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HVAC in Washington: the heat pump mandate that was removed, and the new cooling load

Washington is often said to require heat pumps. It does not: the mandate was deleted before the code took effect.

Updated September 2026 · Data as of EIA 2024 prices; 2021 WSEC as amended by WSR 23-21-105

Written by HYRE HVAC Research Desk Primary-source research and analysis

Audited by HYRE HVAC Research Desk Fact check against the Washington State Register, the State Building Code Council, eCFR, EIA, NOAA and Washington L&I

52.5% of Washington households have air conditioning, against 88.7% nationally EIA RECS 2020, 52.5% ± 2.8 percentage points
291 household-weighted cooling degree days — the lowest of the eight states we cover EIA RECS 2020
1,223 Washington contractor records verified against L&I license data Washington State Department of Labor & Industries, retrieved August 29, 2026

The short answer

Washington does not require heat pumps. The 2021 Washington State Energy Code took effect March 15, 2024, but its heat pump mandates were removed first over federal preemption.

Its Table R406 credit system makes a gas-heated home earn more credits instead. The DOE regional AC standard does not apply here.

Only 52.5% of homes have AC, so a heat pump is often the cheapest way to add cooling.

What does the Washington energy code require in 2026?

Energy credits, not a heat pump mandate. Most Washington HVAC pages get this wrong by describing a rule that was struck out of the code before it ever took effect.

Source fact: The current residential energy code is the 2021 Washington State Energy Code, chapter 51-11R WAC, adopted November 4, 2022 and effective March 15, 2024.

The State Building Code Council publishes it as “WAC 51-11R (Residential) 2nd Edition, 2nd Printing (Sept 2024)” and describes it as: “Based on the 2021 IECC.”

The Department of Energy’s Building Energy Codes Program records the same edition and the same effective date for both residential and commercial buildings.

Source fact: Between adoption and that effective date, the Council amended it.

WSR 23-21-105, filed October 18, 2023, was made to address preemption under the Energy Policy and Conservation Act of 1975 in the light of the Ninth Circuit’s decision in California Restaurant Association v. City of Berkeley.

The rule deleted section R403.13, the heat pump space heating requirement, and deleted section R403.5.7, the heat pump water heating requirement.

It also moved the baseline of the Table R406 credit system from a heat pump to a combustion heating system and redistributed the credits accordingly, adding further credit options.

HYRE HVAC Research Desk analysis: The distinction matters commercially and legally. Washington does not require you to install a heat pump, and a contractor telling you the state has banned gas furnaces is wrong.

What Washington has is a performance-credit code: a new or substantially altered home must accumulate a required number of energy credits from Table R406.

A home that heats with combustion has to make up the efficiency the heat pump baseline would have delivered from somewhere else — better envelope, better windows, a heat pump water heater, ventilation heat recovery. Gas remains legal. It is simply more expensive to comply with.

The useful next step: If you are building or doing a substantial alteration, ask your contractor which Table R406 credits your design is claiming and to show the total against the requirement.

That single sheet is what the permit reviewer will look at, and it is where a gas decision either pays for itself elsewhere or does not.

Does the DOE regional efficiency rule apply in Washington?

No. Source fact: 10 CFR § 430.32(c)(6) sets a national minimum for split-system air conditioners and then adds a higher, installation-enforced floor in two regions only: the Southeast (14.3 SEER2 under 45,000 Btu/hr) and the Southwest (the same, plus an EER2 floor of 11.7/9.8).

Washington is in neither. Its air conditioners are held to the national 13.4 SEER2, which is triggered at manufacture rather than at installation.

Source fact: And the correction that matters everywhere: the regional standard reaches air conditioners only. Heat pumps carry no regional installation standard anywhere in the United States.

Their floor is the national 14.3 SEER2 and 7.5 HSPF2 — in Washington, in Arizona, and in every other state. Our study of the regional split reads this out of the full CFR text.

HYRE analysis: The practical consequence for a Washington buyer is that the federal floor is low and does almost nothing for you.

HSPF2 — the seasonal heating efficiency measure — is where a Washington system earns or loses its money, and 7.5 is a floor, not a target. Equally important and not federally regulated at all: rated capacity at low outdoor temperatures.

A heat pump’s output falls as it gets colder, and the number that decides whether your house stays warm in January is the capacity at your design temperature, not the SEER2 on the brochure.

Our cold-climate performance study covers what that data looks like and where to find it.

Why do so few Washington homes have air conditioning?

Heating against cooling degree days, six Washington counties● heating degree days   ● cooling degree days02,5005,0007,50010,000Benton County (Tri-Cities)744 CDDSpokane County (Spokane)337 CDDClark County (Vancouver)263 CDDKing County (Seattle)80 CDDPierce County (Tacoma)68 CDDOkanogan County153 CDDNOAA nClimDiv 1991–2020 county normals, base 65°F, summed by HYRE from the twelve published monthly values.Gray dot is heating, dark dot is cooling.
Six Washington counties: King County and Benton County are in the same state and the same energy code, and one of them barely has a cooling season. NOAA nClimDiv county degree-day normals, 1991–2020. Annual sums computed by HYRE from the published monthly normals.

Because until recently they rarely needed it. Source fact: EIA’s Residential Energy Consumption Survey 2020 records 52.5% of Washington households with air conditioning (52.5% ± 2.8 percentage points) — 50th of the 51 jurisdictions reported, and far below the national 88.7%. Washington’s household-weighted cooling load is 291 degree days against 4,793 heating.

Source fact: NOAA’s 1991–2020 county normals show the Cascades doing the work. King County, containing Seattle, records 80 cooling degree days and 6,290 heating.

Benton County, east of the mountains, records 744 cooling — about 9 times as much — and Okanogan County records 8,164 heating degree days.

Across 39 counties the median is 157 cooling and 6,319 heating degree days.

Source fact: Those normals cover 1991–2020, and they end just before the event every Washington homeowner now sizes against.

NOAA records that Seattle reached “108 on June 28 after reaching 104 the day prior” in late June 2021, and that “in the previous 126 years, Seattle had only hit 100 degrees three times. It reached that mark in three consecutive days in June!”

HYRE HVAC Research Desk analysis: This is why a 30-year normal is the wrong sole input for a Washington cooling decision, and it is an honest limitation of the degree-day figures on this page.

A normal describes a typical year; the reason Washington households are adding cooling is not the typical year but the tail.

A system sized only to 80 cooling degree days is sized for the season, not for the week that matters — and in a housing stock built for a climate without air conditioning, that week is also a health question rather than a comfort one.

Recommendation: Ask what outdoor design temperature the load calculation used and whether it reflects recent extremes rather than the 1991–2020 normal alone. Then ask what the system’s rated cooling capacity is at that temperature.

For a house with no existing ductwork — common in Washington’s older stock — a ductless heat pump usually answers both the heating and the cooling question with one machine, which is a materially different proposition from bolting an air conditioner onto a gas furnace.

What does it cost to run, and which licenses cover the work?

Annual Washington running cost by end use, EIA 2024 state prices0Gas furnace, 95% AFUE$296Heat pump, seasonal COP 3.0$266Cooling, either system$244HYRE calculation. West census-region consumption averages from EIA RECS 2020 Table CE3.1, at Washington’sEIA 2024 residential prices of 11.90 cents per kilowatt-hour and $12.72 per thousand cubic feet.
Washington annual running cost by end use: Cooling is the smallest bar on this site by a wide margin, which is why the Washington argument for a heat pump is not primarily a running-cost one. HYRE calculation from EIA-861 and EIA Natural Gas Navigator 2024 Washington prices and RECS 2020 west-region consumption averages.

A heat pump heats for about $266 a year against $296 for gas, and two L&I licenses cover the work. Source fact: EIA’s 2024 residential averages for Washington are 11.90 cents per kilowatt-hour — 47th of 51 jurisdictions, among the cheapest electricity in the country — and $12.72 per thousand cubic feet of natural gas.

HYRE calculation: Applying the west census-region consumption averages from RECS 2020 Table CE3.1: a 95% gas furnace costs about $296 a year, a heat pump at a seasonal COP of 3.0 about $266, and cooling only about $244.

The breakeven seasonal COP is 2.70. The heat pump wins, but narrowly — Washington’s cheap hydroelectric electricity and cheap gas move together, so the running-cost margin here is smaller than in Arizona or Florida.

Washington ranks 20 of 51 on our Heat Pump Readiness Index.

HYRE analysis: Notice the third bar. Washington is the mirror image of the Sunbelt: heating is almost the entire bill and cooling is a rounding error.

So the efficiency money belongs on heating performance and on the envelope — and, uniquely among our eight states, the strongest financial argument for a heat pump here is often not the running cost at all but that it delivers cooling a furnace cannot, to a house that currently has none.

Source fact: Washington splits this work across two license regimes, and our store shows both.

Of the 1,223 Washington records verified against the Department of Labor & Industries' contractor license data on August 29, 2026, 760 are registered as “CONSTRUCTION CONTRACTOR — Heating/Vent/Air-Conditioning and Refrig (HVAC/R) (specialty SM)”.

463 hold an electrical contractor license in the HVAC/refrigeration specialty: 447 as “ELECTRICAL CONTRACTOR — HVAC/RFRG (specialty 6A)” and 16 as “ELECTRICAL CONTRACTOR — HVAC/RFRG-RESTRICTED (specialty 6B)”.

HYRE analysis: That split is not bureaucratic trivia. A ductless heat pump installation is substantially electrical work — a dedicated circuit, a disconnect, often a panel assessment — and in Washington the electrical side is licensed separately by L&I. The 6B “restricted” specialty is narrower again.

So the right question is not “are you licensed?” but “who is doing the electrical work, under which license?” If the answer is a subcontractor, ask for their license number too.

The useful next step: L&I publishes contractor license data openly. Look up the registration, confirm it is active, and check the bond and liability entries — Washington requires both, and both lapse.

What should you ask a Washington HVAC contractor?

Which Table R406 credits the design claims, and the total against the requirement

The 2021 Washington State Energy Code is a credit code, not a mandate code. If you are keeping gas, the credits have to come from somewhere else, and that sheet is what the permit reviewer reads.

The rated heating capacity at your design temperature, not the HSPF2

HSPF2 is a seasonal average and the federal floor of 7.5 is low. Capacity at the coldest hours is what keeps the house warm, and it is not federally regulated.

What outdoor design temperature the load calculation used

NOAA’s normals cover 1991–2020. Seattle reached 108°F on June 28, 2021, which those normals barely reflect. Ask whether the cooling side was sized for the season or for the extreme.

Who performs the electrical work and under which L&I license

Washington licenses the electrical side separately — 463 of the 1,223 records we verified hold an electrical contractor license in the HVAC/refrigeration specialty. On a ductless install this is most of the work.

Whether your panel has capacity, before the equipment is ordered

A heat pump and, later, a heat pump water heater both draw on the service. Finding out afterwards that a panel upgrade is needed turns a straightforward job into a much larger one.

Do not accept "Washington requires a heat pump" as a reason

It does not. WSR 23-21-105 removed sections R403.13 and R403.5.7 from the code over federal preemption. A heat pump may well be the right answer for your house — but if this is the argument being made, the rest of the quote deserves a closer look.

Do not accept a federal tax credit as part of the price

§25C and §25D both closed for property placed in service after December 31, 2025 under Public Law 119-21. Washington state and utility programs are separate and unaffected.

What does our Washington contractor data cover?

Source fact: HyreHVAC’s store holds 1,223 Washington records verified against the Department of Labor & Industries' contractor license data, published through the Washington Open Data Portal and retrieved August 29, 2026. Each carries the issuing authority, the register checked and the date of the check. No Washington record failed verification.

What that is not: 1,223 records is 13.7% of the 8,930 verified records we hold across 8 jurisdictions, and it is not a census of Washington HVAC contractors.

It is not a ranking, and no company has paid for a position in it. Every national claim on this site rests on federal data — EIA, NOAA, the CFR — never on our own counts.

The useful next step: Verify any contractor yourself against L&I’s own record. Our licensing study explains what the eight state registers do and do not prove, including why “we could not verify this” and “this contractor is unlicensed” are different findings that must never be printed as the same one.

Questions

Does Washington require a heat pump in new homes?
No. The 2021 Washington State Energy Code’s heat pump sections R403.13 and R403.5.7 were removed by WSR 23-21-105, filed October 18, 2023, over federal preemption. The code in force since March 15, 2024 uses Table R406 energy credits instead, so a gas-heated home must earn more credits. Gas is legal; it is harder to comply with.
Which energy code applies to my Washington project?
The 2021 Washington State Energy Code, chapter 51-11R WAC, effective March 15, 2024, published by the State Building Code Council as “WAC 51-11R (Residential) 2nd Edition, 2nd Printing (Sept 2024)” and based on the 2021 IECC. The Department of Energy’s Building Energy Codes Program records the same edition and effective date.
Does the DOE regional efficiency standard apply in Washington?
No. 10 CFR § 430.32(c)(6) raises the air-conditioner floor only in the Southeast and Southwest regions. Washington is in the North, so equipment here is held to the national minimum of 13.4 SEER2 for split-system air conditioners. Heat pumps carry no regional installation standard anywhere in the country, Washington included.
Why do so few Washington homes have air conditioning?
Because until recently they rarely needed it. EIA RECS 2020 records 52.5% of Washington homes with AC against 88.7% nationally, and NOAA normals put King County at 80 cooling degree days a year. Installations are rising after events like late June 2021, when NOAA records Seattle at “108 on June 28 after reaching 104 the day prior”.
Is a heat pump cheaper to run than a gas furnace in Washington?
Yes, but by less than in most states. At EIA 2024 Washington prices, a heat pump (seasonal COP 3.0) heats for about $266 a year against $296 for a 95% gas furnace; the breakeven COP is 2.70. Both fuels are cheap here, so the stronger argument is usually the cooling a furnace cannot provide.
What license should a Washington HVAC contractor hold?
It depends on the work. L&I registers construction contractors with an HVAC/R specialty and separately licenses electrical contractors in HVAC/refrigeration. Of the 1,223 Washington records we verified on August 29, 2026, 760 hold the registration and 463 the electrical license. A ductless install is largely electrical, so ask who does that part.

Written and audited by

HYRE HVAC Research Desk

Primary-source research, data analysis and fact checking

We are a research desk, not a sales floor. We read the federal microdata file, the statute or the manufacturer data sheet ourselves, and we publish the figure with the document it came from and the date we retrieved it.

Where a number cannot be traced to a primary source, we publish the shorter page and say what we could not verify.

The counts below are generated from the published pages themselves, last counted September 28, 2026, and they are what we have actually published rather than what we intend to.

13
studies published
12
federal sources read and cited
8
studies published with their full dataset as CSV
51
jurisdictions reproduced against EIA’s own tables

How this desk works

  • Primary sources only. Federal data comes from the agency that collects it, in the file that agency publishes. We do not cite an article that cites a source; we download the source and compute the figure ourselves.
  • We validate against the agency before we publish. First, we use each federal microdata file to reproduce the agency’s own published tables. Our cooling research reproduces EIA’s state estimates and standard errors for all 51 jurisdictions. That check caught a variance formula that was off by a factor of four.
  • Every estimate carries its uncertainty. These are survey figures, not counts. Standard errors are computed from the replicate weights the federal file supplies and printed beside the estimate. An estimate too imprecise to publish is reported as such rather than printed.
  • Nothing is typed by hand. Prose, tables and charts all read from one dataset built by script, so a number in a sentence and the same number in the table below it cannot disagree.
  • We publish the data, not just the conclusion. 8 of our 13 studies offer the full computed table as a CSV download on the page, so you can check the analysis or disagree with it. A study without a row-level dataset gets no download link and claims none in its structured data.
  • We correct in public. Where we have published a figure wrongly we fix the figure, rewrite any analysis that rested on it rather than patching the number underneath it, and leave a dated correction note on the page.
  • We do not install or sell HVAC equipment, and we take no payment for placement, ranking or a favorable mention. Nobody buys a position on this site.

Data as of EIA 2024 prices; 2021 WSEC as amended by WSR 23-21-105. Authorship on this site is organizational: the analysis belongs to the desk rather than to a named individual, and we do not publish credentials we do not hold. Our editorial policy sets out how we source, date and correct what we publish.

Sources & retrieval dates

DOE regional efficiency standards, 10 CFR § 430.32(c)(5)–(6) , Minimum SEER2 and EER2 for central air conditioners and heat pumps, and the three-region split that makes the air-conditioner floor higher in the Southeast and Southwest than in the rest of the country. Retrieved from the eCFR versioner API for the September 1, 2026 text of title 10 part 430; the region lists and both standard tables were transcribed from that XML. Retrieved September 5, 2026.
NOAA nClimDiv county degree-day normals, 1991–2020 , Annual heating and cooling degree days, base 65°F, summed by HYRE from the twelve published monthly normals for the 1991-2020 period across 3,107 counties in 48 states. Files dated August 6, 2026. No interpolation, smoothing or re-basing. Retrieved September 5, 2026.
EIA Residential Energy Consumption Survey 2020 , Public use microdata file v7. 18,496 responding households, weighted to represent 123.53 million occupied primary housing units. Standard errors from the 60 replicate weights supplied with the file. Retrieved September 4, 2026.
EIA Form EIA-861, Sales to Ultimate Customers , Average residential electricity price by state, derived as revenue over sales across the reporting parts EIA files separately for restructured markets. Validated against EIA’s own published state price series across 357 state-years to within 0.005 cents per kilowatt-hour; the 2024 national figure reproduces EIA’s published 16.48 cents exactly. Retrieved September 4, 2026.
EIA Natural Gas Navigator, series N3010 , Price of natural gas delivered to residential consumers, dollars per thousand cubic feet, annual, by state. Retrieved September 4, 2026.
EIA Residential Energy Consumption Survey 2020, Table CE3.1 , Annual household site end-use consumption in the United States — totals and averages, 2020. Released June 2023, revised March 2024. Averages are million Btu per household using the end use, across 123.53 million housing units. Retrieved September 5, 2026.
Washington State Register WSR 23-21-105 — proposed changes to the 2021 Washington State Energy Code , Filed by the Washington State Building Code Council on October 18, 2023. Addresses EPCA preemption following California Restaurant Association v. City of Berkeley, deleting section R403.13 (heat pump space heating) and section R403.5.7 (heat pump water heating) from chapter 51-11R WAC, and re-baselining the Table R406 credits from a heat pump to a combustion heating system. Retrieved September 6, 2026.
Washington State Building Code Council — 2021 Washington State Energy Code, Residential , WAC 51-11R (Residential) 2nd Edition, 2nd Printing (Sept 2024). Effective March 15, 2024. “Based on the 2021 IECC.” Retrieved September 6, 2026.
US DOE Building Energy Codes Program — Washington status , Records the 2021 Washington State Energy Code for residential and commercial buildings, adopted November 4, 2022, effective March 15, 2024. Retrieved September 6, 2026.
NOAA Climate.gov — record heat across the Pacific Northwest, June 2021 , NOAA’s account of the late-June 2021 heat: Seattle “108 on June 28 after reaching 104 the day prior”, and “in the previous 126 years, Seattle had only hit 100 degrees three times. It reached that mark in three consecutive days in June!” Retrieved September 6, 2026.
Washington State Department of Labor & Industries — Contractor License Data , Washington State Department of Labor & Industries — Contractor License Data (General), via the Washington Open Data Portal Retrieved August 29, 2026.
Energy Efficient Home Improvement Credit (Internal Revenue Code §25C) , IRS: "The credit is allowed for qualifying property placed in service on or after Jan. 1, 2023, and before December 31, 2025." Retrieved September 5, 2026.

Compare Washington HVAC quotes on the lines that are actually local

Ask for the Table R406 credit sheet, the rated capacity at your design temperature, and who is doing the electrical work under which L&I license. The quote comparison worksheet lines three Washington bids up on credits, low-temperature capacity and license.

Get HVAC Options Quote comparison worksheet

HyreHVAC does not install, service or sell HVAC equipment, holds no dataset of quotes or invoices, and takes no payment for placement or a favorable mention.

Contractor counts on this page are records our own store verified against the named state register on the date given — they are not a count of every licensed contractor in the state, and they are not a recommendation of any company.