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[E360 Webinar Wrap-up] Refrigerant Rulemaking Recap: Regulatory Uptick Expected for 2021

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

Emerson’s Commercial & Residential Solutions Business

 

The commercial refrigeration and air conditioning sectors are currently experiencing an active period of refrigerant rulemaking. As we move through the first quarter of 2021, our industry is evaluating a variety of regulatory activities and climate initiatives — at both the state and federal levels — that govern the transition to lower global warming potential (GWP) refrigerants and the safe use of flammable alternatives. I recently co-hosted an E360 webinar with Jennifer Butsch, Emerson’s regulatory affairs director, to discuss current developments and explore their potential impacts on our industry. We were joined by Helen Walter-Terrinoni, vice president of regulatory affairs for the Air-Conditioning, Heating, and Refrigeration Institute (AHRI).

As global regulatory efforts to phase down the use of HFC refrigerants continue in earnest, the transition to alternatives with lower GWP is gaining momentum in the U.S. At the state level, California is preparing for its next phase of rulemaking, while more U.S. Climate Alliance states leverage the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rules 20 and 21 as the bases for their own environmental initiatives. In addition, a new presidential administration and the passing of new federal legislation represent significant shifts in U.S. regulatory dynamics — resuming our global participation in combating climate change and giving the EPA authority to govern HFCs.

But the progression of refrigerant rulemaking along both state and federal lines continues to create complexity for an industry that seeks guidance in understanding and applying an ever-evolving, complex mix of regulations.

California Air Resources Board (CARB) Seeks to Finalize Proposals

In 2019, California was the first state to adopt EPA SNAP Rules 20 and 21 in their entirety. Since then, CARB has developed additional proposals to meet its stated 2030 emissions-reduction targets. For commercial refrigeration, these proposed refrigerant regulations target the installation of new refrigeration systems greater than 50lbs:

  • 150 GWP limit for systems installed in new facilities
  • In existing facilities, food retailers must choose from one of the following company-wide reduction targets:
    • Reduce their weighted average GWP below 1,400
    • Achieve a 55% or greater reduction in their greenhouse gas potential (GHGp) below 2019 baseline levels by 2030
  • Other GWP limits for systems in existing facilities include a 750 limit for ice rinks and a 1500 – 2000 limit for industrial refrigeration

In air conditioning applications, the CARB proposal targets a 750 GWP limit across multiple end uses in the coming years:

  • 2023: room AC and dehumidifiers
  • 2024: AC chillers (consistent with SNAP Rule 21)
  • 2025: residential and commercial AC
  • 2026: variable refrigerant flow (VRF) systems

CARB has also introduced its Refrigerant Recycle, Recovery and Reuse (R4) program, which proposes new air conditioning equipment in 2023 and 2024 to use reclaimed R-410A refrigerant in an amount equal to 10% of equipment operating charge in California. In addition, CARB has stated that it will expand its R4 program by introducing new rulemaking this year.

U.S. Climate Alliance States Adopt Legislation

Among the 25 member states that have joined the U.S. Climate Alliance, nine have finalized legislation for adopting SNAP Rules 20 and 21 into law. Like the original EPA rules, the timings of enforcement dates are end-use specific and designed to be phased in over several years. But because the start dates of these rules differ among the nine member states, our industry faces an increasingly complex patchwork of compliance schedules.

As Walter-Terrinoni pointed out in the webinar, the prospect of new federal legislation may give these and other states the option to pursue a consistent, nationwide approach to the refrigeration phase-down. States could place their focus on the local level, where they can further the advancement of building codes and safety standards.

Federal HFC Phase-down Takes AIM

Regulatory activity is also picking up at the federal level, starting with the EPA’s proposed SNAP Rule 23, which reaffirms its commitment to approve low-GWP refrigerants. The proposal lists several mildly flammable (A2L) refrigerants, including R-452B, R-454A, R-454B, R-454C, R-457 and R-32 as acceptable, subject to use conditions in new residential and light commercial air conditioners and heat pumps. For retail food refrigeration — medium-temperature, stand-alone units — SNAP Rule 23 lists A1 refrigerants R-448A, R-449A and R-449B as acceptable, subject to narrowed use limits. Emerson and other industry stakeholders have asked for further clarification on these restrictions, as these A1s have already been listed as acceptable without limitations in many other commercial refrigeration applications.

As part of major pandemic relief legislation, the American Innovation and Manufacturing (AIM) Act was passed and signed into law in late 2020. This legislation gives the EPA the authority to phase down HFC production and consumption limits in a manner consistent with the Kigali Amendment to the Montreal Protocol within nine months. It also authorizes the EPA to regulate HFCs through sector based rulemaking and establish standards for HFC management — servicing, repair, recover, recycle and reclaim — similar to CARB’s R4 program. This is welcome news for our industry, as it paves the way for a federally guided, low-GWP refrigerant transition, which would minimize the complexities of differing state-led regulations.

Under the new Biden administration, the U.S. has rejoined the Paris Agreement and is taking steps to ratify the Kigali Amendment. These are among many early indications of this administration’s commitment to combat climate change at home and abroad.

A2L, A3 Standards and Codes Progress

With the industry moving toward the use of flammable A2L and A3 refrigerants to achieve lower-GWP goals, the technical committees and governing bodies who provide guidelines on how to safely use these refrigerants and related equipment are currently updating their safety standards. Among the updates that many are closely watching are the proposed changes to the Underwriter’s Laboratory (UL) 60335-2-89 standard, which would increase the charge limits in self-contained and remote refrigeration applications. While the industry expects this proposal potentially to be finalized by the end of the year, it’s important to remember that once established, these standards will take several years to make their way into the building codes and local standards needed to permit the widespread use of flammable refrigerants.

To learn more details about each of these important regulatory developments, please view our on-demand webinar.

Proposed EPA SNAP Rule 23 Addresses A2L, HFO Refrigerant Use

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

Emerson’s Commercial & Residential Solutions Business

In May, the Environmental Protection Agency (EPA) pre-published Rule 23 of its Significant New Alternatives Program (SNAP), which proposed approving (or listing) multiple substitute refrigerants for commercial refrigeration and air conditioning equipment. Overall, the HVACR industry was pleased to see the EPA actively evaluating the use of lower-global warming potential (GWP) refrigerants, although many stakeholders have sought clarifications on several aspects of the proposal. I recently provided Emerson’s perspective on the proposed SNAP Rule 23 for an article that was published in ACHR The NEWS.

Per normal rulemaking protocols, the EPA accepted public comments on the proposed rule to give equipment manufacturers and industry associations opportunities to submit their thoughts and concerns. Like many industry stakeholders, Emerson expressed our appreciation to the EPA for once again approving new low-GWP refrigerants. As I stated in the article, the HVACR industry relies on federal guidance to provide regulatory consistency across the U.S. — rather than allowing states to assume that role — and SNAP Rule 23 is a continuation of the EPA’s efforts to provide that much-needed guidance.

New A2L listings for AC applications

The SNAP Rule 23 proposal lists several mildly flammable (A2L) refrigerants, including R-454B and R-32, as acceptable, subject to use conditions in new residential and light commercial air conditioners and heat pumps. Other A2Ls listed as acceptable in these applications include: R-452B, R-454A, R-454C and R-457A. The rule also lists R-32 as acceptable, subject to use conditions for new self-contained air conditioners that are typically used for comfort-cooling applications (e.g., rooftop units, water-source heat pumps and ground-source heat pumps) and split systems.

For industry stakeholders, this proposal is an indication that the EPA is likely to move towards approving A2L refrigerants in comfort-cooling applications where applicable safety standards — developed by the Underwriters Laboratory (UL) and the American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE) — are now in place to govern the safe use of A2Ls in these applications. As the development of A2L safety standards for commercial refrigeration is still ongoing, it is important to remember that the SNAP Rule 23 proposal does not yet include recommendations for the use of A2Ls in commercial refrigeration.

With respect to A2Ls, Emerson and other industry stakeholders questioned why the SNAP Rule 23 proposal did not also recommend these newly approved refrigerants for use in positive displacement chillers. From Emerson’s perspective, we welcome new low-GWP options for residential and light commercial air conditioning applications and would like to see substitutes such as A2L refrigerants used to replace R-410A for positive displacement chillers.

Narrowed use of R-448A and R-449A in commercial refrigeration

In terms of Emerson’s other concerns on the SNAP Rule 23 proposal, we are seeking clarification on the narrowed use limits placed on R-448A, R-449A and R-449B in stand-alone, medium-temperature commercial refrigeration units. Today, these hydrofluoroolefin (HFO) refrigerants are used broadly across many applications and provide the flexibility to meet various design requirements. It is our hope that we could potentially remove unnecessary restrictions and/or simplify the guidelines for using these refrigerants within these applications.

Other prominent stakeholders also objected to the EPA’s proposed use limits of these HFO refrigerants, noting that they impose an unnecessary burden on the industry’s transition away from high-GWP refrigerants. R-448A, R449A and R-449B have already been listed as acceptable without these limitations in many types of applications, including: low-temperature, stand-alone equipment; remote condensing units; supermarket systems; and cold storage warehouses.

Overall, Emerson sees the SNAP Rule 23 proposal as a positive step in the right direction for both the EPA and our industry. Considering the global initiative to phase down higher-GWP, hydrofluorocarbon (HFC) refrigerants, the approval of new lower-GWP alternatives will give manufacturers the confidence to move forward with plans to integrate these approved refrigerants into their product development lifecycles.

 

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.

Emerson Celebrates and Sponsors World Refrigeration Day 2020

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

Emerson Commercial & Residential Solutions

June 26 is the second annual celebration of World Refrigeration Day. The event, which memorializes the birth date (June 26) of Lord Kelvin for whom the Absolute temperature scale is named, was started last year to raise visibility, awareness and understanding of the significant role that the refrigeration, air-conditioning and heat pump (RACP) sector plays in modern life and society.

Emerson Celebrates and Sponsors World Refrigeration Day 2020

This year’s theme, “Cold Chain 4 Life,” aims to make the public, policy makers and end-users aware of technology, food waste/loss, human health and comfort, environment and energy considerations associated with the cold chain. The campaign strives to motivate adoption of best practices to minimize food waste/loss in the supply chain, stimulate wise technology selections and enhance operations to minimize leakage of refrigerants and maximize energy efficiency.

As part of its celebration, we will host a live trivia event on our Copeland™ Facebook page at 2 p.m. EDT / 11 a.m. PDT that day (June 26). The trivia questions will be related to the commercial refrigeration and air conditioning industry, Emerson company history and product knowledge. Participants who answer correctly will have the chance to win Emerson items, including genuine Copeland brand t-shirts and a $100 Amazon.com® gift card for the grand-prize winner.

On World Refrigeration Day and every day, we are committed to advancing innovation by actively engaging with industry leaders to address the many challenges the industry is facing — including evolving environment-related regulations; climate change awareness; human health and comfort; the growing ubiquity of digital technologies; food safety and quality needs; and the never-ending energy efficiency and operating cost concerns.

By actively participating in organizations such as Air-Conditioning, Heating & Refrigeration Institute (AHRI), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), Global Food Cold Chain Council (GFCCC), European Partnership for Energy and the Environment (EPEE), and Council for Harmonization of Electrotechnical Standards of the Nations of Americas (CANENA), we play a strategic role in understanding and interpreting the ever-changing landscape of international, national and state-level regulations. Most recently, our experts have been supporting initiatives to explore more globally friendly refrigerants through participation in the AHRI Safe Refrigerant Transition Task Force established in April 2019. The task force was established with the goal of evaluating and in turn enabling safe and reliable use of low-GWP refrigerants. Whether it’s energy efficiency or the transition to lower GWP refrigerants, we are uniquely positioned to help guide and support our customers in overcoming these complexities, not only on World Refrigeration Day, but all year long.

For more information on World Refrigeration Day, visit www.worldrefrigerationday.org.

5 Earth Day Steps to Greener Refrigeration

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

Emerson Commercial & Residential Solutions

Every year on April 22, nations around the globe pause to recognize Earth Day and reflect on the importance of preserving the planet’s environment. This year will mark the 50th anniversary of the annual Earth Day commemoration; its theme is “climate action”. According to the organization’s website, “Climate change represents the biggest challenge to the future of humanity and the life-support systems that make our world inhabitable.” Thus, action is essential for mitigating the damaging impacts of climate change.

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For decades, the commercial refrigeration industry has taken a global focus on climate action. In 1987, the Montreal Protocol set out to ban the use of refrigerants with ozone depletion potential (ODP) — and as of today, these efforts have proved extremely effective. But in 2020, our industry has a new environmental mandate: to phase down the use of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP). The Kigali Amendment to the Montreal Protocol was enacted to do just that; since 2019, 20 countries are participating in these measures. At the same time, other countries have adopted their own HFC phase-down regulations, and states like California are leading the charge here in the United States.

But while the environmental focus is often on refrigerants, it’s important to understand that refrigeration must be evaluated from its total equivalent warming impact (TEWI), which considers both the impacts of refrigerants and the energy efficiency of a system throughout the lifecycle. For decades, Emerson has been committed to promoting sustainable and environmentally friendly refrigeration. Here are five best practices that we promote to achieve greener refrigeration strategies.

  1. Recommission your refrigeration system. Over time, refrigeration systems can drift steadily from their original commissioned performance baselines. It’s important to make sure systems are operating as efficiently as possible before considering any upgrades such as replacing a compressor. Recommissioning returns the system back to its original operating parameters and establishes a necessary baseline from which ongoing improvements can be made.
  2. Implement an energy measurement and verification (M&V) program. The decision to upgrade or replace a compressor must be evaluated from a holistic assessment of the refrigeration system. To gain deeper insights into system performance, we recommend implementing a formal measurement and verification program in tandem with the recommissioning process. An M&V program helps to identify holistic system energy-efficiency data and evaluate individual compressor performance, which operators can use to potentially qualify for an energy incentive program. Participating utilities may offer rebates for replacing inefficient equipment with newer, energy-efficient models.
  3. Retrofit to variable-capacity modulation. After identifying the low- and medium-temperature compressors that are underperforming, the next step would be to upgrade them to enable a variable-capacity compression strategy — either by upgrading to a digitally modulated compressor or adding a variable frequency drive (VFD). Replacing even one fixed-capacity compressor with a variable-capacity digital compressor can result in significant benefits, such as: improved energy efficiencies, precise matching of capacity to changing refrigeration loads, improved case temperature precision, reduced compressor cycling (on/off), and tight control over suction manifold pressures.
  4. Enable low-condensing operation. One often overlooked strategy — which is also factoring into some environmental regulations — is the practice of low-condensing operation (aka floating the head pressure). Instead of operating at a high fixed head pressure regardless of the ambient temperature, low-condensing operation floats the head pressure down as the ambient temperature drops — in the evening, overnight and early morning hours. This best practice utilizes electronic expansion valves (EEVs) that allow for dynamic control so that the system is no longer operating at maximum capacity during periods of cooler ambient temperatures. As a result, compressor capacity increases while wattage consumed decreases. In fact, operators can realize lower costs through energy efficiency ratio (EER) improvements of 15–20% for every 10 °F decrease in head pressure.
  5. Transition to lower-GWP refrigerants. Preparing for the future of refrigeration means transitioning from higher-GWP HFC refrigerants to lower-GWP alternatives. Of course, doing so will require adopting new refrigeration technologies and system architectures. From self-contained, integrated cases which utilize natural, hydrocarbon refrigerants to proven CO2 transcritical booster systems and new distributed micro-booster systems that use lower-GWP refrigerants with familiar operating properties, there are a wide variety of emerging systems capable of addressing the full range of commercial refrigeration applications.

Emerson is committed to developing innovative refrigeration technologies and helping commercial refrigeration stakeholders adopt more sustainable refrigeration strategies. We’re actively developing solutions that address all the best practices listed above, and we’re working to promote future refrigeration technologies that will help our customers meet their unique sustainability goals.

 

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