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Posts tagged ‘Rajan Rajendran’

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.

 

[Webinar Recap] 8 Keys to Understanding the Ongoing Refrigerant Transition

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

Emerson Commercial & Residential Solutions

The transition to more environmentally friendly refrigerants in commercial refrigeration and air conditioning applications is underway all around the globe. In the United States, ever-evolving state and federal regulations are forcing industry stakeholders to pay close attention to the developments taking place in their regions. Regardless of your specific location or operational requirements, the use of hydrofluorocarbon (HFC) refrigerants is being phased down in favor of alternatives with lower global warming potential (GWP).

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I recently co-hosted an E360 Webinar with Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, to discuss the latest regulatory developments and industry trends driving this transition. For those who could not attend this informative session, you can view the webinar in its entirety. And if you need a primer for quickly understanding this transition, I developed the following list to highlight the key points of our discussion:

  1. The refrigerant transition is not new — In the 1980s, scientists discovered that chlorofluorocarbon (CFC) and hydrochlorofluorocarbon (HCFC) refrigerants — such as R-22 — were contributing to the depletion of the ozone layer. The Montreal Protocol Treaty was enacted in 1987 to ban the use of refrigerants with ozone depletion potential (ODP); since then, the hole in the ozone layer has steadily recovered. But the ban on these refrigerants led to the introduction of HFCs — such as R-404A and R-410A — which were then proven to cause global warming. As a result, the Kigali Amendment to the Montreal Protocol was established in 2016 to phase down the use of HFCs; it went into effect in 2019 for its 20 participating member countries.
  2. The transition is a global effort — Even before the Kigali Amendment went into effect, other global regions and countries established their own HFC phase-down regulations. The European Union’s F-Gas regulations, which went into effect in 2014, has led the way on establishing a framework for rulemaking. Environmental Canada enacted its own HFC rulemaking in 2017; many of its requirements went into effect this year.
  3. California takes initiative in the U.S. — In the absence of federal regulations, the California Air Resources Board (CARB) has introduced its own HFC phase-down measures, starting with the adoption of the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rules 20 and 21. In addition, it is currently working with industry associations and stakeholders to develop proposals to achieve additional GWP reductions by 2030. Many in the industry consider CARB’s proposals among the most ambitious in the world.
  4. States are joining the charge — Following California’s lead, many states have also committed to introduce climate change initiatives, including the reduction of HFCs. Currently, 25 members have joined the U.S. Climate Alliance, which now represents more than 55% of the U.S. population and an $11.7 trillion economy. A few member states have also adopted SNAP Rules 20 and 21 into law; however, each of these states has set forth varying implementation timelines, which will only add complexity to the national regulatory landscape.
  5. New federal regulations are on the horizon — To restore federal guidance pertaining to HFC phase-down regulations, both the Senate and the House have recently introduced new bills, respectively: The American Innovation and Manufacturing Act of 2019, and the American Innovation and Manufacturing Leadership Act of 2020. Both bills align with the HFC reduction goals established in the Kigali Amendment and would authorize the EPA to once again regulate HFCs and establish standards for HFC
    management (servicing, repair, recovery, recycle, reclaim, etc.). The general consensus throughout the industry is that a standardized federal approach would minimize compliance complexities created by a potential patchwork of state regulations.
  6. The next generation of refrigerants is already here — Many low-GWP alternative refrigerants not only have been developed already, they are being designed to replace HFCs commonly used in specific applications today. These refrigerants offer varying GWP ranges and cover the spectrum of refrigerant safety classifications, from A1 (non-flammable) to A2L (mildly flammable) to A3 (highly flammable) and B2L (toxic, mildly flammable). It’s important to point out that many of the lowest-GWP alternatives are classified as A2L, and thus will require equipment and facility redesigns to meet application and safety standards.
  7. Safety standards and codes are evolving — With the industry moving toward the use of flammable refrigerants, the technical committees and governing bodies who provide guidelines on how to safely use these refrigerants are actively updating safety standards. While these activities are ongoing, it’s important to remember that once established, these standards will take several years to make their way into both model and local codes needed to permit the widespread use of flammable refrigerants. The industry still has more work to do before that becomes a reality.
  8. System architectures are changing — This transition is ushering in a new era of system architectures. To utilize low-GWP refrigerants, reduce refrigerant charges and the potential for leaks, look for the commercial refrigeration industry to shift from traditional centralized systems toward more distributed approaches. Natural refrigerant architectures — such as CO2 transcritical booster and R-290 integrated cases — will also continue to expand. Manufacturers are utilizing familiar booster technologies and components to help end users transition to lower-GWP A1s today and even lower-GWP A2Ls in the future. In trials, these systems have provided significant energy savings with reduced installation costs and refrigerant charges.

To learn more details about any of these points, please view this informative webinar in its entirety.

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.

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