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Posts tagged ‘Jennifer Butsch’

[New E360 Webinar] Will Provide Regulatory Update on Refrigerant Rulemaking and Climate Initiatives

Jennifer Butsch | Regulatory Affairs Director

Emerson’s Commercial & Residential Solutions Business

The environmental regulations landscape continues to be a source of great uncertainty for the commercial refrigeration and AC industries. Sorting through the latest developments in an ever-evolving mix of global policy, federal and state rulemaking — for both refrigerant and energy efficiency regulations — is a complicated task. In our next E360 webinar, my colleague Dr. Rajan Rajendran, Emerson’s vice president of systems innovation center and sustainability, and I will explore recent regulatory activities and help you to understand their potential impacts on your business. The webinar will take place on Tuesday, Feb. 16 at 2 p.m. EST/11 a.m. PST.

From all indications, 2021 is shaping up to be a transitional year among the federal and state regulations governing commercial refrigeration and AC applications in the U.S. At the federal level, the recent enactment of the American Innovation and Manufacturing Act of 2020 (AIM Act) gives the Environmental Protection Agency (EPA) the authority to phase down the consumption and production of hydrofluorocarbon (HFC) refrigerants and establish sector-based limits. In addition, the introduction of the EPA’s Significant New Alternatives Policy (SNAP) Rule 23 proposal in 2020 was an indication of the agency’s desire to approve certain mildly flammable (A2L) refrigerants as acceptable for use — subject to use conditions — in new residential and light commercial air conditioners and heat pumps.

For several years, the California Air Resources Board (CARB) has stepped up its efforts to phase down the use of HFC refrigerants. This started with the adoption of EPA SNAP Rules 20 and 21 and now continues with a proposal that calls for increased HFC and refrigerant global warming potential (GWP) reductions, which could take effect as soon as January 1, 2022. As a result, retailers in California may soon face the prospect of making significant changes to their refrigeration systems — in at least some of their stores — to achieve compliance.

While retailers outside of the state of California currently may not face an imminent regulatory mandate, member states of the U.S. Climate Alliance are moving forward with their own HFC phase-down initiatives, which include the adoption of EPA SNAP Rules 20 and 21. And with a new administration taking office, we are also likely to see a new tone and urgency with respect to broader climate initiatives, as well as the potential for greater participation in global environmental policies.

All these moving pieces set the stage for a potentially active period of regulatory developments in 2021 and beyond. The primary goals of our upcoming E360 webinar are to explore these developments in more detail, place them into their proper context, and offer insights to help you understand the impacts on your business.

Attendees will learn:

  • Status of CARB regulations/proposals and their potential impacts
  • Review of U.S. Climate Alliance state activities and adoption of EPA SNAP Rules 20 and 21
  • Overview of AIM Act and its potential impacts
  • Update on the codes and standards for flammable refrigerants, such as UL 60335-2-89 and ASHRAE 15
  • Impacts that a new administration may have on climate initiatives

Register now for this informative and free webinar.

Refrigerant Transition Continues Along State and Federal Lines

Jennifer Butsch | Regulatory Affairs Manager

Emerson’s Commercial & Residential Solutions Business

Emerson recently participated in the Atmosphere America online conference, where commercial refrigeration industry stakeholders discussed the ongoing transition from hydrofluorocarbon (HFC) refrigerants to those with lower global warming potential (GWP). Dr. Rajan Rajendran, Emerson’s vice president of system innovation center and sustainability, and I were speakers at the event; ACHR The News reported on our thoughts on the topic in a recent article.

Recapping recent events that impacted refrigerant rulemaking

To recap the activities regarding U.S. federal refrigerant regulations, I explained how these policies have faced many legal headwinds over the past few years. These began in 2017, when in response to a court challenge, a federal court vacated the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rule 20 on the basis that the EPA didn’t have authority to regulate non-ozone depleting substances. If you remember, SNAP Rules 20 and 21 had been adopted on the basis of reducing global warming by phasing down the use of higher-GWP HFCs in some commercial and air conditioning equipment.

In response to the court’s ruling, the EPA released a guidance document stating that they would no longer be enforcing the delisting of HFCs under SNAP Rules 20 or 21. As a result, the scope of the SNAP program — including its ability to regulate HFCs and implement Rules 20 and 21 — remains to be seen. As of this time, the industry is still waiting for clarification from the EPA on this matter.

Reviewing new regulatory activity

However, as I explained at the conference, the EPA did introduce a SNAP Rule 23 proposal earlier this year, which recommended the use of three additional lower-GWP refrigerant alternatives for commercial refrigeration — R-448A, R-449A and R-449B — subject to narrow use limits. While the industry is currently awaiting the EPA’s final rule on SNAP Rule 23, this new activity demonstrates that the EPA is continuing to evaluate new refrigerants and list additional substitutes — which is a positive step in the right direction for our industry.

But in the absence of federal regulations governing HFCs, many states have taken measures into their own hands. The U.S. Climate Alliance now consists of 25 member states that are taking the lead on climate policy and in general, refrigerant regulations. So far, the majority of those efforts have been through the adoption of SNAP Rules 20 and 21, which California was the first to adopt into state law via its California Air Resources Board (CARB) initiatives. And as we’ve discussed previously in this blog, additional CARB proposals are currently under review and being formulated with guidance and input from industry stakeholders.

Rajan also spoke about a pair of new bipartisan bills that have been introduced in the House and the Senate which would phase down the production and consumption of HFCs over a 15-year period in accordance with guidance from the Kigali Amendment to the Montreal Protocol. The passing of these companion bills — known as the Senate American Innovation and Manufacturing (AIM) Act of 2019 and the House American Innovation and Manufacturing Leadership (AIML) Act of 2020 — would authorize the EPA to regulate HFCs and establish standards for HFC management (service, repair, recovery, recycle, reclaim, etc.).

Both the AIM and AIML Acts would not affect existing equipment but would provide allowances for the aftermarket servicing needs of our industry. Their goals would be to preserve previous technological investments while supporting innovation and potential job creation.

As Rajan stated, by adopting a federal approach proposed by these bills, our industry would benefit greatly from much-needed regulatory consistency and certainty. It’s important to note that Emerson and its industry partners, such as the American Heating and Refrigeration Institute (AHRI), have pledged their support for these new bills. In addition, since these bills do not preclude states’ rights, efforts that have taken place in California and other states are still valid. While these states might be slightly leading in the refrigerant transition, our hope would be that the rest of the country would soon catch up and follow a standardized approach.

Why Refrigerant Leak Repair Still Matters

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

Proactive refrigerant management isn’t just good for the environment. It is also sound business practice. I was recently interviewed by ACHR’s The News magazine on the Environmental Protection Agency’s (EPA) partial rollback of Section 608 provisions for appliance leak repair and maintenance. You can read the full article here  and more on our perspective below.

Why Refrigerant Leak Repair Still Matters

In February, the EPA eliminated leak repair and maintenance requirements on appliances containing 50 or more pounds of substitute refrigerants, such as hydrofluorocarbons (HFCs). As a result, equipment owners are no longer required to:

  • Repair appliances that leak above a certain level
  • Conduct verification tests on repairs
  • Periodically inspect for leaks
  • Report chronically leaking appliances to the EPA
  • Retrofit or retire appliances that are not repaired
  • Maintain related records

But just because these leak repair provisions are no longer required doesn’t mean food retailers should ignore these best practices. There is a price to pay for refrigerant leakage that extends far beyond environmental damage. Detecting, repairing and even proactively reducing refrigerant leaks will help operators avoid a variety of associated costs.

The high cost of refrigerant leaks

The rollback of legal penalties for refrigerant leaks does not change the math on the operational costs. An average food retail store leaks an estimated 25 percent of its refrigerant supply each year, which can quickly add up to thousands of dollars in lost refrigerant. In addition, retailers must consider the maintenance and equipment costs. Persistently low levels of refrigerant can cause:

  • Excess compressor wear and tear
  • Reduced compressor and system capacities
  • Premature system failures
  • Double-digit efficiency losses

Left unchecked, even minor leaks can eventually lead to equipment failure. When this occurs, emergency repair costs are often only the tip of the iceberg. Operators may also be looking at revenue loss from food waste, business disruptions and reputational damage.

Proactive refrigeration management

So what can operators do to prevent leaks, even in the absence of federal requirements?

In the near term, they can — and should — implement rigorous leak detection and repair programs. Refrigerant leaks can occur anywhere in a system. Thus, an effective refrigerant leak detection program will combine monitoring, detection and notification.

Multiple technologies are available to support these efforts, including active and passive devices for monitoring and detection. Internet of things (IoT) capabilities allow for remote monitoring, enabling operators to focus on more pressing tasks. And with the integration of data analytics platforms, operators can uncover trends, identify persistent problem areas, and make informed choices about equipment upgrades and replacement options.

Over the longer term, operators can adopt refrigeration architectures that reduce the potential for refrigerant leakage in the first place. Legacy, centralized direct-expansion rack systems are high leak-rate offenders. That shouldn’t be a surprise; with thousands of feet of pipe, hundreds of joints and large refrigerant charges, there are many opportunities for leaks to occur.

In contrast, distributed micro-booster, indoor distributed and outdoor condensing unit (OCU) architectures experience lower leak rates by design. As an added benefit, they offer more options for lower-GWP alternative refrigerant use. This is a crucial advantage for operators who want to position their business for future regulations.

Sustainable best practices

The EPA’s Section 608 leak repair provisions were good for the environment. They are also part of a larger body of best practices for optimizing HVACR equipment. As states take the lead in adopting standards for leak detection and control, operators may find the rollback of these regulations to be short-lived.

Emerson is proud to take a lead in developing sustainable and cost-effective refrigeration systems and supporting technologies. Operators and original equipment manufacturers count on us to deliver strategies and solutions that anticipate emerging trends and regulations. From pioneering refrigeration architectures to refrigerant leak detection tools, we are committed to providing operators with the capabilities to meet their sustainability and operational goals today and into the future.

 

 

 

Refrigerant Regulations Update and Industry Trends

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

In the United States, the regulations governing the use of refrigerants in commercial refrigeration and AC applications remain in a state of flux. Our next E360 Webinar will take place on Tuesday, March 31 at 2 p.m. EDT/11 a.m. PDT and provide an update on the latest regulatory developments at the state and federal levels.

Refrigerant Regulations Update and Industry TrendsThe unpredictable nature of environmental regulations in the U.S. continues to be a source of great uncertainty in today’s commercial refrigeration and AC industries. While many countries around the world are following international guidelines set forth by the Kigali Amendment to the Montreal Protocol and the Paris Agreement, the U.S. has rolled back its former federal refrigerant regulations and has yet to participate in these multi-national climate measures.

However, at the state level domestically, things are evolving quickly. The California Air Resources Board (CARB) is moving forward with its stated 2030 deadline of reducing hydrofluorocarbon (HFC) emissions by 40 percent from the state’s 2013 baseline levels. While CARB is currently drafting specific proposals on how to achieve this goal, it’s clear that supermarkets and cold storage operators will soon need to accelerate their transition to new refrigerant alternatives that offer much lower global warming potential (GWP).

California is forging a path to long-term environmental sustainability that many other states are following. Currently, 25 states and provinces have joined the U.S. Climate Alliance — which represents 55 percent of the national population — and committed their leadership on climate change initiatives, including the reduction of HFCs. But with 25 governing bodies working toward similar goals, we’re already seeing the possibility of divergent regulatory approaches that would make it increasingly difficult for our industry to manage.

Meanwhile, both the House of Representatives and the Senate have introduced new bills that would give the Environmental Protection Agency’s (EPA) authority to regulate HFCs. With this dynamic mix of activities and new developments happening almost every week, it’s becoming more important than ever to stay informed. Our next E360 Webinar is dedicated to making sense of this turbulent regulatory climate and will provide you with guidance on how to prepare for the future.

This timely and informative E360 Webinar will take place on Tuesday, March 31 at 2 p.m. EDT/11 a.m. PDT. It will be hosted by Emerson’s leading experts on refrigerant regulations: Rajan Rajendran, vice president, systems innovation center and sustainability; and Jennifer Butsch, manager, regulatory affairs. Attendees will learn:

  • How CARB is building upon its Significant New Alternatives Policy (SNAP) ruling foundation with newly proposed HFC refrigerant phase-down efforts
  • How some U.S. Climate Alliance states are adopting the EPA’s SNAP Rules 20 and 21 on their own individual timelines
  • Status of the standards governing charge limits and safe use of A2L and A3 refrigerants, including the potential impacts on building codes
  • Availability of new low-GWP refrigerants
  • Update on the new federal HFC regulations introduced by the Senate and the House
  • New and emerging industry trends to watch closely

Register now for this informative and free webinar.

 

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.

 

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