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Integrated R-290 Cases Expand Into U.S. Markets

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

Emerson Commercial & Residential Solutions

I was recently asked to contribute to an Accelerate America article about the increasing use of R-290 in the U.S. commercial refrigeration market. The article featured a variety of perspectives from supermarket operators and equipment manufacturers. Read the full article (pg. 38) and more on Emerson’s perspective below.

Integrated R-290 Cases Expand Into U.S. Markets

A growing number of American retailers — including Target, ALDI US and Whole Foods Market — have been deploying self-contained, R-290 cases as spot merchandisers in hundreds of stores, many of which are mainly served by centralized rack systems. Some retailers regard these units as partial or even full-store alternatives to using a centralized rack-based system.

Obviously, this comes as no surprise to Emerson. Not only have we been partnering with R-290 equipment manufacturers for many years, we also support operators and commercial refrigeration designers alike in their efforts to utilize R-290 — and a variety of other lower-GWP and natural refrigerants — in their systems. As others have stated in the article, this trend reflects a shift in the research and development processes for some manufacturers, in that fewer emerging architectures are being designed to utilize hydrofluorocarbon (HFC) gases.

It’s further evidence that, regardless of the unpredictable state of environmental regulations, R-290 use in commercial refrigeration continues to gain traction. We at Emerson are seeing the use of integrated case architectures — where one or more R-290 compressors is/are housed within a refrigerated case — and the continued use of completely self-contained units as the most likely paths to wider adoption of integrated R-290 in 2019 and beyond.

While R-290 systems may have originally been born out of necessity to address environmental concerns, today they’re perceived in the market as much more than just eco-friendly alternatives. With the expansion of smaller-format stores and increasing retail urbanization, many times there simply isn’t enough space to accommodate a machine room for a traditional central system. In these scenarios, plug-and-play, low-charge, R-290 systems are an ideal fit.

The safe use of R-290, which is classified as an A3, highly flammable refrigerant, is governed globally by the International Electrotechnical Commission (IEC) and nationally by the Underwriters Laboratory (UL). Historically, these standards mandated that R-290 charge limits should be limited to a maximum of 150g. However, the IEC recently updated their standard (IEC 60335-2-89) to allow the use of up to 500g of A3s like R-290. This charge limit increase will enable more application flexibility for European food retailers.

It’s important to note that in the U.S., the UL standard still mandates a maximum of 150g charge limit for A3s. Even with the low charge limit of 150g, R-290 cases have proven viable options for many leading retailers in the U.S. market and abroad.

While the industry adapts to the charge limit increase, there are real-world installations that are also indicative of the safety and reliability of these self-contained, R-290 cases. Since 2013, an HEB grocery store in San Antonio has utilized the R-290 cases installed throughout the entire store as its primary refrigeration source. The designer of that architecture, who was also interviewed in the same article, stated that these cases have proved to be both safe and reliable — and have had no leaks since they’ve been installed.

Today we’re achieving more flexibility using R-290 systems with micro-distributed architectures utilizing integrated cases. They are designed to remove compressor exhaust heat via a shared glycol water loop that’s directed to the roof of the facility for heat removal. These systems typically stay within the 150g limit and enable a greater degree of scalability.

It will be interesting to see how the possibility of increasing the R-290 charge limit, as has been discussed and studied within the industry for years, might impact system design in the future. For now, R-290 seems to have a place — albeit a relatively niche one — in U.S. markets.

Regulatory Uncertainty Impacts Refrigerant Decisions

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

Emerson Commercial & Residential Solutions

I was recently asked to contribute to an ACHR The NEWS article about the uncertainty surrounding the dynamic regulations governing the use of refrigerants. The article provided perspectives from several industry stakeholders, and I was happy to discuss Emerson’s views on the short- and long-term implications of the situation. Read a summary of the article below and view it here in its entirety.

For the last two years, the commercial refrigeration industry has been in a period of uncertainty regarding the regulations that govern the use of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP). Since the U.S. DC Court of Appeals ruled that the Environmental Protection Agency (EPA) did not have the authority to phase down HFCs, the EPA’s role in the national HFC phase-down has been unclear.

R-22 phase-out is still in effect

For the time being, the EPA’s authority covers only the transition from ozone-depleting substances, such as the chlorofluorocarbon (CFC) R-22. So, even though the HFC rules have been vacated, the EPA still has the authority to phase out R-22, which is scheduled to take place on Jan. 1, 2020.

While there’s plenty of discussion about the fate of HFCs, it would be unwise to presume that the 2020 R-22 phase-out won’t have significant impacts. In fact, it may surprise some to learn that there are still many operators with older refrigeration systems currently charged with R-22. But after Jan. 1, they must either retrofit their systems with lower-GWP refrigerants or continue to recover and reuse R-22 until their supplies run out — with the understanding that the latter choice is not a permanent solution.

HFC phase-down continues in California and other states

The absence of a federal mandate to phase down common HFCs is not deterring California from taking its own steps. Per a recent ruling by the California Air Resources Board (CARB), R-404A and R-507A are no longer allowable in many new commercial refrigeration applications.

California’s regulatory stance is a reminder that a retailer’s geographic location is an important factor in the development of their refrigerant strategy. While California is currently taking the lead on U.S. HFC reductions, there are currently

As retailers evaluate their future refrigerant options, state-specific environmental regulations will factor prominently in their decision processes. For example, operators in California are well aware of the efforts to phase down HFCs and most likely have alternative refrigerant plans in place. These operators are either planning for retrofits or trialing new alternative refrigerant architectures.

Strategies for moving forward

Fortunately for operators, component and equipment manufacturers have continued developing solutions that feature a wide range of lower-GWP refrigerant alternatives. These solutions are helping retailers align their sustainability objectives with their refrigeration architectures, and include the following strategies:

  • Retrofit using lower-GWP HFOs — Moving from R-404A to R-448A or R-449A may require adding compressor cooling and other relatively minor system changes but can help operators preserve their existing system investments. Deploying energy optimization best practices will also help them reduce indirect emissions, which lessens their overall carbon footprint.
  • Transition to a new and/or natural refrigerant system — Natural architectures offer maximum carbon footprint reductions and are considered by many as the only true future-proof solutions available today. These systems can be installed in new locations or in parallel with an existing system, allowing the retailer to slowly transition to the natural solution.

Emerson is continuing to develop a variety of alternative refrigerant solutions designed to help operators and equipment manufacturers reduce their carbon footprints. Regardless of the regulations in your specific region, we’re here to support the commercial refrigeration supply chain as it transitions to lower-GWP refrigerant alternatives.

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 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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