Protecting Your Interests! Keeping Your Informed!
Fall 2024
Duct testing and air balancing issue
ACA/NE recently testified at a Massachusetts Department of Energy Resources (DOER) public hearing on behalf of its Massachusetts members to voice opposition to two provisions of the Stretch Code and Specialized Code
In the testimony, ACA/NE addressed two specific provisions including:
These provisions mandate that a HERS Rater, HERS Rating Field Inspector, or an applicable BPI Certified Professional perform the testing and verification of work conducted by a professional HVAC Contractor.
ACA/NE testified that provisions conflict with existing Massachusetts law. M.G.L. c. 112, §§ 237-251 requires individuals engaged in the sheet metal trade to obtain a state license to perform their work. This law clearly outlines the scope of work for sheet metal workers, including "the testing, adjusting, and air-balancing of all air-handling equipment and ductwork installed during new or remodeling construction."
Despite ACA/NE's efforts, the code went into effect without any amendments. As a result, the ACA/NE Government Affairs Committee will soon reconvene to strategize and discuss the next steps to support its members in navigating these new regulations.
Read the testimony here.
In the testimony, ACA/NE addressed two specific provisions including:
- R403.3.5 Duct Testing - Post-construction or rough-in testing and verification shall be performed by a HERS Rater, HERS Rating Field Inspector, or an applicable BPI Certified Professional."
- R403.6.3 Testing and Verification - Installed performance of the mechanical ventilation system shall be tested and verified by a HERS Rater, HERS Rating Field Inspector, or an applicable BPI Certified Professional
These provisions mandate that a HERS Rater, HERS Rating Field Inspector, or an applicable BPI Certified Professional perform the testing and verification of work conducted by a professional HVAC Contractor.
ACA/NE testified that provisions conflict with existing Massachusetts law. M.G.L. c. 112, §§ 237-251 requires individuals engaged in the sheet metal trade to obtain a state license to perform their work. This law clearly outlines the scope of work for sheet metal workers, including "the testing, adjusting, and air-balancing of all air-handling equipment and ductwork installed during new or remodeling construction."
Despite ACA/NE's efforts, the code went into effect without any amendments. As a result, the ACA/NE Government Affairs Committee will soon reconvene to strategize and discuss the next steps to support its members in navigating these new regulations.
Read the testimony here.
A2L (R32 and R454B) Refrigerants
Many states across the U.S. have begun adopting these low-GWP refrigerants, aligning with EPA's phasedown of HFCs under the AIM Act.
The transition to lower-global warming potential (GWP) refrigerants like R32 is part of a broader shift under the American Innovation and Manufacturing (AIM) Act, which mandates a phasedown of hydrofluorocarbons (HFCs) in the U.S. by 2025
Massachusetts is waiting for the 10th edition of the Building Code to be promulgated, expected to be in effect January 2025. This code cycle references the 2021 IRC, IECC, and IMC which were written before EPA approval of A2L's and the R-410A phase-out requirement. To accommodate A2L installations in 2025, the Massachusetts BBRS has already passed an amendment which references the ASHRAE 15 Standard, which also aligns with the next ICC code cycle 2024.
Connecticut has made regulatory changes and updates regarding the use of R-32, a refrigerant used in air conditioning systems. The state has been moving towards more stringent regulations to phase out high-GWP (Global Warming Potential) refrigerants like R-410A in favor of lower-GWP alternatives such as R-32.
Maine has not yet passed specific regulations concerning the adoption of R-32 refrigerants, but the state is gradually updating its building codes to align with the phasedown of high-GWP (Global Warming Potential) hydrofluorocarbons (HFCs), like R-410A, in favor of lower-GWP alternatives such as R-32.
New Hampshire has not yet implemented specific regulations allowing R32 or A2L refrigerants in air conditioning systems.
Rhode Island passed legislation in June 2023 allowing the use of R32 and other A2L refrigerants. This aligns the state’s regulations with federal guidelines, specifically the U.S. Environmental Protection Agency’s Significant New Alternatives Policy (SNAP), which supports the transition to low global warming potential (GWP) refrigerants.
Vermont has approved the use of R32 refrigerant. Vermont has been proactive in adopting more environmentally friendly refrigerants, and R32, which has a lower global warming potential compared to other refrigerants, is among those that have been approved for use.
The transition to lower-global warming potential (GWP) refrigerants like R32 is part of a broader shift under the American Innovation and Manufacturing (AIM) Act, which mandates a phasedown of hydrofluorocarbons (HFCs) in the U.S. by 2025
Massachusetts is waiting for the 10th edition of the Building Code to be promulgated, expected to be in effect January 2025. This code cycle references the 2021 IRC, IECC, and IMC which were written before EPA approval of A2L's and the R-410A phase-out requirement. To accommodate A2L installations in 2025, the Massachusetts BBRS has already passed an amendment which references the ASHRAE 15 Standard, which also aligns with the next ICC code cycle 2024.
Connecticut has made regulatory changes and updates regarding the use of R-32, a refrigerant used in air conditioning systems. The state has been moving towards more stringent regulations to phase out high-GWP (Global Warming Potential) refrigerants like R-410A in favor of lower-GWP alternatives such as R-32.
Maine has not yet passed specific regulations concerning the adoption of R-32 refrigerants, but the state is gradually updating its building codes to align with the phasedown of high-GWP (Global Warming Potential) hydrofluorocarbons (HFCs), like R-410A, in favor of lower-GWP alternatives such as R-32.
New Hampshire has not yet implemented specific regulations allowing R32 or A2L refrigerants in air conditioning systems.
Rhode Island passed legislation in June 2023 allowing the use of R32 and other A2L refrigerants. This aligns the state’s regulations with federal guidelines, specifically the U.S. Environmental Protection Agency’s Significant New Alternatives Policy (SNAP), which supports the transition to low global warming potential (GWP) refrigerants.
Vermont has approved the use of R32 refrigerant. Vermont has been proactive in adopting more environmentally friendly refrigerants, and R32, which has a lower global warming potential compared to other refrigerants, is among those that have been approved for use.
Under Ten-Ton Refrigeration License Legislation
For the past several years, ACA/NE has worked to defeat legislation requiring that residential HVAC contractors obtain a refrigeration license. ACA/NE members are opposed to these bills because they would require residential HVAC contractors to obtain a refrigeration license to perform work on refrigerant systems under ten tons under M.GL. 146, which licenses commercial refrigeration technicians, ten tons and over.
The 2024 legislation, S143, An Act relative to refrigeration technicians, is currently in the Senate Ways and Means Committee. However, ACA/NE and its legislative agents will remain vigilant, even during this informal legislative session to ensure it does not pass.
Click here to read ACA/NE’s testimony in opposition to S143.
The 2024 legislation, S143, An Act relative to refrigeration technicians, is currently in the Senate Ways and Means Committee. However, ACA/NE and its legislative agents will remain vigilant, even during this informal legislative session to ensure it does not pass.
Click here to read ACA/NE’s testimony in opposition to S143.
HVAC Construction Supervisors License (CSL)
ACA/NE continues its efforts on the code change proposal submitted in 2020, which urges the Board of Building Regulations and Standards (BBRS) to adopt 780 C.M.R. § 110.R55, establishing an HVAC Construction Supervisors License (CSL).
Since submitting the proposal, ACA/NE has made multiple presentations and followed up numerous times, yet the proposal remains stagnant. This lack of progress has caused increasing frustration among building inspectors and residential HVAC contractors across the Commonwealth.
ACA/NE strongly believes that the introduction of an HVAC CSL will streamline the licensing process for single- and two-story residential HVAC work. Moreover, it will implement standardized certification, testing, and continuing education requirements for professionals overseeing residential HVAC systems.
In a letter dated September 3rd, ACA/NE once again urged the BBRS to include the HVAC CSL proposal on the agenda for an upcoming meeting.
Despite the BBRS's decision to decline this request, ACA/NE remains committed to advocating for the passage of the HVAC CSL.
Click here to review ACA/NE/BBRS Communication.
Since submitting the proposal, ACA/NE has made multiple presentations and followed up numerous times, yet the proposal remains stagnant. This lack of progress has caused increasing frustration among building inspectors and residential HVAC contractors across the Commonwealth.
ACA/NE strongly believes that the introduction of an HVAC CSL will streamline the licensing process for single- and two-story residential HVAC work. Moreover, it will implement standardized certification, testing, and continuing education requirements for professionals overseeing residential HVAC systems.
In a letter dated September 3rd, ACA/NE once again urged the BBRS to include the HVAC CSL proposal on the agenda for an upcoming meeting.
Despite the BBRS's decision to decline this request, ACA/NE remains committed to advocating for the passage of the HVAC CSL.
Click here to review ACA/NE/BBRS Communication.
If you have a question or need more information about legislative and regulatory issues please, contact
Cathy Flaherty, ACA/NE Executive Director, at [email protected].
Cathy Flaherty, ACA/NE Executive Director, at [email protected].
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