Daikin appreciates the EPA’s efforts to implement the American Innovation and Manufacturing (AIM) Act and the orderly phase-down of refrigerants, but we are disappointed the proposed rule for allocating HFC production and consumption allowances starting in 2024 does not provide an allocation to air-conditioning equipment manufacturers (OEMs) that use HFCs in their products. This is a valuable tool that could have been utilized by EPA to enable OEMs to better plan, invest, and innovate for the future. The OEM allocation would encourage more market participants, improve market stability, and provide the HVAC industry with the certainty and predictability needed to innovate for the future—ensuring an orderly and economically beneficial phasedown with US investments and jobs, just as the AIM Act intended. The EPA can support the industry’s shift toward climate solutions by providing us with the certainty we need to innovate and invest in the development of ever-more sustainable technology in the US.
Media Contact: Susanna Hinds, firstname.lastname@example.org