While those are welcome improvements, Heating, Air-conditioning & Refrigeration Distributors International (HARDI) believes the proposal still goes too far and has put forward an alternative in which HVAC sales data would be sent to an independent third-party organization approved by the CEC, rather than directly to the state. That organization would validate and aggregate the information and remove identifying details before sharing it with the Commission. The CEC would receive summary data by county — not customer names, contractor identities, buyer addresses, license numbers, individual sales records, or other confidential business information. 

If the CEC is not prepared to adopt a mandatory aggregator structure, HARDI suggested that it should at least allow distributors to use one voluntarily. For example, companies that submit their data through HARDI's existing Unitary Market Intelligence Program (UMIP) — or another CEC-approved aggregator — would be considered in compliance with the reporting rule, as long as the aggregator provides the required summary data to the state. 

HARDI is not alone in arguing that California can obtain useful information without collecting transaction-level data. In their comments to the Commission, AHRI and Daikin both suggested that aggregated and anonymized shipment data should be enough to satisfy CEC's policy needs. Both also favor a statewide online permitting system, which would provide a more direct and accurate way to track actual installations and improve permit compliance. That’s because sales data may show equipment moving through the supply chain, but it cannot reliably establish where a unit was installed, who installed it, or whether a permit was obtained. 

Taken together, these seem like common-sense approaches. If California's objective is to understand how many heat pumps, air conditioners, and water heaters are entering the market, aggregated statistics should provide the information needed for forecasting and policy decisions. Collecting the purchasing history of individual contractors or maintaining databases of customer information appears to offer little additional value toward those objectives. 

The concerns expressed by individual contractors reinforce that point. Two California HVAC contractors who submitted comments to the CEC argued that small businesses lack the staff and systems needed to comply with additional reporting requirements, meaning more administrative work, higher operating costs, and ultimately higher prices for homeowners. One also warned that duplicating information already collected through permitting and rebate programs could place licensed contractors at an even greater competitive disadvantage against unlicensed operators. 

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One contractor summarized the concern this way: “These added costs will likely be passed on to California homeowners through higher installation and service prices. At a time when many families are already struggling with the cost of replacing heating and air conditioning systems, I believe we should be reducing unnecessary burdens, not creating new ones.” He urged the Commission to “consider solutions that achieve California's energy goals without imposing additional reporting requirements on small HVAC businesses.” 

Those are legitimate concerns. California's HVAC industry is made up of thousands of small independent contractors that already navigate an increasingly complex regulatory environment, and every new reporting requirement carries a cost. 

Whether the Commission ultimately adopts these suggestions remains to be seen, although it has already shown a willingness to refine its proposal based on earlier feedback. As it reviews this latest round of comments, consideration should be given to stakeholders’ compelling arguments that there may be a better way to collect the information the CEC is looking for.