EPA Compliance Insights | What Is “Light Commercial” HVAC?

A Q & A with Ted Atwood on EPA Compliance and Perfection.

In the HVAC world, “Light Commercial” is the term that ends conversations and starts budget surprises.

While the industry has spent decades using it as a convenient shorthand for sales channels or building types, the 2026 AIM Act and recent EPA compliance regulation changes have turned it into a high-stakes legal hinge.

We sat down with Carbon Connector co-founder and 30-year industry veteran Ted Atwood to talk about why most facility leaders are “flying blind” when it comes to light commercial and compliance, and how to start managing for realities rather than regulations.

Q: Ted, we’ve talked before about how light Commercial HVAC is a vibe rather than a definition. Why is this still such a controversial topic in the industry?

Ted Atwood: It’s controversial because it’s being forced to do two incompatible jobs.

On one hand, it’s a sales shorthand—Carrier or York selling to a specific vendor network. On the other hand, it’s a regulatory category.

The EPA regulates systems 15 lbs and over unless they’re light commercial, but they’ve never actually defined the term.

I’ve sent 28 emails asking for clarity. No definition. Just links.

This creates a massive, difficult-to-enforce loophole. Some retailers claim the label just to avoid EPA tracking, while the OEM manufacturers will tell you the exact same hardware is commercial.

Eventually, this will be settled in court, not in a meeting room.

Q:  If there’s no federal definition of light commercial, what should multi-state operators do right now to protect themselves?

Ted Atwood: Stop using the government’s rules to define your management style. If you manage to regulate, you’ll be changing your strategy every time a new administration comes in.

Instead, build your own internal standard based on the broadest scope of existing rules and apply it to every location in every state. Then it doesn’t matter what changes externally; you have a defensible posture.

And don’t wait for perfect. Perfection is the enemy of progress. I’ve never been to the North Star. I see it in the sky, but I’m not going to get there.

Having a North Star is great, but feeling like a failure because you didn’t get there? That’s every person on this planet. Start somewhere.

Q: What is the single most important tactic a leader can deploy today to stop “flying blind when it comes to EPA compliance?

Ted Atwood: Identify and verify your assets. You can’t budget accurately or hold vendors accountable for equipment you haven’t physically verified.

We find that between 30% and 60% of assets on a typical corporate spreadsheet are wrong. Either they aren’t there, or the specs are incorrect. And tagging isn’t a one-time milestone. It’s a live-action verb.

You need a system where anyone, a store manager, a front-end clerk, can snap a photo and get an asset profiled.

→ Looking to learn how to turn HVAC guesswork into operational certainty? See how Tag Wizard helps you profile your assets in minutes.

Q: What does it actually cost a company when their HVAC equipment asset list isn’t accurate?

Ted Atwood: I know of a retailer that added standalone refrigerated units to their stores specifically to sidestep the commercial and light commercial classification altogether. They thought they were being efficient.

But those units dump heat straight into the store and add roughly 10 extra tons of heat load for every 10 units added.

Because they didn’t have an accurate rooftop equipment list, nobody caught the load increase until the rooftop units couldn’t keep up and the complaints started rolling in.

They had to go back across multiple locations and add more cooling to the roof at emergency pricing. Then it turned out one store was borrowing equipment from another.

It was an absolute mess. If you don’t know your cooling load, you don’t know your store.

Q: You’ve used a car insurance analogy for HVAC. How does that apply to a facility manager’s risk profile?

Ted Atwood: It lands every time because it’s so absurd. Imagine an insurance company calls you and asks what kind of car you have, and you say, “I don’t know”. They ask if it’s an SUV, and you say, “Well, what’s an SUV? It’s just big”.

You can’t insure a car you can’t describe, yet that is exactly how most companies manage millions in HVAC inventory.

If you don’t know the tonnage, the age, or the refrigerant type of your assets, you aren’t managing risk; you’re guessing.

Q: Final thoughts for facility and compliance managers in 2026?

Ted Atwood: Posture around effectiveness, not just EPA regulations. Focus on food safety, efficient use of budget, and fewer after-hours service calls. Use the EPA’s documentation standards for systems over 15 lbs as an internal accountability tool to manage your service providers.

Don’t wait for perfect. Start by identifying the assets you have, and the rest of your strategy will fall into place.

→ For a deeper look at how “light commercial” is treated under current regulations, read our Complete Guide to Light Commercial HVAC Under the AIM Act.