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Posts tagged ‘HFC’

Court of Appeals Ruling Questions the Elimination of EPA SNAP

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

Emerson Commercial & Residential Solutions

On April 7, the U.S. District Court of Appeals for the District of Columbia ruled that the Environmental Protection Agency (EPA) had improperly suspended the limits on the use of hydrofluorocarbon (HFC) refrigerants in its 2018 guidance. ACHR The NEWS interviewed Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, and me to discuss the implications of this ruling and what it means to our industry. View the full article here or read a summary of its contents in this blog.

To put this latest development into context, we must go back to 2017, when the Court of Appeals ruled to vacate the EPA’s Significant New Alternative Policy (SNAP) Rule 20. The ruling was based on the assertion that the EPA did not have the authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS). The EPA had interpreted the Court’s 2017 decision by suspending the requirements of SNAP Rule 20, which then allowed current users of ODS to freely switch to HFCs.

Despite widespread business and HVACR industry objections to overturn the Court of Appeal’s decision, the Supreme Court declined to hear the HFC case in 2018. Vacating EPA SNAP 20 halted years of regulatory progress in one of the world’s leading governing bodies on HFCs — and left the U.S. without a clear path forward in terms of a unified refrigerant strategy.

The April 7 Court of Appeals ruling was in response to a lawsuit introduced by the National Resources Defense Council (NRDC) and a coalition of states led by New York. The court ruled on both procedure and substance of the EPA’s 2018 guidance, stating:

  • The decision was made without going through proper public notice-and-comment procedures.
  • The agency had improperly suspended the limits on the use of HFC refrigerants.

As a result, the Court of Appeals requested that the EPA restore its prohibition on transitioning from refrigerants with ozone depletion potential to HFCs with a higher global warming potential. In essence, the EPA did not need to completely eliminate the requirements of SNAP Rules 20 and 21.

Implications to commercial refrigeration equipment

If you are a supermarket owner or operator wondering which refrigerants you will be permitted to use moving forward, we suggest referring to the original SNAP Rules 20 and 21 if you are considering replacing refrigeration equipment that still uses an ODS refrigerant such as R-22.

As I stated in the article: “If you’ve got an existing piece of equipment that’s running on R-22, you can continue to use it and service it with reclaimed R-22. That has not been taken away. If you have an R-22 system, and you’re looking to replace it with a newer system, I would look at the SNAP 20/21 list and find someone who can provide a refrigerant that’s on that list.” It’s also important to remember that states such as California have already adopted SNAP Rules 20 and 21, so choosing new equipment that is compatible with SNAP rules is still required in those states.

As Jennifer pointed out in the article, this Court of Appeals ruling does not clear up the regulatory uncertainty that’s prevalent in our industry.

“The exact impact of the decision is unclear, and further guidance from the EPA is necessary. This ruling also underscores the need for congressional action on federally regulating HFCs to deliver the certainty the industry needs,” she said.

Newly proposed legislation, such as the American Innovations and Manufacturing (AIM) Act, would give clear authority to the EPA on what they can and cannot do with respect to the HFC refrigerant phase-down. As I stated in the article, “We need the AIM Act now more than ever.”

Rest assured that as we gain more clarity on this quickly changing regulatory climate, we will continue to keep the industry informed of the latest developments.

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.

Evaluate System Lifecycle Performance When Making the Decision to “Go Green”

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

Emerson Commercial & Residential Solutions

I recently contributed to an ACR News publication with an article which addressed the topic of “green refrigeration.” The article, entitled A Greener Landscape for Commercial Refrigeration, explored why and how operators are making the transition to more eco-friendly refrigeration systems. View the full article here or read a summary below.

As global and national refrigeration industry dynamics continue to rapidly evolve, more business owners and supermarket operators are seeking new refrigerant and equipment alternatives. Ever-changing refrigerant and energy regulations, combined with an increased awareness of the environmental impacts of legacy refrigeration systems, are prompting more stakeholders to explore the green and growing edges of the refrigeration landscape.

But because commercial refrigeration systems can potentially be in service for decades, end users must carefully consider not only today’s regulatory requirements, but also tomorrow’s potential constraints. This means making the most informed equipment decisions possible with the goal of maximizing the investment throughout the system’s lifecycle. Doing so requires a fundamental understanding of the environmental impacts and financial considerations of a commercial refrigeration system.

Total equivalent warming impacts
While today’s regulations are primarily focused on reducing the global warming potential (GWP) from direct emissions of hydrofluorocarbon (HFC) refrigerants, it’s also important to remember that the total equivalent warming impact (TEWI) also accounts for indirect emissions — or the amount of greenhouse gases generated from the refrigeration system’s energy consumption. It’s estimated that these indirect emissions represent the majority of total climate impacts.

Only by evaluating both energy consumption and refrigerant GWP — including leaks and disposal — over the lifetime of a system can we estimate a system’s full lifecycle climate performance (LCCP).

Environmental and financial sustainability
Operators who are considering going green must also factor in the financial viability and sustainability of new or upgraded refrigeration systems. This means determining not only first costs and installation expenses, but also estimating the long-term maintenance and service requirements.

For manufacturers of these new eco-friendly equipment, components and systems, their task is twofold: 1) utilize lower-GWP refrigerants to meet regulatory requirements, while 2) minimizing ownership and operating costs.

Building a greener future
Like much of the commercial refrigeration industry, Emerson believes that the adoption of environmentally responsible, financially viable refrigeration systems will become more commonplace over the next decade. After all, there is a historic precedent for refrigerant phase-downs, including the ban on ozone-depleting substances which began in the 1990s and is now coming to fruition. Under the authority of the Montreal Protocol and the Environmental Protection Agency’s Clean Air Act, ozone- depleting substances like R-22 will no longer be manufactured or imported into the U.S. as of Jan. 1, 2020.

Today, the global reduction of fluorinated gases (aka F-gases) is being driven by the Kigali Amendment to the Montreal Protocol, which has now been ratified by more than 80 countries. As federal regulations continue to take shape and regional mandates become more prevalent throughout the U.S., it seems inevitable that the industry will eventually make the transition to more eco-friendly refrigeration systems.

Emerson has helped support this transition for many years by working with early adopters of low-GWP refrigerants and supporting technologies. Those operators who are taking proactive steps now will have a head start on this transition and be able to provide insights from which the rest of the industry can learn.

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.

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