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Low-GWP Strategies for Achieving CARB Compliance

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

Emerson Commercial & Residential Solutions

Emerson was recently invited to participate in a webinar series hosted by the North American Sustainable Refrigeration Council (NASRC) aimed at helping retailers prepare for California’s refrigerant regulations and incentives. In the webinar, Diego Marafon, refrigeration scroll product manager at Emerson, and I discussed emerging refrigeration strategies for supporting low-GWP (global warming potential) compliance and hydrofluorocarbon (HFC) reductions while uncovering opportunities to lower operating costs.

Low-GWP Strategies for Achieving CARB Compliance

In the U.S., the California Air Resources Board (CARB) is leading the charge for regulations impacting commercial refrigeration. For large centralized refrigeration systems — which today make up the majority of retail refrigeration — CARB’s current proposal would require new systems with more than 50 pounds of refrigerant to use refrigerants below 150 GWP. As a result, CO2 is a primary refrigerant choice for operators seeking to stay with a large centralized system and meet CARB’s proposed regulation.

But as retailers evaluate new system architectures, they also have an expanding variety of decentralized and distributed options to consider. What’s more, CARB’s latest proposals provide new approaches for achieving HFC reductions that are giving retailers the option to remodel, rather than invest in all-new refrigeration systems for their fleet of stores. These proposals include:

  • Greenhouse gas emission potential (GHGp) reduction by 55% — Requires the total GHGp of all refrigeration systems in all stores to be 55% below the 2018 baseline by 2030, where GHGp equals the sum of the refrigerant charge times GWP — or GHGp = ∑(charge X GWP). This is a per-company target which gives retailers some flexibility in achieving compliance. As retailers retrofit their stores, they’ll receive credits for refrigerant charge and GWP reductions. But retailers must have the abilities to track, report each store’s GHGp baselines as well as document and verify any equipment changes.
  • Weighted average GWP (WAGWP) reduction < 1,400 — Requires the WAGWP of each retailer to be less than 1,400 by 2030. It’s calculated by finding the sum of the charge times GWP in every system in every store, divided by the total charge — or weighted average GWP = ∑(charge X GWP) / ∑ This approach allows retailers to aim for a fixed target — without the need for tracking a company baseline — while giving them the option to only retrofit the stores needed to meet the 1,400 GWP target. Retailers may need to apply this equation to multiple retrofit scenarios to successfully deploy this strategy. Simply put, they’ll need to do the math and figure out how to best reach this target.

Weighing your retrofit options

In the webinar, we discussed each of these approaches and ran the numbers to show how retailers could take a long-term view of their store fleet strategies and make modifications to achieve their goals — utilizing refrigerant changes, system retrofits or installing new refrigeration systems. Using a WAGWP calculator developed by Emerson, we demonstrated different strategies for achieving CARB compliance, providing cost projections for each option. If you’re interested in learning more about the WAGWP calculator, you can contact your salesperson, or visit the contact us page.

For this exercise, we looked at a hypothetical scenario of a California retailer with 25 stores, 66 total refrigeration systems and a WAGWP of 2,715. Then we evaluated three different retrofit options and calculated their impacts:

  • Refrigerant change from R-404A to R-448A — By changing out the refrigerant in all 25 stores, the retailer could achieve a WAGWP of 1,383 (nearly a 50% GHGp reduction). The total CapEx for the changes were $3M, with a cost per WAGWP reduction of $2.2k.
  • Convert half the stores to a new CO2 system — By installing new CO2 systems in 12 of the stores and leaving the other 13 untouched, the retailer could achieve a WAGWP of 1,277 (or a 54% GHGp reduction). The total CapEx for the changes were $27.3M, with a cost per WAGWP reduction of $19k.
  • Hybrid approach — By converting 20 systems to R-448A and installing 28 new scroll booster systems (with R-513A) — leaving 18 systems as is — the retailer could achieve a WAGWP of 1,520 (or 55% GHGp reduction). The total CapEx for the changes were $15M, with a cost per WAGWP reduction of $13k.

These scenarios demonstrated how to calculate system retrofit and remodel impacts while showing the multiple alternatives for implementing lower-GWP remodel strategies. It’s important to realize that in California, CARB has incentive programs to help retailers offset the cost of making these system changes.

But CARB is just one piece of a dynamic regulatory landscape — which includes energy, environmental and food safety regulations within varying regional, national and global jurisdictions — that continues to drive changes in refrigeration equipment and architectures. In response, Emerson is committed to developing a full spectrum of low-GWP refrigerant technologies, including CO2, R-290 and hydrofluoroolefins (HFOs), as well as lower-GWP HFC A1 refrigerants that are still in use. Most recently, we’ve expanded our offerings to support the industry’s need for more flexible, distributed architectures which deliver both high energy efficiencies and low-GWP ratings.

To learn more about using Emerson’s tools for calculating the impacts that system retrofits or remodels would have on your store fleet’s environmental footprint, view this NASRC webinar with the title of, “Emerson Technology Solutions.”

 

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.

 

California’s HFC Phase-down: Costs, Energy, Leaks and Incentives

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

Emerson Commercial & Residential Solutions

As Jennifer Butsch and I discussed in our most recent E360 Webinar, the California Air Resources Board (CARB) has adopted the Environmental Protection Agency’s (EPA’s) Significant New Alternatives Policy (SNAP) regulations 20 and 21. ACHR NEWS, which attended our webinar and CARB’s most recent public stakeholder meeting, has compiled a report on the implications of CARB’s hydrofluorocarbon (HFC) phase-down efforts. Below is a synopsis of their article, which you can read here in its entirety.

California’s HFC Phase-down: Costs, Energy, Leaks and Incentives

In early March, CARB held its first of several public technical working group meetings of the year. While the focus of this workshop was on stationary AC equipment, the scope of the issues discussed also extended to matters impacting commercial refrigeration. The purpose of these meetings is to gain insights into the many questions surrounding the implementation of its current and future regulations governing the state’s HFC phase-down. In this session, CARB posed several questions related to equipment costs, refrigerant leaks, the intersection with energy efficiency regulations and incentives for making the transition to lower-GWP refrigerants. And while these questions were targeted to California stakeholders, their relevance extends to the larger United States, where it is estimated that a federal mechanism to phase down HFCs will eventually be reinstated.

First costs, installation and maintenance

As we discussed in our most recent webinar, the commercial refrigeration sector is where the industry will continue to experience a proliferation of refrigeration systems. But this presents a series of challenges for OEMs and component manufacturers as we attempt to balance refrigerant GWP limits with economic viability — with hopes to minimize first costs, install costs and long-term service expenses of new equipment.

Opinions about cost considerations varied at the CARB meeting, though attendees generally agreed that first costs on AC equipment could range from 5 to 15 percent in various categories of equipment. CARB estimated that install and maintenance costs could increase anywhere from 5 to 10 percent, especially considering the need for additional contractor and technician training and tools to work with lower-GWP refrigerants such as A2Ls.

Factoring energy into the equation

For OEMs, meeting CARB’s GWP limits is only one of the regulatory milestones they will face in the next few years. The Department of Energy’s (DOE’s) new energy efficiency requirements are scheduled for 2023, which means OEMs need to factor both energy-related equipment upgrades and the refrigerant transition into their design cycles. This was another topic of debate at the CARB meeting.

CARB members suggested that OEMs could try to offset upgrade expenses and achieve economies of scale by combining design cycles. Representatives from the Air-Conditioning, Heating and Refrigeration Institute (AHRI) took the position that these upgrades would require separate efforts. To help CARB understand the implications of these scenarios, AHRI cited survey data in which its members considered the costs of efficiency upgrades before addressing required refrigeration changes.

Leak reduction and prevention

Meeting attendees reached a consensus when discussing the problem of refrigerant leaks. As an AHRI representative pointed out: none of California’s GWP targets will be attainable if the industry can’t figure out this critical issue. They cited a UN Environmental Program report that estimated up to 60 percent of GWP sources from HVACR equipment can be traced to leaks.

And as we reported in our recent webinar, supermarkets that in the EPA’s GreenChill program have achieved drastically reduced leak rates, sometimes more than 50 percent. It’s also a reminder that as California and the rest of country continue their transitions to lower-GWP refrigerant alternatives, proper reclamation, recycling and disposal of HFCs will be extremely important.

Incentivizing participation

When the California Senate Bill No. 1013 (aka the California Cooling Act) was passed in 2018, it included an incentive mechanism via the Fluorinated Gases Emission Reduction Incentive Program. To date, this program has remained unfunded in the 2019 budget, although there still is yet a possibility for budget adjustments this year.

As was noted in the article, California’s tradition of incentives has helped create momentum to move the state toward lower-GWP refrigerants, systems with lower leak rates and better recordkeeping. Regardless, early adopters of climate-friendly cooling will have a variety of options from which to choose for new low-GWP systems, retrofits and upgrades.

What’s next?

CARB has stated that it will hold further stakeholder meetings this year, including a workshop focused on commercial refrigeration at the end of May. These meetings will conclude with a draft of the proposed new rulemaking along with continued economic analysis. As the industry awaits an update from the EPA on HFC-related regulations, California continues to be the country’s torchbearer for low-GWP refrigeration and cooling systems. As I was quoted in the article, our industry still has a lot of learning to do in the next four or five years, as the refrigerant transition will continue to drive equipment changes.

 

Refrigerant Rulemaking in 2019

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

Emerson Commercial & Residential Solutions

While the phase-down of hydrofluorocarbon (HFC) refrigerants is underway globally, federal regulatory uncertainty and state-level actions in the U.S. continue to raise many questions in our industry. Our latest E360 Webinar presented the latest developments in this dynamic area in hopes of clearing up some of the confusion. View the webinar in its entirety.

Along with my Emerson colleague, Jennifer Butsch, regulatory affairs manager of air conditioning, I recently presented the latest information on refrigerant regulations and rulemaking. The primary objective of these activities is to reduce the use of HFC refrigerants with high global warming potential (GWP), and at the same time, introduce lower-GWP alternatives. For those of us in the commercial refrigeration and AC industries, this transition impacts many of our most common applications.

Here’s a summary of our discussion.

Kigali Amendment takes effect

To put these matters into their proper context, it’s important first to understand the global regulatory driver of the HFC phase-down, the Kigali Amendment to the Montreal Protocol. This proposal was agreed upon at a meeting of 197 countries in 2016, and has since been ratified into law by more than 65 countries, including European members, Canada and Mexico.

While the U.S. has yet to ratify the Kigali Amendment, its phase-down guidelines went into effect for participating countries as of Jan. 1, 2019. However, this doesn’t necessarily mean its impacts are not being felt in the U.S., particularly in state-level initiatives to meet environmental targets.

California adopts SNAP rules, plans further reductions

While the Environmental Protection Agency (EPA) SNAP Rule 20 has been vacated and Rule 21 remains in litigation, California has adopted these rules into law. Effective Jan. 1, R-404A and R-507A are not allowable in many commercial refrigeration applications, including: supermarket central systems, remote condensing units and stand-alone systems. Essentially, this upholds previous SNAP 20 rulemaking and prevents operators in the state from using high-GWP HFCs. But this is just the first of many steps.

California is also adhering to the longer-term HFC phase-down schedule for commercial refrigeration and AC as outlined in SNAP Rules 20 and 21. In addition, the California Air Resources Board (CARB) has been tasked with reducing HFC emissions 40 percent by 2030 from the state’s 2013 baseline level — a target that’s very much in alignment with the Kigali Amendment’s HFC phase-down recommendations for the United States.

Achieving these levels will require new rulemaking in accordance with CARB’s short-lived climate pollutant (SLCP) reduction strategy. CARB is planning on releasing a final rule toward the end of this year. In the meantime, they will conduct a series of public meetings for both AC and commercial refrigeration stakeholders. Emerson strongly encourages you to participate in these meetings to make sure your questions and concerns are addressed.

Other states join the charge

While California appears to be taking the lead on domestic HFC phase-down efforts, there are also many other states making commitments to climate change initiatives, including the reduction of HFCs.

The U.S. Climate Alliance now includes 21 states; combined they make up 49 percent of the U.S. population and 50 percent of the gross domestic product (GDP). We believe that it is in our industry’s best interest for these states to follow a united course of action, rather than a patchwork of individual state mandates.

Other key webinar takeaways

Jennifer and I also discussed many other important developments pertaining to the use of lower-GWP alternatives, including:

  • Applications, availability and GWP ratings of A1, A2L, A3, B2L and natural alternatives
  • Update on refrigerant safety standards of A2L and A3 (flammable) refrigerants
  • How refrigerant standards affect equipment, applications, building codes and local codes
  • Lower-GWP refrigerant impacts on refrigeration architectures

To learn more about these topics, please view this webinar in its entirety.  

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