Emerson’s Commercial & Residential Solutions Business
The recent passing of the American Innovation and Manufacturing (AIM) Act is accelerating the phasedown of hydrofluorocarbon (HFC) refrigerants and renewing the search for viable refrigerant alternatives, including those classified as A2L (mildly flammable) and A3 (highly flammable). But while A2Ls are among the leading alternatives capable of achieving regulatory requirements, the safety standards governing their use in the U.S. have yet to be finalized. Our next E360 Webinar — which will take place on Thursday, May 27 at 10 a.m. ET/7 a.m. PT — will feature a panel discussion about how A2Ls have been successfully deployed in regions where they have already been approved.
Around the globe, the phasedown of HFC refrigerants is prompting a transition toward alternatives with lower global warming potential (GWP). While A2Ls and A3 have been approved for use in Europe and are now widely adopted in commercial refrigeration applications there, the development of safety standards is ongoing within the U.S.
Currently, several industry working groups are evaluating A2Ls and A3s in equipment and field applications, including UL 60335-2-89 (the equipment standard based on IEC 60335-2-89) and ASHRAE-15 (the application standard updated for commercial refrigeration based on ISO 5149) — both of which are approaching the final phases of approval.
Our upcoming E360 Webinar will explore one European retailer’s sustainability journey from HFCs to low-GWP A2L refrigerants. As part two of the Air-Conditioning, Heating, and Refrigeration Institute’s (AHRI) webinar series, How to Not Only Survive, but “Win” the Refrigeration Industry HFC Phasedown, this webinar will provide an opportunity for the U.S. to learn from their experience and prepare for a future with A2L refrigerants.
The webinar will include the following experts and practitioners:
Helen Walter-Terrinoni of AHRI
Lauren MacGowens of AHRI
Tim Anderson of Hussmann Corporation
Stephen Spletzer of The Chemours Company
Brian Churchyard of ASDA (a European retailer)
Attendees will learn about the key points of the European retailer’s journey:
Defining sustainability goals and objectives — and meeting them
Transitioning from A1s (HFCs) to A2Ls
Applying A2L systems in a safe and effective way
Understanding the impacts on store and equipment design, training and maintenance
Emerson’s Commercial and Residential Solution’s Business
For over a decade, environmental advocates around the globe have recognized the need for the commercial refrigeration industry to make the transition from hydrofluorocarbon (HFC) refrigerants to lower-global warming potential (GWP) alternatives. An HFC phase-down is well underway in many countries and regions, and today conditions are favorable for these efforts to increase within the U.S. I recently contributed to an ACHR The NEWS article where we discussed how recent developments may accelerate this refrigerant transition.
Recent regulatory developments in the U.S. have increased the likelihood the HFC phase-down will become a higher priority for equipment manufacturers, contractors, and food retailers. Among the greatest contributing factors include:
The inclusion of HFC phase-down legislation in the recent Omnibus and COVID relief bill
A new presidential administration with a greater commitment to environmental stewardship
Continued regulatory activities taking place at the state levels
All eyes on California
For several years, the California Air Resources Board (CARB) has been proposing regulations targeting HFC emissions reductions in commercial refrigeration equipment used within grocery stores. In 2019, CARB banned the use of R-404A in new or retrofit centralized systems. Last December, CARB finalized those regulations and established an enforcement date, beginning January 1, 2022. Details of the rulemaking impact new (or remodeled) and existing facilities:
A limit of 150 GWP for new or fully remodeled facilities in California that utilize commercial refrigeration equipment containing more than 50 pounds of refrigerant.
Existing food retail facilities with refrigeration systems charged with more than 50 pounds must collectively meet a 1,400 weighted average GWP or 55 percent greenhouse gas potential (GHGp) reduction relative to a 2019 baseline by 2030.
As a result (in California, at least), natural refrigerant-based systems — such as CO2 transcritical boosters — are often considered leading options for compliance in new facilities.
California’s new regulations, along with new developments in federal refrigerant regulations, will present opportunities for manufacturers who already developed lower-GWP solutions. To support these efforts, Emerson has been qualifying its compressor lines to use a variety of lower-GWP refrigerants for more than a decade. Also, we are developing full-system strategies — such as CO2-based technologies and our distributed scroll booster architecture — that leverage new refrigerant alternatives and enable the implementation of lower-GWP systems. In addition, for retailers in California, we developed smart tools to help them evaluate their store fleets and calculate how they can achieve CARB compliance.
Elsewhere, a growing coalition of states — the U.S. Climate Alliance — has vowed to follow California’s lead. These member states are also continuing to develop their own legislation to enforce HFC phase-down commitments.
New federal legislation could provide industry-wide consistency
While state-level regulations have pushed forward, the status of refrigerant rulemaking at the federal level has been stagnant for several years — particularly after a 2017 court ruling determining the Environmental Protection Agency (EPA) did not have the authority to regulate HFCs under the Clean Air Act. But with the recent passage of the American Innovation and Manufacturing Act of 2020 (AIM Act) as part of the Omnibus and COVID relief bill, that may all soon change. The AIM Act restores the EPA’s authority to phase down the consumption and production of HFC refrigerants and establish sector-based limits.
As importantly, the new federal mandate will hopefully simplify the growing complexity of managing a multitude of state-led HFC phase-down initiatives. Ultimately, a federally-led refrigerant compliance program would provide much-needed guidance to the industry and remove the burden facing individual states. In addition, the industry could even see the adoption of new rulemaking from the EPA’s Significant New Alternatives Policy (SNAP) program.
This uptick in regulatory activity will likely result in a busy period for HVACR contractors and food retailers around the country — particularly those in California who will be preparing for the CARB regulations to take effect next year. Emerson is committed to helping commercial refrigeration stakeholders in the U.S. and throughout the world achieve their refrigeration goals and make the transition to lower-GWP refrigerant alternatives.
Emerson’s Commercial & Residential Solutions Business
The commercial refrigeration and air conditioning sectors are currently experiencing an active period of refrigerant rulemaking. As we move through the first quarter of 2021, our industry is evaluating a variety of regulatory activities and climate initiatives — at both the state and federal levels — that govern the transition to lower global warming potential (GWP) refrigerants and the safe use of flammable alternatives. I recently co-hosted an E360 webinar with Jennifer Butsch, Emerson’s regulatory affairs director, to discuss current developments and explore their potential impacts on our industry. We were joined by Helen Walter-Terrinoni, vice president of regulatory affairs for the Air-Conditioning, Heating, and Refrigeration Institute (AHRI).
As global regulatory efforts to phase down the use of HFC refrigerants continue in earnest, the transition to alternatives with lower GWP is gaining momentum in the U.S. At the state level, California is preparing for its next phase of rulemaking, while more U.S. Climate Alliance states leverage the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rules 20 and 21 as the bases for their own environmental initiatives. In addition, a new presidential administration and the passing of new federal legislation represent significant shifts in U.S. regulatory dynamics — resuming our global participation in combating climate change and giving the EPA authority to govern HFCs.
But the progression of refrigerant rulemaking along both state and federal lines continues to create complexity for an industry that seeks guidance in understanding and applying an ever-evolving, complex mix of regulations.
California Air Resources Board (CARB) Seeks to Finalize Proposals
In 2019, California was the first state to adopt EPA SNAP Rules 20 and 21 in their entirety. Since then, CARB has developed additional proposals to meet its stated 2030 emissions-reduction targets. For commercial refrigeration, these proposed refrigerant regulations target the installation of new refrigeration systems greater than 50lbs:
150 GWP limit for systems installed in new facilities
In existing facilities, food retailers must choose from one of the following company-wide reduction targets:
Reduce their weighted average GWP below 1,400
Achieve a 55% or greater reduction in their greenhouse gas potential (GHGp) below 2019 baseline levels by 2030
Other GWP limits for systems in existing facilities include a 750 limit for ice rinks and a 1500 – 2000 limit for industrial refrigeration
In air conditioning applications, the CARB proposal targets a 750 GWP limit across multiple end uses in the coming years:
2023: room AC and dehumidifiers
2024: AC chillers (consistent with SNAP Rule 21)
2025: residential and commercial AC
2026: variable refrigerant flow (VRF) systems
CARB has also introduced its Refrigerant Recycle, Recovery and Reuse (R4) program, which proposes new air conditioning equipment in 2023 and 2024 to use reclaimed R-410A refrigerant in an amount equal to 10% of equipment operating charge in California. In addition, CARB has stated that it will expand its R4 program by introducing new rulemaking this year.
U.S. Climate Alliance States Adopt Legislation
Among the 25 member states that have joined the U.S. Climate Alliance, nine have finalized legislation for adopting SNAP Rules 20 and 21 into law. Like the original EPA rules, the timings of enforcement dates are end-use specific and designed to be phased in over several years. But because the start dates of these rules differ among the nine member states, our industry faces an increasingly complex patchwork of compliance schedules.
As Walter-Terrinoni pointed out in the webinar, the prospect of new federal legislation may give these and other states the option to pursue a consistent, nationwide approach to the refrigeration phase-down. States could place their focus on the local level, where they can further the advancement of building codes and safety standards.
Federal HFC Phase-down Takes AIM
Regulatory activity is also picking up at the federal level, starting with the EPA’s proposed SNAP Rule 23, which reaffirms its commitment to approve low-GWP refrigerants. The proposal lists several mildly flammable (A2L) refrigerants, including R-452B, R-454A, R-454B, R-454C, R-457 and R-32 as acceptable, subject to use conditions in new residential and light commercial air conditioners and heat pumps. For retail food refrigeration — medium-temperature, stand-alone units — SNAP Rule 23 lists A1 refrigerants R-448A, R-449A and R-449B as acceptable, subject to narrowed use limits. Emerson and other industry stakeholders have asked for further clarification on these restrictions, as these A1s have already been listed as acceptable without limitations in many other commercial refrigeration applications.
As part of major pandemic relief legislation, the American Innovation and Manufacturing (AIM) Act was passed and signed into law in late 2020. This legislation gives the EPA the authority to phase down HFC production and consumption limits in a manner consistent with the Kigali Amendment to the Montreal Protocol within nine months. It also authorizes the EPA to regulate HFCs through sector based rulemaking and establish standards for HFC management — servicing, repair, recover, recycle and reclaim — similar to CARB’s R4 program. This is welcome news for our industry, as it paves the way for a federally guided, low-GWP refrigerant transition, which would minimize the complexities of differing state-led regulations.
Under the new Biden administration, the U.S. has rejoined the Paris Agreement and is taking steps to ratify the Kigali Amendment. These are among many early indications of this administration’s commitment to combat climate change at home and abroad.
A2L, A3 Standards and Codes Progress
With the industry moving toward the use of flammable A2L and A3 refrigerants to achieve lower-GWP goals, the technical committees and governing bodies who provide guidelines on how to safely use these refrigerants and related equipment are currently updating their safety standards. Among the updates that many are closely watching are the proposed changes to the Underwriter’s Laboratory (UL) 60335-2-89 standard, which would increase the charge limits in self-contained and remote refrigeration applications. While the industry expects this proposal potentially to be finalized by the end of the year, it’s important to remember that once established, these standards will take several years to make their way into the building codes and local standards needed to permit the widespread use of flammable refrigerants.
Emerson’s Commercial & Residential Solutions Business
The environmental regulations landscape continues to be a source of great uncertainty for the commercial refrigeration and AC industries. Sorting through the latest developments in an ever-evolving mix of global policy, federal and state rulemaking — for both refrigerant and energy efficiency regulations — is a complicated task. In our next E360 webinar, my colleague Dr. Rajan Rajendran, Emerson’s vice president of systems innovation center and sustainability, and I will explore recent regulatory activities and help you to understand their potential impacts on your business. The webinar will take place on Tuesday, Feb. 16 at 2 p.m. EST/11 a.m. PST.
From all indications, 2021 is shaping up to be a transitional year among the federal and state regulations governing commercial refrigeration and AC applications in the U.S. At the federal level, the recent enactment of the American Innovation and Manufacturing Act of 2020 (AIM Act) gives the Environmental Protection Agency (EPA) the authority to phase down the consumption and production of hydrofluorocarbon (HFC) refrigerants and establish sector-based limits. In addition, the introduction of the EPA’s Significant New Alternatives Policy (SNAP) Rule 23 proposal in 2020 was an indication of the agency’s desire to approve certain mildly flammable (A2L) refrigerants as acceptable for use — subject to use conditions — in new residential and light commercial air conditioners and heat pumps.
For several years, the California Air Resources Board (CARB) has stepped up its efforts to phase down the use of HFC refrigerants. This started with the adoption of EPA SNAP Rules 20 and 21 and now continues with a proposal that calls for increased HFC and refrigerant global warming potential (GWP) reductions, which could take effect as soon as January 1, 2022. As a result, retailers in California may soon face the prospect of making significant changes to their refrigeration systems — in at least some of their stores — to achieve compliance.
While retailers outside of the state of California currently may not face an imminent regulatory mandate, member states of the U.S. Climate Alliance are moving forward with their own HFC phase-down initiatives, which include the adoption of EPA SNAP Rules 20 and 21. And with a new administration taking office, we are also likely to see a new tone and urgency with respect to broader climate initiatives, as well as the potential for greater participation in global environmental policies.
All these moving pieces set the stage for a potentially active period of regulatory developments in 2021 and beyond. The primary goals of our upcoming E360 webinar are to explore these developments in more detail, place them into their proper context, and offer insights to help you understand the impacts on your business.
Attendees will learn:
Status of CARB regulations/proposals and their potential impacts
Review of U.S. Climate Alliance state activities and adoption of EPA SNAP Rules 20 and 21
Overview of AIM Act and its potential impacts
Update on the codes and standards for flammable refrigerants, such as UL 60335-2-89 and ASHRAE 15
Impacts that a new administration may have on climate initiatives
In 2017, the Department of Energy (DOE) passed its final rule on new energy conservation standards for walk-in coolers and freezers (WICFs). The ruling mandated new efficiency requirements on WICFs with dedicated condensing systems in both low- and medium-temperature applications. With enforcement of these requirements now having taken effect, I recently published an article for Contracting Business that explained the implications of the DOE’s ruling. View the full article here and read a summary of it below.
Per the ruling, 20–40 percent energy reductions are now required on WICFs smaller than 3,000 square feet manufactured after the following enforcement dates:
January 1, 2020, for WICFs with medium-temperature dedicated condensing systems
July 10, 2020, for WICFs with low-temperature dedicated condensing systems
Now that enforcement dates are here, industry stakeholders are tasked with verifying that they are achieving compliance with the DOE’s WICF rule.
Who and what does the ruling apply to?
The ruling directly applies to anyone manufacturing, producing, assembling or importing to certify WICF components. From a refrigeration system standpoint, compliant components refer to dedicated and packaged condensing units (indoor and outdoor) used in both new and retrofit applications, including:
Condensing units that are assembled to construct a new WICF
Condensing units used to replace an existing, previously installed WICF component (retrofit)
Condensing units used within packaged systems
Other components — such as unit coolers (evaporators), doors, panels and lighting — are also within the jurisdiction of the DOE’s WICF ruling.
Contractors and wholesalers can still use and stock condensing units that were manufactured before the DOE enforcement dates. All newly manufactured condensing units must be compliant if intended for use in applicable WICF applications, as defined by the DOE’s ruling.
How can you measure efficiency and achieve compliance?
The DOE uses a metric created by the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) called the Annual Walk-In Energy Factor (AWEF) to evaluate a WICF system’s energy efficiency. This AWEF calculation is based on “a ratio of the total heat, not including the heat generated by the operation of refrigeration systems, removed, in Btu, from a walk-in box during a one-year period of usage for refrigeration to the total energy input of refrigeration systems, in watt-hours, during the same period.”
Per the DOE, there are several WICF equipment classes below the 3,000 square foot limit that must meet or exceed the minimum AWEF ratings based on capacity and application (e.g., medium- or low-temperature, indoor or outdoor). Condensing unit manufacturers and WICF original equipment manufacturers (OEMs) must follow approved AWEF testing and certification procedures to meet or exceed the DOE standards.
How will the ruling impact you?
From OEMs and wholesalers to contractors and end users, the DOE’s WICF ruling has broad impacts throughout the industry. Because the DOE WICF ruling impacts both new and retrofit equipment, every segment of the commercial refrigeration supply chain will need to understand its implications. Here’s what you need to know:
OEMs —need to complete the engineering design cycle, testing and certification to sell new compliant equipment.
Contractors —must understand that if they replace a condensing unit with one manufactured after the DOE enforcement dates, it must be an AWEF-compliant unit. However, units manufactured prior to the DOE’s enforcement dates already in inventory may still be used.
Wholesalers —must be prepared for changing inventories and begin to carry only AWEF-compliant condensing units that were manufactured after the 2020 enforcement dates for the relevant WICF applications.
Design consultants —must be well-versed in the regulatory impacts to advise end users in the selection of energy-compliant, sustainable systems.
End users —need to select future-proof equipment that aligns with their long-term refrigeration strategies.
How is Emerson helping OEMs?
As a manufacturer of condensing units for a wide range of refrigeration applications, we manufacture WICF condensing units that have been certified as meeting the DOE’s minimum AWEF requirements. Compliance data is listed in our condensing unit AWEF product literature.
For WICF OEMs, using certified condensing units will help them meet the compliance requirements in one of their primary refrigeration system components. OEMs should be able to combine an Emerson AWEF-compliant condensing unit with any AWEF-compliant unit cooler in order to achieve compliance in a dedicated system.
So if you’re an OEM of walk-in coolers and freezers, you now need to manufacture WICFs that meet the DOE’s minimum AWEF standards. If you’re not sure how to proceed with this compliance process, you may consult with Emerson’s Design Services Network to expedite your product development, design and testing processes.
With our breadth of products, expertise and resources, we can help you achieve compliance and develop sustainable refrigeration strategies for your customers — and our future.
Commercial & Residential Solutions is a global innovator of energy-efficient heating, air conditioning and refrigeration solutions for residential, industrial and commercial applications. www.climate.emerson.com
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