AUGUST 2025 ISSUE

Hot Topic: Leak Inspections!

The next RMS training will be a deep dive on everything related to federal and state refrigerant leak inspection requirements. And because the subject of mandatory leak inspections is intimately tied to the subject of automatic leak detection systems (ALDS), we’ll cover those too. Register for our “Compliance Deep Dive: Leak Inspections and ALDS,” taking place on August 26th at 10 am.

NY State Postpones Compliance. Again.

NY state’s Dept. of Conservation issued another enforcement discretion letter delaying enforcement of the R-404/507 bulk refrigerant sales prohibitions to 03/31/26. They had previously delayed enforcement through 12/31/25, so this is a 3-month extension. At what point do NY grocers stop believing that this ban will ever take place? And why are CA grocers able to cope with their ban, while NY grocers swear it will put them out of business? It can’t possibly be that New Yorkers are just whinier than Californians, can it? I await your emails with bated breath.

Reconsideration of AIM Act ERR Regs

Well, the verdict seems to be in: the Congressional Review Act effort to rescind the AIM Act Emissions Reduction and Reclamation Regs (ERR) failed. The Florida representative who couldn’t persuade the rest of Congress that it should be rescinded, Neal P. Dunn (R), is now petitioning the EPA Administrator to add the ERR to its “Reconsideration” list. The letter sent to EPA Administrator Zeldin contains several inaccuracies, and it misses the best rationales for reconsideration, but my guess is that the current EPA will jump on any excuse to reconsider any regulation. Stay tuned for future developments.

Facilio Hosts Q&A with RMS on the AIM Act Section H Regs

Join me and Leia Waln (RMS’s walking Federal Register) on September 16th at 11 am mountain for a Q&A webinar hosted by Facilio on the AIM Act Section H regulations. This is a chance to pose all those questions you were too afraid to ask. Submit your questions early or bring them to the webinar. This isn’t speculation or sales fluff — it’s your opportunity to get clear, actionable advice. Register for “Live Q&A with Keilly Witman & Leia Waln: Navigating AIM Act Section H Regs & State Mandates” today!

Washington State Proposes Increased RMP Fees

Washington state’s Dept. of Ecology (DoE) proposed adding a carbon fee to the annual Refrigerant Management Program (RMP) fees to help fund the state’s program costs. The proposal limits the fee to facilities that currently fall under the RMP – those that have at least one appliance that contains 1500+ lbs. of refrigerant – but I’m taking bets on how long it will take Ecology to apply the fee to the medium-sized systems that have to register in 2026. Submit comments on the proposal while there’s still a chance to influence it. Speak now or forever hold your peace!

The “Newly Reconsidered” TTR Approaches the Finish Line

It looks like the EPA is finished with their proposed changes to the AIM Act Technology Transitions Regulations (TTR), because they sent it to the President’s Office of Management and Budget (OMB) for review. Why is that important? OMB is the last significant hurdle before the EPA issues their proposal to the public for our comments. OMB is the office that ensures that the regulation aligns with the Trump Administration’s goals. Let’s see if the EPA’s reconsideration is reconsidered enough for the Trump Administration.

DoE Concludes that Climate Change is No Big Deal

The Department of Energy (DOE) published a report called “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” which concludes that greenhouse gases are “less damaging economically than commonly believed.” The report also states that “aggressive mitigation strategies could be more harmful than beneficial,” and that “U.S. policy actions are expected to have undetectably small direct impacts on the global climate and any effects will emerge only with long delays.” DoE has opened the report for public comments until September 2nd. Let’s see if the comments are as fun to read as I expect them to be.

Arizona Tech Dies from Extreme Heat

To the extent that anything good can come out of a story like this, let it serve as a reminder to our technicians out there to stay safe in the extreme heat. How long would you last on a hot supermarket roof in Texas in August?

US Montreal Protocol Funding Eliminated

President Trump signed H.R.4, the “Recissions Act of 2025,” a $9 billion foreign aid and public media recissions package that eliminates federal funding for a broad range of international organizations and programs. As part of this package, the annual US contribution to the United Nations Multilateral Assistance Fund for the Montreal Protocol was chopped. The money in the Montreal Protocol’s Multilateral Fund goes toward other countries’ implementation of Montreal Protocol projects.

This is NOT about Chemical Manufacturer Money

Just in case anyone got to the end of this newsletter and wondered why it didn’t contain anything about the D.C. Circuit Court upholding the AIM Act Allocation Rule, we didn’t include it because the only practical effect the decision had was on the chemical manufacturer battle over who gets to make how many billions of dollars.

Our Favorite This Month

We’re kicking-off something new this month: the favorite article or other news that tickled all of us at RMS. We tried out the idea in various issues this year with articles about Easter Potatoes, potheads, modern art HVAC vents, and funny stories about Polish smugglers. Now we’re making it official. This month, it’s an article called, “Coors Light releases refrigerable deodorant you can keep next to beer,” which we found in the ACHR News’ “The Weekly Chill.” The Weekly Chill’s tagline is “The week’s irreverent HVAC insights presented by The NEWS.” They had us at “irreverent.”

Need Some Help?

If you need help with these or any other topics related to refrigerant management, feel free to reach out to me (Keilly Witman). We’re a friendly bunch and happy to help!