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ACCA Comments & Testimony

ACCA and our leaders and members regularly testify before Congressional committees, and submit comments on regulatory matters to federal agencies. Read them here!

R-22 Production and Consumption Phase Out
The EPA is proposing to reduce the production and consumption of HCFCs in the years 2010-2014 as part of the phase out mandated by the Montreal Protocol and the Clean Air Act. ACCA commented on the proposed step down and EPA's unorthodox interpretation of when air conditioning or refrigeration system is "manufactured." Read it.

ACCA Comments on OSHA's Crane and Derricks Rule
OSHA has proposed new rules governing the use of cranes and derricks used in construction. ACCA filed comments on the proposed rules on behalf of the small businesses of the HVACR industry. Read it.

ACCA Testimony on EPA's Proposed HCFC Allocation Rule
Presented on January 7, 2009 at a hearing on the Allocation Rule. Read it.

ACCA Testimony on EPA's Ban on Pre-Charged Equipment Rule
Presented at a January 7, 2009 hearing on the Pre-Charged Rulemaking. Read it.

The Role of Green HVAC in Creating Jobs
Ellis Guiles showed the House Committee on Small Business how green HVACR technologies can spur economic growth and create jobs. Read it.

ACCA Responds to California Utility Proposal
On March 24, ACCA responded to a proposed strategic plan for energy efficiency from the California Investor-Owned Utilities. ACCA's comments were supported by letters from a wide variety of industry organizations, including AHRI, HARDI, IAQA, NAFA, NATE, PHCC, and RSES. Read it.

Depreciation Rules for HVAC Must Be Changed
ACCA board member David Kyle of Trademasters Service Corp. testified before the Regulatory Fairness Board on the need for changes in HVAC depreciation rules. Read it.

Small Business Energy Priorities
ACCA past chairman Mitchell Cropp testified on energy legislation pending before Congress. Read it.

Changes Needed in Section 608
ACCA member Richard Dean testified on the need to enforce Section 608 requirements for refrigerant handling. Read it.

Small Business Expensing
ACCA member Brian Harvey testified on the need to change expensing rules to provide incentives for small business. Read it.

Removing Obstacles to Job Creation
ACCA member Richard Dean testified on ways the government can encourage small businesses to create more jobs. Read it.

Anti-competitive Threats from Utilities
ACCA member Brian Harvey testified on potential threats to small business from subsidized utility companies. Read it.

Organizing Against Small Business
ACCA member Ray Isaac testified on certain union organizing tactics and their affect on small business. Read it.

Comments on Lead Paint Renovation Rule
ACCA commented on a proposal from the EPA regarding renovation requirements in homes with lead paint. Read it.