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It’s been a crazy couple of years for the HVAC industry, thanks to the seemingly endless stream of regulatory and legislative requirements coming from various levels of state, local, and federal governments. From environmental concerns driving energy-efficiency mandates and the phasedown of HFC refrigerants to the global push for electrification and sustainability, the HVAC industry finds itself at the intersection of numerous, often conflicting, demands.

And right in the middle of the fray, you’ll often find Chris Forth, vice president of regulatory, codes, and environmental affairs at Johnson Controls. In his current position, Forth is responsible for monitoring and addressing the numerous issues that could affect the company’s products.

“I'm looking out for anything that could impact our products, from a regulatory or legislative front,” said Forth. “I’m responsible for helping Johnson Controls navigate the patchwork of different regulations, different dates, whether it concerns refrigerants or energy efficiency. It is great when there is a national baseline, but that doesn't happen in all cases. Some states are finding ways around federal preemption, and that makes it very complex.”

Career Progression

But Forth is up to the challenge, given his wide-ranging experience and deep knowledge of the HVAC industry. He began his HVAC career in 1990, when he graduated with a bachelor’s degree in engineering and later with a master’s degree in engineering management from Oklahoma State University. He immediately got a job with Aaon in Tulsa, Oklahoma, which focuses on custom commercial HVAC systems. During his time there, he specialized in understanding customer specifications and designing HVAC equipment for several of the company’s national accounts.

In the early 1990s, Forth seized an opportunity to work for York, which was looking to expand its national accounts business. In 2005, Johnson Controls (JCI) acquired York, and Forth has been with the company ever since. Over the course of his 30-year career in HVAC, Forth has progressed from an engineer to an engineering director to product management, and his roles have expanded to encompass both commercial and residential product lines, including international responsibility. In 2018, his passion for shaping regulations and standards led to a full-time regulatory role, a position that he thoroughly enjoys, even though it requires a tremendous amount of time, energy, and travel.

“I really like my job because it utilizes all my experiences in engineering and product management, as well as my knowledge of customers and the market. It also requires a great deal of strategy,” said Forth. “I think most people consider regulations to be simply compliance, such as meeting EER or SEER. They don’t realize just how much strategy is involved when dealing with test procedures, building codes, timing, etc. And honestly, I like the politics of it, as I get to negotiate with regulatory bodies and legislative officials.”

That said, Forth concedes that it can be a challenge to keep abreast of the numerous regulations that have affected the HVAC industry in recent years. That’s because regulations at the state, local, and federal levels can encompass everything from refrigerants to efficiency standards to plastic usage to emissions from gas-fired equipment.

“I've been in our industry a long time, and I've never seen the amount of regulatory actions being taken across all levels as we are experiencing today,” he said. “It's the cumulative effect of all these regulations from the different bodies, from federal to state to local entities like the Air Quality Districts in California. There’s never a dull moment.”

Current Workload

Indeed, Forth has been involved with just about every regulatory issue that affects the HVAC industry, from the 2023 Department of Energy energy-efficiency regulations, which included the controversial date-of-installation mandate for southern regions, to the Inflation Reduction Act. Then of course, there’s the AIM Act, which phases down the use of HFC refrigerants, necessitating updates in building codes across all 50 states to facilitate the adoption of the new, mildly flammable (A2L) refrigerants.

TRAVELING MAN: When he’s not working on regulations or code issues, Chris Forth likes to travel with his lovely wife, Sonja. (Courtesy of Chris Forth)

“Lately, a significant portion of our efforts have been dedicated to codes and standards,” said Forth. “We’ve spent a huge amount of time, trying to get these codes updated through the code bodies, ICC and IAPMO. It’s really a state-by-state battle. I’ve been traveling all over, testifying at state hearings to prepare for compliance by January 1, 2025, and subsequently, for VRF systems by January 1, 2026.”

Forth believes most states will be ready to meet the deadlines noted above, although it could come down to the wire in some states. For example, Kansas has no statewide building codes, and Hawaii and Alaska have not yet passed legislation or updated their building codes.

Another focus for Forth is the date-of-installation mandate that was included in the Environmental Protection Agency’s (EPA’s) “Technology Transitions” final rule, which was published in early October. EPA had previously indicated that the final rule would include a sell-through period for equipment manufactured up until January 1, 2025 (“date of manufacture”), so distributors and contractors would not be stuck with equipment that could not be legally installed. Instead, EPA unexpectedly included a “date of install” requirement for complete, new, split-system air conditioners and heat pumps, which now must be installed no later than January 1, 2025.

Given that this final rule takes will take effect for some most residential and light commercial products in a little over a year, Forth will be very busy for the remainder of 2023 – and beyond. In the meantime, he advises those in the HVAC industry to not be alarmed but to proactively address the challenges posed by this contentious regulation.

“It’s possible that rule could be revised before its effective date, making it important for all stakeholders to continue to monitor EPA and their trade organizations for any changes,” said Forth.