EPA Proposes an HFC Emissions Reduction and Reclamation Program
Beveridge & Diamond Russ LaMotte, Liz Johnson, Lauren Karam, Nikki Waxman On October 19, 2023, the U.S. Environmental Protection Agency (EPA) published a proposed rule to establish an Emissions Reduction and Reclamation Program to manage certain HFCs and their substitutes. The proposed rule, Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h) of the American Innovation and Manufacturing Act of 2020 , is the latest rule proposed to be promulgated under the American Innovation and Manufacturing Act of 2020 (AIM Act), 42 U.S.C. § 7675 et seq ., and the first to address the AIM Act’s repair and reclamation requirements under subsection (h). EPA also released its final Technology Transition rule on the same day, which implements subsection (i) of the AIM Act. B&D’s summary of the Technology Transition Rule can be found here . Additionally, the Proposed Rule also includes alternative standards...