Brian Reid
Sierra Club DC Chapter
Before the Committee of the Whole
Department of Consumer and Regulatory Affairs
Oversight Hearing
February 24, 2022
Introduction
Chairman Mendelson, thank you for the opportunity to testify at this performance oversight hearing on the Department of Consumer and Regulatory Affairs (DCRA). My name is Brian Reid and I am testifying on behalf of the Sierra Club’s DC Chapter. The Sierra Club is the nation’s oldest, largest, and most influential environmental advocacy group with chapters in all 50 states, Puerto Rico, and DC. The DC chapter has about 3,000 dues-paying members.
The DC chapter has identified an issue under the oversight of the DCRA, allowing climate-friendly refrigerants into the DC building code, which we outline in this testimony.
Climate-Friendly Refrigerants
Hydrofluorocarbon (HFC) refrigerants are commonly used in air conditioning, heat pumps, and refrigeration. HFC refrigerants pose a risk to the climate because they have global warming potentials that are often thousands of times more than carbon dioxide. Because of this, federal legislation–the American Innovation and Manufacturing Act of 2020–mandates a national phasedown of the production and consumption of HFC refrigerants by reducing the amount of HFC refrigerant available for purchase over the next 14 years. Importantly, by 2024, the amount of HFC refrigerant for sale will be reduced by 40 percent relative to the historical average of HFC refrigerant production under EPA’s regulation.
Fortunately, safe alternative refrigerants now exist that are much less damaging to the climate and are categorized under the designation of A2L refrigerants. However, these EPA-approved A2L refrigerants are not permitted under DC’s current building code because previous versions of industry safety standards did not allow for their use. Extensive research has been conducted and has shown that A2L refrigerants are safe when used and installed with proper safety equipment. Current industry safety standards now allow for A2L refrigerants to be used in buildings.
Consequently, a number of states across the nation have recently updated their building codes to allow for these climate-friendly refrigerants. Additionally, the 2024 national model code has been updated to allow for the use of A2L refrigerants.
On March 29, 2021, the Sierra Club’s DC Chapter, along with the Natural Resources Defense Council and the Air-Conditioning, Heating, and Refrigeration Institute, submitted a proposal requesting that DC’s building codes be updated to allow for the use of A2L refrigerants.
The Sierra Club urges the DCRA to implement this change in the current 2021 Code Development Cycle process. We believe it is critical to make the change in this current code update and not wait until the next code update.1 If these climate-friendly A2L refrigerants are not allowed in the building codes, DC residents and businesses may have difficulty purchasing the HFC refrigerants as the supply shrinks which could lead to higher installation and operational costs.
DC has an opportunity to both protect the climate and reduce the financial and regulatory burden for its constituents by updating the building codes to allow for A2L refrigerants.