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Regulatory Landscape Presents New Challenges and Complexities

AndrePatenaude_Blog_Image Andre Patenaude | Director, Food Retail Marketing & Growth Strategy, Cold Chain

Emerson Commercial & Residential Solutions

Significant regulatory changes — including some just a few weeks old — were summarized at our latest E360 Forum, which was held in Chicago on October 5. Read the highlights below or watch the full video for complete details.

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During the next four years, the industry will face no fewer than 10 Environmental Protection Agency (EPA) Significant New Alternatives Policy (SNAP) rulings on refrigerants — as low as 700 GWP for AC chillers and 150 GWP for other applications. These have been coming for a while, but in the last three months there have been three major developments:

  1. The Department of Energy (DOE) finally confirmed that energy standards will be established for all walk-ins. These appeared in the federal register on July 10 and will become effective in 2020.
  2. The EPA approved R-452A for use in remote units/walk-in applications.
  3. Most significantly, on August 8, the 2015 SNAP ruling (rule 20), which delisted certain HFCs such as
    R-404A, was struck down by the U.S. Court of Appeals DC Circuit. If that ruling stands, refrigerants like
    R-404A and R-507 could be back on the table. However, the court immediately issued an order withholding the decision. So, SNAP is still in place — for now.

The last matter is likely to be tied up in the Courts for some time, but some states like California may create additional regulations to fill the void. Yet, no matter how it’s resolved, there appears to be enough global momentum to stay the course on phasing down HFCs.

The most common industry strategy has been the deployment of natural alternatives acceptable under SNAP, including R-290 (propane), R-744 (carbon dioxide) and R-717 (ammonia). While a lot of progress has been made, a significant part of the market remains uncomfortable with the potential flammability of propane, the pressure of CO2 and the potential toxicity of ammonia.

This has sparked a growing demand for the lowest-GWP, non-flammable (A1) refrigerants available. The question now is: How far do we need to go to find a middle ground between natural and A1 options? We’re interested in discussing that with you.

About half of our customers have basic compliance plans in place, but as of three months ago, around 80 percent still weren’t ready. From products to plants to people, most anticipate costly and time-consuming changes to meet new regulations.

The magnitude of the changes will require a holistic look at the system level — and perhaps even the ecosystem level. In the next five years, our research suggests innovation will need to look very different in six key areas:

  • Serviceable — easy to maintain for new and experienced technicians
  • Simple — less complexity
  • Sustainable — addressing energy, environment and economics
  • Safe — customer safety is paramount
  • Stable — reliable and efficient
  • Smart — controls are easy and intuitive

Stronger collaboration can help all of us meet these challenges. To aid this effort, we’ve created The Helix Innovation Center to advance research and education in heating, ventilation, air conditioning and refrigeration. We encourage your input and collaboration as we strive to meet these goals.

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