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Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

RajanRajendran2 Rajan Rajendran | V.P., System Innovation Center and Sustainability

Emerson Commercial & Residential Solutions

As the phasedown of hydrofluorocarbon (HFC) refrigerants continues globally, the United States currently lacks a federal mandate with which to govern their use in both AC and commercial refrigeration. Instead, several state-led initiatives and proposals are driving sustainability measures now in the U.S. At a recent E360 breakfast at the AHR event, I co-hosted an industry discussion with Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, on the latest developments in refrigerant regulations and rulemaking.

Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

Gauging from the level of interest from those who attended, the U.S. regulatory climate is an important topic for industry stakeholders. With dynamic developments taking place along state and federal lines, it’s more important than ever to stay informed and engage with any efforts to steer these evolving regulations in the direction of regulatory uniformity.

From Kigali to the EPA to the U.S. Climate Alliance

The Kigali Amendment to the Montreal Protocol remains the global force behind the phasedown of HFCs. Currently, more than 90 countries — not including the U.S. — have ratified this international treaty and plan to follow its recommendations to reduce the use of HFC refrigerants with high global warming potential (GWP). In the U.S., the rollback of the Environmental Protection Agency’s (EPA’s) Significant New Alternative Policy (SNAP) Rules 20 and 21 has deregulated the use of these HFCs from a federal perspective.

Even though SNAP Rules 20 and 21 have been vacated, today they serve as the regulatory framework for a growing number of states in the U.S. Climate Alliance — which currently is comprised of 25 member states representing 55 percent of the national population and $11.7 trillion in economic contributions. Among these, California, Washington, Vermont and New Jersey legally have adopted SNAP Rules 20 and 21, with five additional states proposing similar measures. Their charter is committed to “implementing policies that advance the goals of the Paris Agreement, aiming to reduce greenhouse gas emissions by at least 26-28 percent below 2005 levels by 2025.”

While these new states share a common regulatory framework, enforcement dates of refrigerant phasedowns per application vary from state to state. Although the industry recognizes the states’ sovereignty to take environmental action, we also urge consistency in approach and enforcement to reduce complexity. Imagine the challenge for contractors covering a multi-state territory where each state has different enforcement dates. This is the type of complexity that we should strive to avoid as an industry.

All eyes on CARB proposals

Not only was California the first state to adopt SNAP Rules 20 and 21 — which have already taken effect — its California Air Resources Board (CARB) has mandated 40 percent HFC emissions reductions from the state’s 2013 baseline levels by 2030. To date, California has taken the most aggressive environmental stance of any of the U.S. Climate Alliance states, and in many ways, is creating the path forward for other states to follow. This is precisely why it’s so important for industry stakeholders in all states to pay close attention to active proposals and engage in any opportunities to comment on the nature of proposed rulemaking.

Currently, the following CARB proposals for AC and chiller applications are open for additional industry input and comments:

AC

  • 750 GWP limit for new residential and non-residential, air-conditioning equipment, effective Jan. 1, 2023

Chillers and process chillers

  • 750 GWP limit for new chillers designed for a minimum evaporator temperature > -15 °F, effective Jan. 1, 2024
  • 2,200 GWP limit for new process chillers designed for a minimum evaporator temperature between -15 °F and -58 °F, effective Jan. 1, 2024

For the commercial refrigeration sector, CARB’s proposals have evolved to consider the challenges facing operators of existing food retail facilities by introducing the option of meeting a company-wide weighted average GWP or achieving a 55 percent reduction in Greenhouse Gas Potential (GHGp).

New commercial refrigeration

  • 150 GWP limit for new, non-residential refrigeration equipment containing more than 50 pounds of refrigerant, effective Jan. 1, 2022

Companies owning or operating 20 or more retail food facilities

  • Attain a company-wide weighted average of 2,500 GWP or achieve a 25 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2026
  • Attain a company-wide weighted average of 1,400 GWP or achieve a 55 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2030

Companies owning or operating fewer than 20 retail food facilities

  • Attain a company-wide weighted average of 1,400 GWP or achieve a 55 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2030

CARB has asked the industry for input and comments on these proposals, which are expected to be finalized later this year. It’s critically important to review the details, definitions and exceptions to these proposed rules in order to gain a clear understanding of how they might impact you and provide informed feedback to help steer the rulemaking process.

New federal HFC bills on the horizon

With the EPA no longer authorized to regulate HFC use, the U.S. Senate and the House of Representatives have each penned new bills that would put the EPA in alignment with the Kigali Amendment and restore the EPA’s authority to phase down the production and consumption of HFCs over a 15-year period.

  • Senate: American Innovation and Manufacturing Act of 2019 (S2754)
  • House: American Innovation Leadership Act of 2020 (HR5544)

While the future and timing of these new bills are uncertain, they offer the potential to re-establish a federal standard for HFC management, including guidelines for servicing, recovery, recycling and reclamation. In the best-case scenario, these could provide the industry guidance that individual states need to move forward with a unified approach, remove the legislative burden from the states, and reduce regulatory complexity.

Download our full AHR breakfast presentation to learn more about proposed refrigerant rulemaking and how to prepare for regulations in your region.

Montreal Protocol Members Declare Commitment to Reduce Food Loss and Waste

RajanRajendran2 Rajan Rajendran | V.P., System Innovation Center and Sustainability

Emerson Commercial & Residential Solutions

In November, the 31st Meeting of the Parties to the Montreal Protocol convened in Rome to discuss progress in their ongoing efforts to protect the Earth against ozone depletion and global warming. Among the new topics introduced by member nations was the need to implement sustainable and efficient solutions in the refrigeration and air-conditioning sector — not only to meet future cooling demand but also to include cold chain initiatives for food preservation.

Montreal Protocol Members Declare Commitment to Reduce Food Loss and Waste

For more than three decades, the Montreal Protocol has introduced measures to reduce the harmful environmental impacts of cooling technologies — first with a mandate to phase out ozone-depleting substances such as chlorofluorocarbons (CFCs), and most recently with the Kigali Amendment, which targets a phase-down of hydrofluorocarbons (HFCs). As these efforts have experienced wide adoption by its global member nations, the Montreal Protocol’s stakeholders are now vowing to take a closer look at additional cooling-related climate issues, such as reducing food waste and creating a more sustainable cold chain.

At the November meeting, key stakeholders discussed the Montreal Protocol’s global responsibilities to continue its leadership in climate matters and extend its efforts into reducing global food loss and waste. Participants stressed the urgency for countries to work together to find new solutions to address world hunger — noting that it would be possible to feed the entire world with current food production levels if waste was eliminated.

Participants also discussed other far-reaching benefits of these efforts toward creating more sustainable cold chains, such as: price stabilization; improved food security; enhanced profitability; more secure livelihoods; social and economic development gains; fair and just sustainability transitions; achieving sustainable development goals; continuing research, development and innovation; synergistic action; and restoration of degraded lands.

Introducing the Rome Declaration

At the November Meeting of the Parties to the Montreal Protocol, members were invited to support the Rome Declaration on the Contribution of the Montreal Protocol to Food Loss Reduction through Sustainable Cold Chain Management initiative. Currently, the Rome Declaration has been signed by ministers of 76 countries and is open for additional member signatures until the start of the next Meeting of the Parties, to be held next November.

The Rome Declaration calls for both national action and international cooperation to promote sustainable cold chain development, including the use of environmentally friendly refrigeration to reduce food loss. It states that achieving its objectives will require cooperation among governments, the Protocol’s institutions, United Nations (UN) specialized agencies, existing private and public initiatives, and all relevant stakeholders to exchange knowledge and promote innovation.

Among the Rome Declaration’s key objectives is to provide access to energy-efficient, sustainable refrigeration technologies in developing nations — particularly those that follow the Montreal Protocol’s guidance on refrigerants — thereby helping them contribute to the reduction of food loss and waste.

Aligning with Emerson’s cold chain capabilities

We won’t know for some time whether the Rome Declaration will become an internationally agreed upon mandate. But like the previous efforts of the Montreal Protocol to phase down harmful substances used in cooling devices, the Rome Declaration is an opportunity to leverage Emerson’s efforts in providing sustainable and energy-efficient solutions — not only in the refrigeration and air-conditioning sectors, but throughout the global cold chain.

From compressors and refrigeration system technologies to temperature monitoring and tracking devices to connected electronic controllers and facility management systems, we’re committed to helping cold chain stakeholders achieve temperature certainty and maximize energy efficiencies in the most environmentally responsible means possible.

 

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