Rulemaking- Chapter 173-443 WAC Hydrofluorocarbons (HFC): Formal Comment Period

Hi, my name is Julie Majurin. It's J-U-L-I-E. M-a-j-u-r-i-n, and I'm speaking on behalf of Daikin. Daikin designs and manufactures equipment in many of the sectors listed in tables 1 through 3 of Washington State's rule.

I'm speaking in support of the...↓ proposed amendments. They clarify compliance requirements and improve consistency with regulations in other jurisdictions. We anticipate that these proposed changes will streamline implementation of the statute. As well as significantly reduce compliance burdens for stakeholders like us and resolve market uncertainty in the state. Specifically, we support the proposed two-year time frame for installation of new air conditioning and VRF equipment that was manufactured prior to the effective dates in Table 3. And also, the proposed 2-year time frame for new chillers used for data center. Um, IPR…. manufactured prior to the effective dates listed in Table 2. These clarified cell provisions reduce concerns about potential disruption and help to plan and ongoing projects in the state and then reduce any resulting economic impacts from delays or loss of those projects. So we strongly encourage ecology to maintain the proposed amended provisions for AC, VRF, and chillers that effectively align the compliance dates with those already established by EPA. And then lastly, we also wanted to acknowledge our appreciation for the interpretive statement that Ecology issued in April 2025. That provided reassurance to consumers that ecology was aware of the sell-through discrepancies and intended to address them. Thank you very much.

This is Dana Fisher with Mitsubishi Electric US. Dana, D-A-N-A, Fischer, F-I-S-C-H-E-R. I am the Senior Director of Regulatory Strategy for my testimony today. It is really quite simple; I want to thank the Department of Ecology and staff for taking ...↓our comments during public hearings last fall into consideration. Specifically, related to timelines for VRF systems. The extension of 2 years for a sell-through period beyond the listed prohibition dates in Table 3, brings you into alignment with EPA and allows manufacturers, distributors, and contractors to best serve distributors across the great state of Washington. Thank you again for your efforts. We applaud your

your willingness to align with the national standards.