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Posts from the ‘Regulations’ Category

California HFC Phase-down Schedule Continues

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

The state of California and the California Air Resources Board (CARB) have taken steps to phase down hydrofluorocarbons (HFC) beginning in 2019. I recently presented this topic during Emerson’s January E360 Breakfast at the AHR Expo where I spoke about this and how it may influence refrigerant regulations in other states. Read Accelerate America’s article, “California Starts HFC Bans — with More to Come.”

As we had discussed in late 2018, the Environmental Protection Agency (EPA) indicated that in the wake of the vacating of SNAP Rule 20, it will no longer enforce HFC refrigerant delistings and has proposed to roll back further HFC-related regulations. This decision has a left a void in the regulatory landscape — one in which California and other U.S. Climate Alliance member states are vowing to fill.

In particular, many are looking to California to lead industry efforts on reducing high-GWP HFC refrigerants in commercial, industrial and residential refrigeration and AC applications. With the adoption of SNAP Rules 20 and 21 into state law, California appears to be embracing this role. As of Jan. 1, R-404A and R-507A are no longer permitted in new and retrofit supermarket central systems, remote condensing units, and low- and medium-temperature retrofit stand-alone units — all of which can be legally enforced in California under the authority of the California Cooling Act (Senate Bill 1013).

January 1 also marked the onset of bans for R-404A, R-507A, R-410A, R-134 and R-407A/C/F in new medium-temperature, stand-alone units with a compressor capacity of less than 2,200 BTU/hr and not containing a flooded evaporator. These actions mirror the now vacated EPA SNAP rules and are all part of an HFC phase-down schedule that will continue in California in the coming years.

The California Cooling Act also prohibits manufacturers from selling equipment or products that use banned HFCs manufactured after their respective prohibition dates. It’s important to understand this phase-down in the context of even larger and more ambitious state-wide environmental initiatives.

The California Air Resources Board plans to enact further restrictions on HFCs via its SLCP (Short-Lived Climate Pollutant) strategy, which was approved in March 2017. These actions are all intended to help California reduce HFC emissions 40 percent below the levels it recorded in 2013 by 2030, as stated in Senate Bill 1383 (aka the Super Pollutant Reduction Act).

CARB’s SLCP strategy is based on a multipronged approach in which they have proposed:

  • Limiting the GWP of refrigerants used in new stationary air-conditioning equipment to below 750 starting in 2023
  • Imposing prohibitions on refrigerants (more than 50 pounds) with a GWP of more than 150 for new stationary refrigeration beginning in 2022
  • Calling for a blanket ban on all production, import, sales, distribution or entry into commerce of refrigerants with a GWP of 1,500 or more, effective in 2022, with possible exemptions for

R-410A for use in AC and reclaimed refrigerant

We anticipate CARB to announce a final regulation on these SLCP initiatives in December for AC and March 2020 for commercial refrigeration. In the meantime, we encourage stakeholders to engage CARB in one of the many public meetings they’re planning throughout 2019.

As other states watch closely to see how California’s pending environmental regulations take shape, we believe it’s important that our industry continues to push for consistency in our approaches. Dealing with state-by-state mandates on what’s acceptable and what’s not acceptable would only introduce unnecessary complexity. To see my comments on this matter, please read the full article here.

 

Emerson Supports and Sponsors “World Refrigeration Day”

Emerson will be a sponsor of the first annual World Refrigeration Day on June 26 which will be celebrated on the 195th birthday of refrigeration pioneer Lord Kelvin and raise awareness and understanding of the significant role that refrigeration, air conditioning and heat pump (RACHP) technology plays in modern living

World Refrigeration Day

ASHRAE, UN Environment OzonAction and WRD Secretariat are organizing an international Webinar on the 26th June at 9 a.m. EDT titled “ Refrigerants for Life: How Refrigerants Affect Modern Life”. The event will feature RACHP and HVACR organizations and professionals from around the globe, including: the U.S., India, Pakistan, the Philippines, Thailand, Australia, Africa, and Europe. Representatives from these countries, regions, and organizations have pledged their interest and support for the establishment of World Refrigeration Day and will participate in a variety of activities.

Emerson’s vice president, system innovation center and sustainability, Rajan Rajendran, who is also the 2019-2020 Chair of ASHRAE Refrigeration Committee will participate in the webinar as Keynote Speaker to present the Responsible Use of Refrigerants and cover the following topics:

  • The complexity of choosing a refrigerant for HVACR applications
  • Considerations such as global warming potential (GWP), ozone depletion potential (ODP) and lifecycle climate performance (LCCP)
  • The environmental characteristics of chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs)
  • The growing trend toward the use of environmentally friendly refrigerant alternatives
  • A review of natural and synthetic refrigerants that offer lower LCCP

He will also discuss how the selection of refrigerants and their systems must be based on a holistic analysis that encompasses a variety of criteria, including: energy efficiency and performance attributes, environmental impacts, employee and public safety, and economic considerations. This event will also provide an opportunity for the refrigeration and air conditioning industries to continue a dialogue and address the many challenges we are facing, such as:

  • Rapidly evolving environmental standards
  • Global warming
  • The growing ubiquity of digital technologies
  • Food safety concerns
  • Never-ending energy and operating cost concerns

Emerson is pleased to participate in World Refrigeration Day and promote the roles that refrigeration, air conditioning, and heat pump technologies and applications have in today’s world.

You can register for the Wednesday, June 26 “Refrigerants for Life: How Refrigerants Affect Modern Life” webinar, here.

 

 

HVACR Contractors Discuss the Potential of New Technologies

BobLabbett_Blog Bob Labbett | V.P. – Aftermarket Distribution, Cold Chain

Emerson Commercial & Residential Solutions

At a recent E360 Breakfast, Emerson hosted a panel discussion among HVACR contractors to glean their insights and opinions on the biggest challenges and emerging trends impacting their businesses. It was a valuable opportunity to get a working perspective on issues more often discussed by industry analysts. A recent article covers a wide range of topics, including talks of new, high-end technologies at a practical level. You can read the whole article here.

The new technologies, IoT and analytics in the field

In recent years, the HVACR industry has experienced an influx of new electronic controls, connected technologies and data analytics enabled by the internet of things (IoT). As these technologies have come online, each of the three contractors on the E360 panel, with companies and customer bases of different sizes, has had different degrees of experience and interaction with these technologies in the field — from working with component-level information to gathering insights on facility management.

Making better use of data and analytics in the enterprise

Jim Wharton, area vice president of Link Network, ABM in Atlanta, works with an enterprise-level customer base. He explained that while data collection capabilities have been available for decades in different forms of energy management systems (EMS), many operators don’t use them to their full potential. Many may glance at their facility dashboards, see multiple areas running in the red (out-of-tolerance conditions), and may simply ignore the potential problems. “Most operators know the way their building behaves, and if they see an alarm in a certain area, they also know whether it will go away or if they need to act on it,” he said. He added that advanced data analytics now offer more insights and the potential to add tangible operational value by helping to drive informed decision making, detecting performance trends and providing equipment diagnostics and troubleshooting.

Embracing new technologies at home

Residential consumers are also embracing whole-home automation, said Martin Hoover, owner of Empire Heating & Air Conditioning in Atlanta. He said that his customers love getting notified of routine maintenance items, such as when to change filters or fix a water clog or leak. But most importantly, homeowners are using these systems to diagnose problems. “They like the fact that their home automation systems can let us know if something’s broken, so we can fix it before it affects their comfort levels,” said Hoover. But from a contractor’s perspective, he stressed that a home system also helps properly trained and educated technicians perform their own diagnostics. “This doesn’t allow us to take someone straight out of high school and put them in the field, but it certainly makes it easier,” he added.

On-board compressor controls are also helping service contractors gain deeper insights into overall refrigeration system performance. Michael Duffee, owner of Restaurant Equipment Services, Inc. of Tucker, Ga., cautions that these advanced controls require trained technicians. “If they’re not familiar with the technology, then you have to train them to avoid misdiagnosis, as there’s still the potential for things to go wrong,” he said.

Developing new technology for the real world of refrigeration

Designing new sensor technologies to be resistant to the impacts of weather, water and humid conditions are also very important considerations for Duffee. For example, he said, “In walk-in cooler environments, where it’s wet and sometimes caustic with the food and so forth, we’ve seen issues with consistency and where sensors and microprocessors can cause problems.”

With our broad knowledge of the full range of commercial refrigeration applications, Emerson keeps these environmental considerations upfront as we develop and introduce next-generation sensors and controls. For applications as simple as automated residential controls or as the source of real-time data for enterprise and IoT analytics, Emerson continuously consults with end users on the real-world issues raised by new technology.

How HVACR Contractors Are Responding to the Labor Shortage

BobLabbett_Blog Bob Labbett | V.P. – Aftermarket Distribution, Cold Chain

Emerson Commercial & Residential Solutions

At a recent E360 Breakfast, Emerson hosted a panel discussion among HVACR contractors to glean their insights and opinions on the biggest challenges and emerging trends impacting their businesses. In an article written about the discussion, a wide range of topics was covered, from the impact of new regulated refrigerants to the potential of today’s emerging high-end technologies, and more. One issue dominated the discussion: the impact of the labor shortage in contracting businesses. You can read the entire article here.

“We all would agree that labor is our number one issue.”

This statement by Martin Hoover, owner of Empire Heating & Air Conditioning in Atlanta, phrases American HVAC contractors’ key concern in a nutshell. Throughout the panel discussion, the technician shortage was a recurring theme — regardless of the topic discussed. When the conversation zeroed in on their labor challenges, each contractor was eager to detail how it was impacting his business and what steps the industry could take to help improve the situation.

The recruiting is non-stop

Finding qualified candidates starts at the company level, and each panelist has different approaches to the recruitment, onboarding and training processes. Hoover said his recruitment never stops. “We’re a small company and we recruit 24/seven/365,” he said. His company has developed an accelerated career progression plan for promising candidates, one specially designed to appeal to younger people new to the trade. “We’ve divided career steps into 30-day increments, which engages the younger generation from the entry level and allows them to progress very quickly,” he said. The goal is to accelerate their path to senior technician level and provide ample avenues for advancement.

Changing the perceptions of a valuable skill

Michael Duffee, owner of Restaurant Equipment Services, Inc. of Tucker, Ga., said one of his biggest recruitment hurdles continues to be the negative public perception of the trade. “Let’s face it, the trades sometimes have a less than positive image, and our trade is very demanding,” he said. “We get our hands dirty, we work with heavy equipment, on rooftops in the pouring rain, in snow and 100-degree temps.” Because of these factors, Duffee’s company places a premium on candidates who are enthusiastic and possess positive personality traits.

According to Duffee, the industry needs a renewed focus at the high school level to promote the trades. As experienced technicians retire from the industry, Duffee sees the labor shortage only getting worse in the coming years. “We all should be aware and take whatever steps necessary to change this trend,” he concluded.

Putting HVACR careers on the radar

Adding to Duffee’s point, Jim Wharton, area vice president of Link Network, ABM in Atlanta, noted that HVACR has fallen off the radar of many high schools with trade programs. “When you talk to high schools about trades, no one is talking about HVACR, so most don’t know it is an option.” Instead, Wharton’s company relies on alternative sources for recruitment, reaching out to former members of the U.S. military, vocational schools and technical colleges, and career and technical organizations.

Wherever recruits are found, Hoover stresses that on-the-job experience is the final step toward developing a well-rounded technician. “Tech schools don’t really teach someone how to present yourself to a customer and have the proper communication skills,” he said.

New challenges in HVACR bring new opportunities to technicians

With the introduction of new refrigerants and technologies, there’s no question that the HVACR service technician trade is more challenging than ever. But within this growing knowledge base lie growing career opportunities. As Hoover pointed out, “The technician shortage will drive up pay rates.” And the influx of connected technologies, software and analytics transforming the industry may help make the job more attractive to younger, tech-savvy candidates.

At Emerson, we believe that creating awareness of HVACR technologies and career opportunities at high schools and technical colleges is one of the keys to attracting the next generation of candidates. Even as technologies advance to provide more proactive and predictive capabilities, the industry will still need highly skilled individuals in the field to apply their own experiential know-how to system diagnosis and repair.

 

Refrigerant Regulations: 2018 Recap and 2019 Impacts

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

Emerson Commercial & Residential Solutions

The year 2018 brought many changes to refrigerant regulations, with additional activity expected in 2019 and beyond. This blog highlights some of the key developments, which were presented in a recent E360 article. Read the full article here.

 

The regulation of refrigerants continues to be a source of great uncertainty in the commercial refrigeration industry. As global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants in recent years, some in the industry have begun the transition toward alternative refrigerants with lower global warming potential (GWP). But these environmentally friendly options raise additional questions about performance and safety.

All in all, it’s a complex regulatory mix that got even more complicated in 2018. But we’re here to recap recent events and place them into a larger context.

The status of EPA SNAP Rule 20

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. The court ruled that the EPA did not have authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS) — and thus could no longer enforce its 2015 GWP-based mandates.

In the absence of Rule 20, the commercial refrigeration industry has many questions about what the path toward a more sustainable and environmentally friendly future for refrigerants will look like. Industry calls to overturn the District of Columbia Court of Appeal’s decision were declined by the Supreme Court, which stated it would not hear the HFC case1. Currently, the EPA is drafting new regulations that will clarify its plans to move forward with SNAP. We anticipate details on their position early this year.

EPA rescinds other HFC-related regulations

The EPA has also indicated that it will no longer enforce refrigerant delistings and has proposed to roll back other HFC-related regulations2. In particular, the EPA has proposed excluding HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA.

California adopts Rule 20 as the basis for its initiatives

Regulatory uncertainty at the federal level is not preventing states from adopting their own refrigerant regulations and programs. California Senate Bill 1383, aka the Super Pollutant Reduction Act, was passed in 2016 and requires that Californians reduce F-gas emissions (including HFCs) by 40 percent by 20303. The California Air Resources Board (CARB) has been tasked with meeting these reductions.

Since 2016, CARB had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. Even after SNAP Rule 20 was vacated, CARB moved to adopt compliance dates that were already implemented or upcoming. The passing of California Senate Bill 1013 — aka the California Cooling Act — in Sept. 20184 mandates the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017. The law is currently in effect and does not require additional CARB rulemaking to uphold compliance dates.

CARB is also proposing an aggressive second phase of rulemaking that would further impact commercial refrigeration and AC applications. CARB has held public workshops and invited industry stakeholders to comment on the details of this proposal.

Meanwhile, many other states have announced their plans to follow California’s lead on HFC phase-downs. The U.S. Climate Alliance, formed in 2017 out of a coalition of 16 states and Puerto Rico, is committed to reducing short-lived climate pollutants (SLCPs), including HFCs. Among these alliance states, New York, Maryland, Connecticut and Delaware have announced plans to follow California’s lead on HFC phase-downs.

Refrigerant safety standards and codes under review

Many of the low-GWP, hyrdrofluoroolefin (HFO) refrigerants are classified as A2L, or mildly flammable. R-290 (propane) is also becoming a natural refrigerant option for many low-charge, self-contained 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.

Internationally, the International Electrotechnical Commission (IEC) has proposed increasing charge limits for refrigeration systems in IEC60335-2-89 as follows:

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

These proposals are still under review and will likely be published sometime in 2019.

Kigali Amendment took effect on Jan. 1

The regulatory uncertainty in the U.S. can sometimes obscure international efforts underway to phase down HFCs. The Montreal Protocol has led the way on this effort for nearly a decade5. In 2016, 197 countries met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. Known as the Kigali Amendment, this treaty has been ratified by 53 countries (including the E.U.) and took effect on Jan. 1 for participating countries. The U.S. is still considering ratification.

As we move into 2019, there are many moving pieces on the regulatory chess board, but also some encouraging signs of progress. We will be providing the very latest regulatory updates in our next E360 Webinar. Register now to stay informed.

  1. https://www.achrnews.com/articles/140040-supreme-court-declines-to-hear-hfc-case
  2. https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations
  3. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383
  4. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB1013
  5. https://en.wikipedia.org/wiki/Montreal_Protocol#Hydrochlorofluorocarbons_(HCFCs)_Phase-out_Management_Plan_(HPMP)
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