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Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

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

Emerson Commercial & Residential Solutions

As the phasedown of hydrofluorocarbon (HFC) refrigerants continues globally, the United States currently lacks a federal mandate with which to govern their use in both AC and commercial refrigeration. Instead, several state-led initiatives and proposals are driving sustainability measures now in the U.S. At a recent E360 breakfast at the AHR event, I co-hosted an industry discussion with Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, on the latest developments in refrigerant regulations and rulemaking.

Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

Ever-evolving HFC Phasedown Requires Industry Guidance and Participation

Gauging from the level of interest from those who attended, the U.S. regulatory climate is an important topic for industry stakeholders. With dynamic developments taking place along state and federal lines, it’s more important than ever to stay informed and engage with any efforts to steer these evolving regulations in the direction of regulatory uniformity.

From Kigali to the EPA to the U.S. Climate Alliance

The Kigali Amendment to the Montreal Protocol remains the global force behind the phasedown of HFCs. Currently, more than 90 countries — not including the U.S. — have ratified this international treaty and plan to follow its recommendations to reduce the use of HFC refrigerants with high global warming potential (GWP). In the U.S., the rollback of the Environmental Protection Agency’s (EPA’s) Significant New Alternative Policy (SNAP) Rules 20 and 21 has deregulated the use of these HFCs from a federal perspective.

Even though SNAP Rules 20 and 21 have been vacated, today they serve as the regulatory framework for a growing number of states in the U.S. Climate Alliance — which currently is comprised of 25 member states representing 55 percent of the national population and $11.7 trillion in economic contributions. Among these, California, Washington, Vermont and New Jersey legally have adopted SNAP Rules 20 and 21, with five additional states proposing similar measures. Their charter is committed to “implementing policies that advance the goals of the Paris Agreement, aiming to reduce greenhouse gas emissions by at least 26-28 percent below 2005 levels by 2025.”

While these new states share a common regulatory framework, enforcement dates of refrigerant phasedowns per application vary from state to state. Although the industry recognizes the states’ sovereignty to take environmental action, we also urge consistency in approach and enforcement to reduce complexity. Imagine the challenge for contractors covering a multi-state territory where each state has different enforcement dates. This is the type of complexity that we should strive to avoid as an industry.

All eyes on CARB proposals

Not only was California the first state to adopt SNAP Rules 20 and 21 — which have already taken effect — its California Air Resources Board (CARB) has mandated 40 percent HFC emissions reductions from the state’s 2013 baseline levels by 2030. To date, California has taken the most aggressive environmental stance of any of the U.S. Climate Alliance states, and in many ways, is creating the path forward for other states to follow. This is precisely why it’s so important for industry stakeholders in all states to pay close attention to active proposals and engage in any opportunities to comment on the nature of proposed rulemaking.

Currently, the following CARB proposals for AC and chiller applications are open for additional industry input and comments:

AC

  • 750 GWP limit for new residential and non-residential, air-conditioning equipment, effective Jan. 1, 2023

Chillers and process chillers

  • 750 GWP limit for new chillers designed for a minimum evaporator temperature > -15 °F, effective Jan. 1, 2024
  • 2,200 GWP limit for new process chillers designed for a minimum evaporator temperature between -15 °F and -58 °F, effective Jan. 1, 2024

For the commercial refrigeration sector, CARB’s proposals have evolved to consider the challenges facing operators of existing food retail facilities by introducing the option of meeting a company-wide weighted average GWP or achieving a 55 percent reduction in Greenhouse Gas Potential (GHGp).

New commercial refrigeration

  • 150 GWP limit for new, non-residential refrigeration equipment containing more than 50 pounds of refrigerant, effective Jan. 1, 2022

Companies owning or operating 20 or more retail food facilities

  • Attain a company-wide weighted average of 2,500 GWP or achieve a 25 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2026
  • Attain a company-wide weighted average of 1,400 GWP or achieve a 55 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2030

Companies owning or operating fewer than 20 retail food facilities

  • Attain a company-wide weighted average of 1,400 GWP or achieve a 55 percent reduction in GHGp below 2018 levels, effective Jan. 1, 2030

CARB has asked the industry for input and comments on these proposals, which are expected to be finalized later this year. It’s critically important to review the details, definitions and exceptions to these proposed rules in order to gain a clear understanding of how they might impact you and provide informed feedback to help steer the rulemaking process.

New federal HFC bills on the horizon

With the EPA no longer authorized to regulate HFC use, 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. In the best-case scenario, these could provide the industry guidance that individual states need to move forward with a unified approach, remove the legislative burden from the states, and reduce regulatory complexity.

Download our full AHR breakfast presentation to learn more about proposed refrigerant rulemaking and how to prepare for regulations in your region.

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.

 

HVACR Contractors Offer Practical Perspectives on Refrigerant Regulations

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

Emerson Commercial & Residential Solutions

At a recent E360 Breakfast, Emerson hosted a panel of three Atlanta-area HVACR contractors to glean their firsthand insights into the biggest challenges and emerging trends impacting their businesses and customers. A recent article covers a wide range of topics and issues, including this discussion about the impacts of refrigerant regulations on contractors and their customers. You can read the full article here.

The service impacts of refrigerant regulations

Imagine showing up to a job site and not knowing which refrigerant is being used in the refrigeration or AC system. According to Martin Hoover, owner of Empire Heating & Air Conditioning in Atlanta, this has become an all too common scenario. “When pressures aren’t reading true, we have to start from scratch with a total refrigerant evacuation, recovery and recharge before even attempting a diagnosis,” he said. Hoover noted that the transition from legacy refrigerants to today’s lower-GWP options comes at a cost, even for those refrigerants that are considered “drop-in” replacements.

Michael Duffee, owner of Restaurant Equipment Services, Inc. of Tucker, Ga., added that customers are not happy to see recovery and disposal fees tacked onto their bill, and this is putting competitive pressures to use shortcuts on small contracting businesses. “Many companies may not be following proper recovery protocols to win business, which can put companies like ours at a disadvantage,” noted Duffee. “It is obviously counterproductive from an environmental standpoint.”

When asked if customers were even interested in the trend toward using lower-GWP refrigerants, Duffee said that in his experience, cost considerations are his customers’ first priority. Even if their legacy systems are leaking, customers are reluctant to invest in replacement equipment. They may be more open to discussing new refrigerants when that investment eventually becomes inevitable.

Presenting new refrigerants as an opportunity to add value

Jim Wharton, area vice president of Link Network, ABM in Atlanta, serves a much larger enterprise customer base. He said his customers have demonstrated more interest in making these investments, and his company is trying to frame the transition as an opportunity. “It’s challenging to align customers’ goals with the available equipment options, but there are some cases where federal and regional regulations are forcing a change.” Wharton added that change isn’t always good news for customers, but he helps them understand the real values of their investment, including total lifecycle costs, energy efficiency and performance advantages.

Too many options result in too much complexity

All three of the contractors said that refrigerant uncertainty is also adding complexity to the equipment decision-making process. Hoover noted his customers are concerned about the long-term viability of the changes. “The last thing they want after investing in a new system is for it to be phased out in four to five years due to a refrigerant change.” All three contractors agree that the industry would benefit by standardizing. Hoover added, “Preferably, we’d like to see one refrigerant, not five or six different options, to replace the old ones.” He pointed out that many contractors simply aren’t able to carry multiple varieties of refrigerants in their trucks at all times. And since these different refrigerants often have unique performance characteristics, variety only adds complexity to service calls.

At Emerson, we’ve seen the wide range of new refrigerant options as a technical challenge, developing equipment and retrofits to accommodate and optimize their performances. But it’s our interactions with contractors and customers that give us insights into how options ultimately impact end users. Their answers shed much-needed light on potential solutions — such as a press toward a single, standard and regulatory-compliant refrigerant.

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.

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