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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.

[Webinar Recap] Digital X-Line Enhances Proven Condensing Unit Platform

Julie Havenar | Product Manager – Condensing Units
Emerson Commercial & Residential Solutions

For decades, fixed-capacity outdoor condensing units (OCUs) have been a popular architecture choice for foodservice and food retail applications — providing refrigeration for walk-in coolers, display cases and food preparation tables. With recent advances in digital compression technology to enable variable-capacity modulation, modern condensing units offer an even more compelling alternative to traditional centralized architectures. In our recent webinar, I discussed the many benefits of taking a decentralized approach to refrigeration, specifically by using Emerson’s Copeland™ Digital Outdoor Refrigeration Unit, X-Line series.

[Webinar Recap] Digital X-Line Enhances Proven Condensing Unit Platform

First, it’s important to review the many reasons why fixed-capacity condensing units have experienced wide industry adoption. Their simple architecture — with one dedicated condensing unit per evaporator (or refrigeration fixture) — makes them extremely easy to implement and a flexible option for load expansion or facility retrofits. By locating the condensing units outside the store, this approach also removes heat and mechanical sound from the shopping environment. In addition, their air-cooled design removes the need for water loops while eliminating excess cost and unit cooling.

But there is always room for improvement. So, we reached out to our customer base to gather feedback about their pain points when using these fixed-capacity OCUs. Common challenges included: the use of mechanical controls; lack of remote communications, onboard diagnostics and system protections; limited mounting/installation options; single speed (on/off) fan cycling; single unit required for every load with each unit individually wired.

Overcoming these challenges became the basis of our Copeland™ Outdoor Refrigeration Unit, X-Line series launched a few years ago. X-Line offered the following improvements:

  • Slim, lightweight profile — can be wall-mounted or mounted on rails
  • Quiet — can be located near entrances, patios or residential areas
  • Energy efficient — Copeland scroll compression, variable-speed fan motor control, large condenser coils and enhanced vapor injection (on low-temp, fixed-speed only)
  • Connectivity — communicates with facility management systems, such as Emerson’s XWEB, Site Supervisor and E2 platforms
  • Protection — electronic controls enhance reliability; on-board diagnostics enable fast setup, troubleshooting and alert codes
  • AWEF-compliant — meeting DOE (Department of Energy) regulations

Digital modulation addresses additional customer challenges

With the introduction of the digital X-Line, Emerson was able to address another key customer challenge — requiring a separate condensing unit for each refrigeration load — while enabling variable-capacity modulation from 100% to 20%. The digital X-Line utilizes multiplexing technology to connect multiple fixtures to one condensing unit and detects the required refrigeration demand from each fixture. So, if the digital X-Line were servicing multiple evaporators and only one was calling for cooling, the digital X-Line can run at less than 100% capacity and match the exact load capacity requirement at that moment. This means that operators will need fewer condensing units to meet their refrigeration demands — potentially reducing the equipment footprint.

Other installation benefits include:

  • Simple and quick commissioning — requires only three setpoints: refrigerant, time clock and suction pressure
  • Reduced refrigerant charge and line sets — up to 50% reduction with the option to utilize lower-GWP alternatives
  • Reduced costly call-backs — advanced diagnostics help contractors set it up right the first time

From an operational standpoint, the digital X-Line is designed to deliver continuous performance improvements that impact food quality/safety, energy efficiency and servicing, such as:

  • Tight temperature precision — digital, variable-capacity modulation enables precise control over case temperatures to maximize food quality and safety
  • Energy efficiency gains — larger condenser coils, electronic controls and digital compression (which reduce large amp draws from excessive starts/stop) deliver substantial energy efficiency savings
  • Advanced diagnostics and protection — onboard controls alert end users of faults and KPIs, simplify troubleshooting and provide compressor protection

It’s also important to point out that the digital X-Line maintains the platform’s ultra-quiet operation, which allows the units to be installed nearly anywhere without disrupting customers or neighbors.

Whether you operate a convenience store, restaurant, supermarket or cold storage facility, the digital X-Line provides operators with a state-of-the-art OCU solution that’s ideal for meeting today’s challenging refrigeration requirements. To learn more about the benefits of the digital X-Line in these applications, view this webinar in its entirety.

Preparing for the Future of Alternative Refrigerants

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

Emerson Commercial & Residential Solutions

 

Regulations governing the use of refrigerants in commercial refrigeration remain in a state of flux. While the United States currently lacks a federal mandate for phasing down hydrofluorocarbon (HFC) emissions, many states are already vowing to adopt their own HFC phase-down initiatives. In a new article in RSES Journal, I highlight several proven sustainable refrigeration strategies that operators should begin evaluating now as they prepare for a future that will be fueled by systems that utilize refrigerants with lower global warming potential (GWP). Read the article here.

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It’s clear that the future favors more environmentally friendly refrigeration systems. But the lower-GWP refrigerants and emerging architectures that comprise these systems are up for debate in the United States, where state-led efforts to curb climate change could result in a patchwork of environmental regulations.

The good news for owners and operators is that, even absent federal guidance, component manufacturers, OEMs, contractors and end users are leading the charge. For more than a decade, industry stakeholders have been developing and fine-tuning lower-GWP refrigerants and corresponding technologies to satisfy a range of applications, store formats and corporate sustainability goals.

The resulting proliferation of sustainable refrigeration systems is providing operators with more options than ever before. But as the one-size-fits-all solutions of the past give way to a broader array of strategies, operators need to become experts on alternative refrigerant technologies and architectures — all while trying to predict where future environmental regulations will land. While this may sound like a daunting task, it can be made easier by building a baseline understanding of current and emerging systems.

An expanding set of sustainable refrigeration strategies

Whether motivated by potential regulatory changes or corporate sustainability goals (or both), operators have no shortage of lower-GWP refrigerant systems from which to choose. Proven, viable alternatives to HFC-based systems already on the market include:

  • Lower-GWP A1s (HFO/HFC blends): By blending hyrdrofluoroolefins (HFOs) with HFCs, refrigerant manufacturers have created a new generation of lower-GWP A1 alternatives. These refrigerants do not satisfy the very low-GWP levels of many global HFC regulations, but they do allow for a gradual transition to lower-GWP refrigerants. Refrigeration architectures that use A1 refrigerants include macro-distributed (large) integrated cases, micro-booster (distributed) and small-charge distributed cases.
  • A2L HFO blends: New synthetic HFO blends offer widespread applicability within commercial refrigeration for operators seeking lower-GWP alternatives. U.S. safety codes and standards are still catching up to their use, but many operators anticipate A2L blends will emerge within the next several years. Both macro-distributed and micro-booster architectures that use A1 refrigerants can be used with some A2L blends, enabling operators to maximize their investment as they adopt lower-GWP alternatives.
  • Propane (R-290): This natural refrigerant is energy-efficient and has a very low GWP of 3. Because it’s classified as an A3 (flammable) refrigerant, U.S. building codes currently limit its use to small-charge applications — and that may require more compressors than other approaches. R-290 can be paired with micro-distributed, R-290 integrated cases, which allow for flexibility in store layouts and use 90% less refrigerant than centralized systems.
  • CO2 (R-744): A proven alternative in European and North American applications, CO2 is nonflammable and nontoxic. It also has a GWP of 1, meaning it satisfies current and potential future regulatory requirements. It can be used with CO2 transcritical booster systems — where CO2 provides both low- and medium-temperature cooling — and CO2 sub-critical (cascade) architectures that utilize an HFC or HFC/HFO blend on the medium-temperature side of the system. Both systems are particularly beneficial for large-format supermarkets where a centralized architecture is preferred. However, due to their higher pressures, these systems require access to a trained, skilled workforce for service and maintenance.

Staying ahead of the curve

Emerson is at the forefront of engineering a future that supports the entire spectrum of refrigeration strategies. We’ve been partnering with equipment manufacturers and end users alike to develop future-ready, low-GWP refrigerant technologies to support operators at every stage of their transition to a lower carbon footprint.

From our wide range of energy-efficient compressors, flow controls and smart electronics to fully integrated solutions, we’re providing our customers with the ability to implement sustainable refrigeration strategies that support their unique facility requirements, business objectives and regulatory requirements.

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