HARDI and AHRI Urge New York City to Fix Costly A2L Refrigerant Requirements

HARDI and the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) submitted joint comments urging the New York City Department of Buildings to amend several provisions of its Local Law 77 rule governing A2L refrigerants.

A2L refrigerants have lower global warming potential and are becoming increasingly common as the HVACR industry moves to next-generation equipment. Established safety standards provide clear requirements for their use. However, New York City’s rule adds local restrictions that depart from current national standards and could make otherwise viable HVACR systems more difficult and expensive to install.

HARDI and AHRI asked the department to align its rule with the latest industry standards while maintaining strong safety protections.

New York City’s Rule Relies on Outdated Standards

Local Law 77 currently references the 2022 editions of ASHRAE Standards 15, 15.2, and 34. HARDI and AHRI recommended that the city instead adopt the 2024 editions, including applicable addenda published through June 2026.

The newer standards incorporate updated safety data, technical corrections, and requirements that are more closely aligned with national model codes. Using them would give manufacturers, distributors, engineers, and contractors a clearer and more consistent compliance framework.

The comments also identify three specific provisions that should be revised:

1. A “pipe-in-pipe” requirement that could add significant material, labor, design, and construction costs

2. Restrictions on refrigerant piping in public corridors that go beyond current national standards

3. A modified definition of “air circulation” that could unnecessarily limit common system designs

HARDI and AHRI urged the department to replace these New York City-specific restrictions with the established requirements in current ASHRAE standards. Those standards account for the characteristics of A2L refrigerants while maintaining appropriate safety protections.

Why This Matters to HARDI Members

New York City relies heavily on retrofits and equipment replacements. Requirements that demand additional shafts, piping systems, construction, or redesign can turn a routine HVACR upgrade into a much larger project.

For distributors and their customers, that can mean:

• Fewer viable equipment and system configurations

• Greater design and installation complexity

• Higher project costs

• Longer permitting and construction timelines

• Product availability and distribution challenges

• Delayed adoption of lower-global-warming-potential technologies

These effects could also slow building modernization projects, including work undertaken to comply with New York City’s Local Law 97 emissions requirements.

Manufacturers and distributors need requirements that reflect commercially available products and real-world installation practices. A patchwork of city-specific rules creates further uncertainty across the HVACR supply chain.

HARDI will continue working with AHRI and New York City officials to advocate for a rule that follows current safety standards and allows the HVACR industry to serve building owners and residents effectively.

Read the full text of the comment letter here.

Questions?

If you have questions, please reach out to Alex Ayers.

Stay up to date on the latest Government Affairs and Advocacy updates by subscribing yourself or your company's key contact for these issues. Get the latest Federal and State issues information impacting the HVACR industry.