Conduct realistic cost assessments of the HFC phasedown program

Research notes

• Reviewed 2026-09-06. Status unchanged. The earlier note said the rule’s regulatory impact analysis could not be read because the Federal Register’s full-text pages would not open for us. That was true of federalregister.gov, not of the document: the full text opens on govinfo.gov, at govinfo.gov/content/pkg/FR-2026-05-26/html/2026-10387.htm. We searched it for “Regulatory Impact Analysis” (1 hit, the cross-reference to the 2023 docket), “cost savings” (18, all the rule’s own flexibility savings), “annualized” (4, the EAV presentation), “cost to consumers” (0), “net cost” (0) and “benefit-cost” (0).
• The finding is sharper than the earlier note could be. It is not only that no separate cost assessment was published; it is that the one rulemaking in the window that reopened the program’s costs measured only its own savings and explicitly deferred to the 2023 analysis for everything else. That is the administration touching the ask’s object and declining the ask.
• Negative search (2026-08-27): no EPA notice, report or guidance in the window is titled as a cost assessment of the hydrofluorocarbon phasedown.
• Unified Agenda, read 2026-09-01. We read EPA’s full Unified Agenda on reginfo.gov (214 entries across the active, long-term and completed stages), because the Federal Register prints only the entries that need a Regulatory Flexibility analysis, and the 2026-08-27 negative was taken from that abbreviated version. Nearest entry: RIN 2060-AW39, Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020 (EPA/OAR, Final Rule Stage): https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=2060-AW39. It reopens particular requirements; it is not the cost assessment of the program that the Quote asks for, and no cost or economic-analysis RIN appears anywhere on the agenda. Status unchanged.