Comments on New York Department of Environmental Conservation’s Proposed Amendment Regarding Hydrofluorocarbon Use

This letter was authored by John Ketcham and digitally delivered to the New York State Department of Environmental Conservation.

My name is John Ketcham, and I am a fellow and director of cities at the Manhattan Institute, located in New York City.

I write to you respectfully to express reservations about the New York Department of Environmental Conservation’s (DEC) proposed amendment to 6 NYCRR Part 494 regarding hydrofluorocarbon (HFC) use. Though the proposed amendment’s intent is admirable, its adverse consequences on New York’s residents and businesses outweigh its putative environmental benefits. According to the U.S. Energy Information Administration, New York has long been at or near the bottom of states in terms of emissions and energy consumption per capita. Each New Yorker’s energy-related CO2 emissions amount to just 7.9 metric tons (mt) annually, a fraction of that produced by populous states like Texas (22.4 mt) or Pennsylvania (16.4 mt). Producing one million dollars of state GDP requires under 250 metric tons of CO2 in New York, less than half of states like Florida, Texas, and California. New York’s total HFC emissions, of around 9.32 million metric tons of CO2e (calculated using UN accounting), represent a mere 0.142% of the approximately 6,341 million metric tons of total U.S. CO2-equivalent emissions in 2022 estimated by the U.S. Environmental Protection Agency. These achievements result largely from New York City’s environmentally friendly dense multifamily housing, extensive public transit system, and advanced service-based economy.

Click here to read the full letter.

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John Ketcham is a fellow and director of cities at the Manhattan Institute.

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