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Refrigerant Regulations: 2020 Update

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

Emerson Commercial & Residential Solutions

For several years, the regulatory landscape regarding the governance of refrigerants has been constantly shifting. Already in 2020, we’ve seen developments, both on the state and federal levels in the U.S., which will have significant impacts on the commercial refrigeration and air conditioning sectors for years to come. We recently published an E360 article that lays out these regulatory developments in detail; this blog is a condensed summary of its key points.

Global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP) and replacing them with lower-GWP options. But while emerging refrigerants — such as natural alternatives and new synthetic blends of HFCs and hydrofluoroolefins (HFOs) — offer environmental improvements, they are not without their operational caveats. Making the transition to these new alternatives will impact refrigeration architectures and raise concerns about performance and safety.

This dynamic combination of factors creates a complex regulatory mix that industry stakeholders have been actively working to resolve. To better understand the full context, we’ve summarized the major regulatory developments in the U.S. and abroad.

Update on EPA SNAP Rules 20 and 21

In 2017, the U.S. District Court of Appeals for the D.C. Circuit ruled to vacate the Environmental Protection Agency’s (EPA) Significant New Alternative Policy (SNAP) Rule 20 — ruling that the EPA did not have authority to require those who had already moved out of ozone depleting substances (ODS) to phase down to lower-GWP HFCs under its Clean Air Act (CAA). Subsequently, the EPA published a “Notification of Guidance,” stating that it would not enforce any of the HFC restrictions set forth in SNAP Rules 20 and 21 when drafting future regulations.

The Natural Resources Defense Council (NRDC) filed a lawsuit claiming that the 2018 Guidance was overly broad because it did not distinguish between ODS and HFC replacements, and that the EPA had not followed proper public notice-and-comment procedures to seek stakeholder input.

On April 7, 2020, the Court of Appeals granted the NRDC’s petition, stating that the EPA guidance was procedurally inappropriate. The court agreed that the initial 2017 decision required only a partial vacatur — not entirely eliminating the requirements SNAP Rules 20 and 21.

It’s important to remember that the industry had already made great strides toward meeting the mandates of SNAP Rule 20 after its passing in 2015, but these ongoing legal entanglements have left the U.S. without a clear path forward in terms of a unified refrigerant strategy. While the majority of the industry still supports the move toward a more sustainable and environmentally friendly future, court rulings around SNAP Rules 20 and 21 have created many questions about what the path forward will look like.

HFCs excluded from refrigerant management requirements

In response to the 2017 Court of Appeals ruling, the EPA also has rolled back other HFC-related regulations. Specifically, it excludes HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA. Other beneficial provisions of Section 608 — including the certified technician program and the refrigerant recovery and reclamation rules — are still in effect.

California continues to set the pace

The passing of California Senate Bill 1383 (the Super Pollutant Reduction Act) in 2016 called for Californians to reduce F-gas emissions (including HFCs) by 40 percent by 2030. Since then, the California Air Resources Board (CARB) had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. The subsequent passing of California Senate Bill 1013 (the California Cooling Act) in 2018 mandated the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017; the law is currently in effect.

To meet HFC reductions of 40 percent by 2030, CARB continues to hold public workshops and invited industry stakeholders to comment on the details of its second phase of proposed rulemaking, which currently states:

 

  • Refrigerants with a GWP greater than or equal to 150 will not be allowed in new stationary refrigeration systems charged with more than 50 pounds, effective Jan. 1, 2022.
  • Existing food retail facilities with refrigeration systems charged with more than 50 pounds must collectively meet a 1,400 GWP average or 55 percent greenhouse gas emission potential (GHGp) reduction over 2018 levels by 2030.
  • Refrigerants with a GWP greater than or equal to 750 will not be allowed in new stationary air conditioning equipment, effective Jan. 1, 2023.
  • Refrigerants with a GWP greater than or equal to 750 will not be allowed in chillers (including process chillers) greater than -15 °F and ice rinks, effective Jan. 1, 2024.
  • Refrigerants with a GWP greater than or equal to 2,200 will not be allowed in new chillers ranging from
    -15 °F through -58 °F, effective Jan. 1, 2024.

 

CARB is planning to finalize these rulemaking proposals this summer and is still seeking industry input.

More states join U.S. Climate Alliance

In 2017, a coalition of 16 states and Puerto Rico emerged to form the U.S. Climate Alliance, with a shared commitment of reducing short-lived climate pollutants (SLCPs) and HFCs. Since then, the Alliance has grown to 25 members — comprising more than 55 percent of the U.S. population and an $11.7 trillion economy. Several states have announced plans to follow California’s lead on HFC phase-downs.

Refrigerant safety standards and codes under review

Meeting the targeted emissions reductions in California likely will require the use of low-GWP refrigerants. But many of these low-GWP, HFO refrigerants are classified as A2L, or mildly flammable. The natural A3 refrigerant R-290 (propane) also is becoming more widely used in low-charge, self-contained commercial refrigeration applications. Currently, national and global governing agencies are evaluating the standards that establish allowable charge limits and the safe use of these A2L and A3 refrigerants.

Per a 2019 update from the International Electrotechnical Commission (IEC) to IEC60335-2-89, A2L and A3 charge limits have been increased for commercial refrigeration systems:

  • A2Ls — from 150g to 1.2kg
  • A3s — 500g for factory-sealed systems, and will remain at 150g for split systems

Similar efforts to raise A2L and A3 charge limits also are taking place in the U.S. The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and Underwriters Laboratory (UL) are working to establish new charge limits and mitigations for the use of A2L and A3 refrigerants with support from industry and various stakeholders.

Once adopted, these standards will serve as the bases for codes that govern building, fire and other local authorities having jurisdiction (AHJ). It’s important to remember that building codes vary from state to state; thus, the adoption of flammable refrigerants ultimately may take place on local levels and may take years to accomplish.

Kigali Amendment not ratified in U.S.

In 2016, 197 member countries of the Montreal Protocol met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. The Kigali Amendment required ratification from at least 20 countries to take effect. To date, 92 countries (including many countries in the E.U., but not including the U.S.) have ratified it; it has been in effect for participating countries since Jan. 1, 2019.

According to industry estimates, ratifying the Kigali Amendment could create up to 33,000 jobs in the manufacturing sector by 2027 and have a positive impact on the U.S. economy. For these reasons, industry advocates are in favor of ratification and have demonstrated this through letters of support to both the Senate and the White House.

New HFC bills introduced in the U.S.

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.

Industry appeals for consistency

Industry advocates, including the Air-conditioning Heating and Refrigeration Institute (AHRI) and the NRDC, have appealed for states to be consistent in their approach to adopting CARB’s rules. Establishing a unified framework for future refrigerant regulations would provide the certainty needed to help the industry and regulatory bodies move forward with a consistent approach. At Emerson, we’re actively involved in helping the HVACR industry evaluate and steer these proposals — in industry committees, stakeholder meetings and public comments.

 

Court of Appeals Ruling Questions the Elimination of EPA SNAP

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

Emerson Commercial & Residential Solutions

On April 7, the U.S. District Court of Appeals for the District of Columbia ruled that the Environmental Protection Agency (EPA) had improperly suspended the limits on the use of hydrofluorocarbon (HFC) refrigerants in its 2018 guidance. ACHR The NEWS interviewed Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, and me to discuss the implications of this ruling and what it means to our industry. View the full article here or read a summary of its contents in this blog.

To put this latest development into context, we must go back to 2017, when the Court of Appeals ruled to vacate the EPA’s Significant New Alternative Policy (SNAP) Rule 20. The ruling was based on the assertion that the EPA did not have the authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS). The EPA had interpreted the Court’s 2017 decision by suspending the requirements of SNAP Rule 20, which then allowed current users of ODS to freely switch to HFCs.

Despite widespread business and HVACR industry objections to overturn the Court of Appeal’s decision, the Supreme Court declined to hear the HFC case in 2018. Vacating EPA SNAP 20 halted years of regulatory progress in one of the world’s leading governing bodies on HFCs — and left the U.S. without a clear path forward in terms of a unified refrigerant strategy.

The April 7 Court of Appeals ruling was in response to a lawsuit introduced by the National Resources Defense Council (NRDC) and a coalition of states led by New York. The court ruled on both procedure and substance of the EPA’s 2018 guidance, stating:

  • The decision was made without going through proper public notice-and-comment procedures.
  • The agency had improperly suspended the limits on the use of HFC refrigerants.

As a result, the Court of Appeals requested that the EPA restore its prohibition on transitioning from refrigerants with ozone depletion potential to HFCs with a higher global warming potential. In essence, the EPA did not need to completely eliminate the requirements of SNAP Rules 20 and 21.

Implications to commercial refrigeration equipment

If you are a supermarket owner or operator wondering which refrigerants you will be permitted to use moving forward, we suggest referring to the original SNAP Rules 20 and 21 if you are considering replacing refrigeration equipment that still uses an ODS refrigerant such as R-22.

As I stated in the article: “If you’ve got an existing piece of equipment that’s running on R-22, you can continue to use it and service it with reclaimed R-22. That has not been taken away. If you have an R-22 system, and you’re looking to replace it with a newer system, I would look at the SNAP 20/21 list and find someone who can provide a refrigerant that’s on that list.” It’s also important to remember that states such as California have already adopted SNAP Rules 20 and 21, so choosing new equipment that is compatible with SNAP rules is still required in those states.

As Jennifer pointed out in the article, this Court of Appeals ruling does not clear up the regulatory uncertainty that’s prevalent in our industry.

“The exact impact of the decision is unclear, and further guidance from the EPA is necessary. This ruling also underscores the need for congressional action on federally regulating HFCs to deliver the certainty the industry needs,” she said.

Newly proposed legislation, such as the American Innovations and Manufacturing (AIM) Act, would give clear authority to the EPA on what they can and cannot do with respect to the HFC refrigerant phase-down. As I stated in the article, “We need the AIM Act now more than ever.”

Rest assured that as we gain more clarity on this quickly changing regulatory climate, we will continue to keep the industry informed of the latest developments.

Emerson Celebrates and Sponsors World Refrigeration Day 2020

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

Emerson Commercial & Residential Solutions

June 26 is the second annual celebration of World Refrigeration Day. The event, which memorializes the birth date (June 26) of Lord Kelvin for whom the Absolute temperature scale is named, was started last year to raise visibility, awareness and understanding of the significant role that the refrigeration, air-conditioning and heat pump (RACP) sector plays in modern life and society.

Emerson Celebrates and Sponsors World Refrigeration Day 2020

This year’s theme, “Cold Chain 4 Life,” aims to make the public, policy makers and end-users aware of technology, food waste/loss, human health and comfort, environment and energy considerations associated with the cold chain. The campaign strives to motivate adoption of best practices to minimize food waste/loss in the supply chain, stimulate wise technology selections and enhance operations to minimize leakage of refrigerants and maximize energy efficiency.

As part of its celebration, we will host a live trivia event on our Copeland™ Facebook page at 2 p.m. EDT / 11 a.m. PDT that day (June 26). The trivia questions will be related to the commercial refrigeration and air conditioning industry, Emerson company history and product knowledge. Participants who answer correctly will have the chance to win Emerson items, including genuine Copeland brand t-shirts and a $100 Amazon.com® gift card for the grand-prize winner.

On World Refrigeration Day and every day, we are committed to advancing innovation by actively engaging with industry leaders to address the many challenges the industry is facing — including evolving environment-related regulations; climate change awareness; human health and comfort; the growing ubiquity of digital technologies; food safety and quality needs; and the never-ending energy efficiency and operating cost concerns.

By actively participating in organizations such as Air-Conditioning, Heating & Refrigeration Institute (AHRI), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), Global Food Cold Chain Council (GFCCC), European Partnership for Energy and the Environment (EPEE), and Council for Harmonization of Electrotechnical Standards of the Nations of Americas (CANENA), we play a strategic role in understanding and interpreting the ever-changing landscape of international, national and state-level regulations. Most recently, our experts have been supporting initiatives to explore more globally friendly refrigerants through participation in the AHRI Safe Refrigerant Transition Task Force established in April 2019. The task force was established with the goal of evaluating and in turn enabling safe and reliable use of low-GWP refrigerants. Whether it’s energy efficiency or the transition to lower GWP refrigerants, we are uniquely positioned to help guide and support our customers in overcoming these complexities, not only on World Refrigeration Day, but all year long.

For more information on World Refrigeration Day, visit www.worldrefrigerationday.org.

[New E360 Webinar] Future Refrigeration Architectures for Meeting Refrigerant Regulations

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

Emerson Commercial & Residential Solutions

Supermarket refrigeration architectures are rapidly evolving in the face of food retail market pressures and a dynamic regulatory environment. In our next E60 Webinar, which will take place on Tuesday, May 5 at 2 p.m. EDT/11 a.m. PDT, we’ll examine the forces behind these changes and explore emerging architectures that utilize alternative refrigerants.

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Throughout the food retail industry, supermarket owners and operators are making the transition to refrigerants with lower global warming potential (GWP). Whether you operate in a state that has a legal mandate or are seeking to meet corporate sustainability objectives, many owners, operators and contractors are exploring their current and future refrigeration options. But selecting an architecture goes well beyond sustainability considerations. Stakeholders also must evaluate a variety of economic and operational factors, including first investment, maintenance requirements and lifecycle costs.

The refrigerant transition also is shifting the way we think about system architectures. To reduce refrigerant leaks and system charges, equipment manufacturers are evaluating a variety of approaches that represent more flexible alternatives to traditional centralized direct expansion systems. In our next E360 Webinar, Future Refrigeration Architectures for Meeting Refrigerant Regulations, I will be joined by Diego Marafon, Emerson’s refrigeration scroll product manager, to discuss some of these emerging options. Join us as we explore the latest decentralized and distributed architectures that utilize low-GWP refrigerants.

Attendees will learn about:

  • How refrigerant regulations are impacting operators by state and region
  • The many factors influencing system selection, from facility size and first cost to serviceability and safety
  • Emerging decentralized and distributed architectures and their wide range of applications
  • How a modular approach to system design enables speed and flexibility

 

Register now for this timely and free webinar.

Supermarket refrigeration architectures are rapidly evolving in the face of food retail market pressures and a dynamic regulatory environment. In our next E60 Webinar, which will take place on Tuesday, May 5 at 2 p.m. EDT/11 a.m. PDT, we’ll examine the forces behind these changes and explore emerging architectures that utilize alternative refrigerants.

Throughout the food retail industry, supermarket owners and operators are making the transition to refrigerants with lower global warming potential (GWP). Whether you operate in a state that has a legal mandate or are seeking to meet corporate sustainability objectives, many owners, operators and contractors are exploring their current and future refrigeration options. But selecting an architecture goes well beyond sustainability considerations. Stakeholders also must evaluate a variety of economic and operational factors, including first investment, maintenance requirements and lifecycle costs.

The refrigerant transition also is shifting the way we think about system architectures. To reduce refrigerant leaks and system charges, equipment manufacturers are evaluating a variety of approaches that represent more flexible alternatives to traditional centralized direct expansion systems. In our next E360 Webinar, Future Refrigeration Architectures for Meeting Refrigerant Regulations, I will be joined by Diego Marafon, Emerson’s refrigeration scroll product manager, to discuss some of these emerging options. Join us as we explore the latest decentralized and distributed architectures that utilize low-GWP refrigerants.

Attendees will learn about:

  • How refrigerant regulations are impacting operators by state and region
  • The many factors influencing system selection, from facility size and first cost to serviceability and safety
  • Emerging decentralized and distributed architectures and their wide range of applications
  • How a modular approach to system design enables speed and flexibility

Register now for this timely and free webinar.

Refrigerant Regulations Update and Industry Trends

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

In the United States, the regulations governing the use of refrigerants in commercial refrigeration and AC applications remain in a state of flux. Our next E360 Webinar will take place on Tuesday, March 31 at 2 p.m. EDT/11 a.m. PDT and provide an update on the latest regulatory developments at the state and federal levels.

Refrigerant Regulations Update and Industry TrendsThe unpredictable nature of environmental regulations in the U.S. continues to be a source of great uncertainty in today’s commercial refrigeration and AC industries. While many countries around the world are following international guidelines set forth by the Kigali Amendment to the Montreal Protocol and the Paris Agreement, the U.S. has rolled back its former federal refrigerant regulations and has yet to participate in these multi-national climate measures.

However, at the state level domestically, things are evolving quickly. The California Air Resources Board (CARB) is moving forward with its stated 2030 deadline of reducing hydrofluorocarbon (HFC) emissions by 40 percent from the state’s 2013 baseline levels. While CARB is currently drafting specific proposals on how to achieve this goal, it’s clear that supermarkets and cold storage operators will soon need to accelerate their transition to new refrigerant alternatives that offer much lower global warming potential (GWP).

California is forging a path to long-term environmental sustainability that many other states are following. Currently, 25 states and provinces have joined the U.S. Climate Alliance — which represents 55 percent of the national population — and committed their leadership on climate change initiatives, including the reduction of HFCs. But with 25 governing bodies working toward similar goals, we’re already seeing the possibility of divergent regulatory approaches that would make it increasingly difficult for our industry to manage.

Meanwhile, both the House of Representatives and the Senate have introduced new bills that would give the Environmental Protection Agency’s (EPA) authority to regulate HFCs. With this dynamic mix of activities and new developments happening almost every week, it’s becoming more important than ever to stay informed. Our next E360 Webinar is dedicated to making sense of this turbulent regulatory climate and will provide you with guidance on how to prepare for the future.

This timely and informative E360 Webinar will take place on Tuesday, March 31 at 2 p.m. EDT/11 a.m. PDT. It will be hosted by Emerson’s leading experts on refrigerant regulations: Rajan Rajendran, vice president, systems innovation center and sustainability; and Jennifer Butsch, manager, regulatory affairs. Attendees will learn:

  • How CARB is building upon its Significant New Alternatives Policy (SNAP) ruling foundation with newly proposed HFC refrigerant phase-down efforts
  • How some U.S. Climate Alliance states are adopting the EPA’s SNAP Rules 20 and 21 on their own individual timelines
  • Status of the standards governing charge limits and safe use of A2L and A3 refrigerants, including the potential impacts on building codes
  • Availability of new low-GWP refrigerants
  • Update on the new federal HFC regulations introduced by the Senate and the House
  • New and emerging industry trends to watch closely

Register now for this informative and free webinar.

 

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