IREON Insights: Have HVAC in your building? New laws require replacement, not maintenance!

Long Island, NY For decades, building owners relied on a simple formula: maintain your HVAC system, extend its life, control costs. That era has officially ended. Federal refrigerant phaseouts, updated fire safety codes, and aggressive New York City emissions laws are forcing building owners to confront an uncomfortable reality in New York City and beyond. 

Your existing HVAC systems are becoming obsolete by law.

The technical aspects of these new regulations are cumbersome and complex, but the bottom line is straightforward: your current system, even if running perfectly with years of service life remaining, will be required by law to be replaced well before its intended end-of-use date. This isn’t about equipment failure, it’s about regulatory compliance that makes continued operation either illegal or financially unsustainable.

Under the American Innovation and Manufacturing (AIM) Act, the EPA has mandated the phaseout of refrigerants that contribute to global warming. Starting January 1, 2025, production and import of R-410A refrigerant for new HVAC equipment was prohibited. R-410A is the refrigerant used in virtually every commercial rooftop unit, split system, and VRF installation from the past 15 years. Before that, R-22 (banned in 2020) powered most systems.

“Building owners need to understand this isn’t about equipment failure, it’s about regulatory compliance,” said Alex Lipsky, president at Lipsky Construction Management. “Even if your system runs perfectly, the refrigerant that keeps it operational is being made illegal and is disappearing from the supply chain.”

Replacement refrigerants, such as R-32 and R-454B, aren’t simple substitutes. They require completely different equipment and safety protocols. You cannot simply swap refrigerants in existing systems. Building owners face full equipment replacement, not refrigerant conversion. Updated fire codes have added another layer of complexity. Newer refrigerants now require fire-rated enclosures for refrigerant piping in certain applications. This requirement didn’t exist for older R-410A or R-22 systems.

Lipsky emphasizes the scope: “We’re not talking about minor upgrades. Fire-rated enclosures for refrigerant lines mean rethinking how mechanical systems integrate with building infrastructure. Shafts, penetrations, and routing all need reassessment. When you replace an HVAC system with new compliant equipment, you’re not just swapping out the old units. You’re potentially renovating mechanical spaces, upgrading ventilation, installing refrigerant detection systems, and enclosing previously exposed piping. All upgrades adding significant cost and complexity to your building.”

New York City’s Local Law 97 delivers the knockout punch. Part of the Climate Mobilization Act, LL97 establishes strict greenhouse gas emissions limits for buildings over 25,000 s/f, with the first compliance period already underway since January 2024.

Older HVAC systems, even well-maintained ones, cannot meet these emissions targets for 2024-2029, with even stricter limits arriving in 2030. Penalties for non-compliance start at $268 per ton of CO2 equivalent over the limit, which for larger buildings can quickly escalate into hundreds of thousands of dollars annually.

Jimmy Moyen, principal of First Choice Mechanical said, “Local Law 97 fundamentally changes the economic calculation. Building owners can’t just patch and pray anymore. The law creates a financial imperative to upgrade to high-efficiency systems, regardless of whether your current equipment still functions.”

Upgrading to modern, high-efficiency equipment is the primary pathway to compliance. With R-410A phased out and R-22 systems long past their service life, replacement becomes the only viable option.

What makes this moment particularly challenging is the convergence of multiple regulatory pressures. Building owners aren’t dealing with one law, they’re navigating overlapping federal, state, and local requirements that collectively eliminate any pathway except full system replacement. The only economically rational response is complete system replacement with modern, compliant, high-efficiency equipment designed to meet LL97 targets.

First Choice Mechanical advises building owners to approach this transition strategically: “Don’t wait for equipment failure to force your hand. System replacement in crisis mode costs more, takes longer, and limits your options,” said Moyen.

Property owners should begin with comprehensive mechanical assessments that evaluate not just equipment condition, but regulatory compliance trajectories. What works today may be illegal or financially unsustainable within 24 months. Understanding that timeline enables proactive capital planning rather than reactive crisis management.

Building owners should also explore available incentives and financing options. Various state and utility programs offer rebates for high-efficiency HVAC upgrades, and specialized financing can help distribute costs while energy savings begin offsetting investment.

The message for New York City building owners is clear: the era of HVAC maintenance as a long-term strategy has ended. Federal refrigerant phaseouts, fire code updates for A2L refrigerants, and Local Law 97’s emissions targets have created a regulatory environment where replacement isn’t just advisable, it’s inevitable.

The clock is ticking. The regulations are here. The only choice left for your HVAC is how to respond.

Lipsky Construction Management is a construction management, general contractor, and owners rep for construction projects throughout Long Island and the outter Boroughs. 

First Choice Mechanical is a MBE Certified HVAC solution for the design and installation of mechanical systems throughout Long Island and NYC.