Advocacy

This Month in DC Overview: September 2025

September 25, 2025 | 3 minute read

This Month in DC Overview

Alex Ayers gives us an overview of the most important things going on in DC this month. Highlights of this month's This Month in DC Newsletter:

Anticipated EPA Proposal on Technology Transition Rule

We’re expecting the EPA to release a proposal package later this month or early next month on the reconsideration of the Technology Transition Rule. This follows the petition for reconsideration submitted in December 2023 by HARDI, AHRI, and the Alliance for Responsible Atmospheric Policy.

The proposal will be critical in shaping how the refrigerant transition unfolds—particularly regarding:

  • Avoiding a rollback to R-410A equipment production.

  • Providing clarity on the refrigeration transition set for next year.

Once released, we’ll provide members with a full analysis and opportunities to submit comments through our new grassroots advocacy tools.

Top Five FAQs on the HFC Phasedown

EPA recently addressed common distributor questions about the HFC phasedown. Key topics include:

  • Equipment handling after the January 1, 2026 install ban.

  • Liability for illegal installations.

  • Recordkeeping requirements.

These FAQs are vital for compliance planning—check out our full blog post dedicated to this topic.

Warehouse Worker Protection Act Concerns

Although aimed at large online retailers, the proposed Warehouse Worker Protection Act would impose unnecessary and burdensome paperwork requirements on distributors without improving worker safety. HARDI continues to oppose this government overreach. Read more about it in our blog post.

Enforcement and Legal Updates

  • R-22 Smuggling Case: A Texas individual was placed on probation for illegally importing R-22 cylinders from Mexico. This highlights ongoing enforcement risks around refrigerant smuggling.

  • State & Legal Actions:

    • Utah: Updates expected on ultra-low NOx water heater rules.

    • New York: Our lawsuit against the DEC is approaching oral arguments.

    • Federal: In IGA v. EPA, RMS of Georgia is pursuing an en banc appeal, though prospects remain slim.

Members, mark your calendars for next year’s Congressional Fly-In on April 20–21 in Washington, DC.

Explore HARDI's Industry Issues and State Issues pages and stay up to date on the latest issues affecting the HVACR industry.

Read more on what's affecting our industry here: HARDI's Advocacy Blogs


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Alex Ayers
Vice President of Government Affairs
Alex is HARDI’s lead lobbyist and regulatory expert, with over a decade of experience in Washington, DC. A former Iowa caucus delegate, he built early roots in grassroots politics. He has lobbied, published, and testified on taxes, energy, environment, agriculture, and economics. His work has been cited by the Wall Street Journal, Forbes, and the Tax Foundation.
Todd Titus
Director of State Government Affairs
Todd Titus, J.D. is HARDI's Director of State Government Affairs. As the lead of HARDI's new state affairs department, Todd monitors legislative and regulatory issues across all 50 states to inform HARDI membership about the legislation that impacts the industry. Along with informing membership of key issues, Todd also spearheads grassroots initiatives, advocates before elected officials, and networks in person with relevant stakeholders.
Areas of Expertise
  • State Policy Tracking and Analysis
  • Public Policy & Regulatory Business Risk Analysis
  • Stakeholder & Membership Grassroots
  • Legislative Strategy & Policy Outcomes
Madison Romero
Public Affairs Associate
Madison Romero is HARDI’s Public Affairs Associate, supporting the industry advocacy of the Government Affairs team through strategic writing, grassroots campaigns, and media outreach. She crafts messaging that connects HARDI’s advocacy goals with its members as well as broader HVACR industry audiences. Madison also contributes to developing content around industry events and external communications efforts across platforms.
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