. As adopted, Part 496 explains how the DEC calculated the greenhouse gas inventory to establish the baseline for implementing the CLCPA.   Our letter asked the DEC to consider including supplementary information on the remaining banks of CFCs and HCFCs and their potential greenhouse gas emissions (which we believe would be substantial) and also reiterated the need to focus on capturing refrigerants at end of life and improving refrigerant monitoring standards. Read our Part 496 letter.

 

LOCAL POLICY & PRACTICE

RAISING AWARENESS AMONG HOMEOWNERS AND MUNICIPAL LEADERS

Our outreach and education efforts help municipal leaders and the general public address the problems and opportunities in appliance recycling, air conditioning and heating system installation and monitoring. See our resources page for shareable articles and templates.

  • Campaigns and  Pilot Projects  We helped to develop a pilot project on monitoring cooling systems at Bard College and a recycling drive model for old refrigerators in Warwick.


  • Including Refrigerants in Resource Recovery Plans We are helping to develop recommendations on refrigerant capture, reuse and destruction for Ulster County’s Zero Waste Plan that may be a model for other communities.


  • Climate Smart Communities