While intended to support energy planning and permit compliance efforts, the proposal would require the collection and reporting of sensitive business data and create new compliance burdens across the HVACR supply chain.

HARDI has proposed a better alternative that would provide the CEC with the aggregated market data it needs while protecting confidential business information and avoiding government disclosure mandates.

Please take a moment to urge the CEC to reject unit-level sales tracking requirements and instead adopt a practical, aggregated reporting approach that supports state objectives without creating new burdens for contractors and distributors.

The official Request for Information is available here.

The CEC is specifically requesting information outlined in the RFI. The best comments will counter the need for a tracking registry and show that HARDI's alternative proposal is better for California and industry.