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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.

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.

How Emerson Is Taking on Today’s Most Pressing Refrigeration Challenges with Copeland Scroll ™

Phil Moeller | Vice President – Product Management, Refrigeration
Emerson Commercial & Residential Solutions

Since its introduction nearly 30 years ago, the Copeland Scroll has revolutionized the standards for refrigeration performance and reliability. An article from the E360 Product Spotlight provides an overview of Emerson’s recent innovations for the Copeland Scroll. Click here to read the article in its entirety.

How Emerson Is Taking on Today’s Most Pressing Refrigeration Challenges with Copeland Scroll ™

The commercial refrigeration industry has changed drastically in recent years due to new regulations and consumer trends. Operators demand an ever-widening spectrum of applications, from large centralized systems to small walk-in freezers and coolers. Energy efficiency and environmental sustainability have become business priorities. And digital technologies promise connected, predictable visibility to refrigeration systems.

That’s why Emerson’s research and development (R&D) teams for Copeland Scroll have come up with innovative technologies that optimize performance and reliability, helping you take on these emerging challenges.

Innovations that bring more power, flexibility and advanced capabilities to the Copeland Scroll lineup

Wider application and temperature ranges: We’ve expanded the ranges of commercial applications for Copeland Scroll compressors, now spanning fractional ¾ horsepower ZF*KA compressors designed for low temperatures up to the 17 horsepower K5 compressor for low- and medium-temperature applications. You’ll find a variety of solutions within this horsepower range for your low-, medium- and extended medium-temperature applications.

Inherently robust product designs: Minimalistic, fully hermetic Copeland Scroll designs use up to 70 percent fewer moving parts than semi-hermetic, reciprocating compressors. That means they have no complex suction and discharge valves; can start under any system load; eliminate many vibration issues; improve liquid and debris handling; and, with their compact and lighter-weight designs, make servicing easier.

Energy compliance: Original equipment manufacturers (OEMs) rely on Copeland Scroll technology to help meet the Department of Energy’s annual walk-in efficiency factor (AWEF) ratings for walk-in coolers and freezers. Copeland Scroll’s inherent efficiency and reliability are the foundation of AWEF-compliant condensing units in leading OEM equipment design strategies.

Alternative, lower-GWP refrigerants: The Copeland Scroll lineup includes many compressors rated for use with lower-GWP synthetic and natural refrigerant alternatives. We continue to evaluate and test emerging refrigerants to help operators achieve their performance and sustainability goals.

Performance-enhancing technologies: Emerson R&D teams for Copeland Scroll lead the industry in rolling out performance-enhancing innovations, from digital modulation capabilities to liquid- and vapor-injection options and lower condensing operation. These technologies improve system reliability and capacity while meeting today’s demanding regulatory requirements.

Smart diagnostics and protection: Today, many Copeland Scroll compressors are equipped with on-board CoreSense™ Diagnostics. CoreSense provides advanced motor performance monitoring and protection, diagnostics, power consumption measurements and communication capabilities. Other compressors can be retrofitted with our panel-mounted, remote diagnostic systems. This active protection technology is driven by advanced algorithms and fault detection logging and histories, helping enable technicians to quickly diagnose and repair systems.

Product development partnerships: As an Emerson customer of Copeland Scroll, you have access to Emerson’s extensive capabilities to support your own product development efforts, collaborating with us on application engineering; design, testing and certification services; proof of concept; and application development.

Closer ties to the industry’s largest support network: Copeland Scroll compressors are backed by a network of more than 1,000 Copeland-authorized locations and over 600 certified Copeland technical specialists — a base of operations that can quickly deliver the products and technical assistance you need. Our new, fully featured Copeland™ Mobile app connects to the Emerson Online Product Information database for on-the-go access to 30 years of compressor products and specifications. It can help you quickly troubleshoot and diagnose issues and connect to our wholesaler network to check local availability of replacement products.

 

With a legacy of innovation and an eye toward the future, you can be sure that Emerson will continue to evolve to meet today’s rapidly changing commercial refrigeration requirements. To learn more about our innovations and emerging technologies, read the full E360 article.

 

Evaluating Sustainable Supermarket Refrigeration Technology

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

Emerson Commercial & Residential Solutions

Progressive Grocer recently interviewed me about Emerson’s and the commercial refrigeration industry’s efforts to help promote the emergence of more sustainable, refrigeration technologies. The complete article can be found here.

Evaluating Sustainable Supermarket Refrigeration Technologyd

It’s not news that supermarkets are under continuous regulatory pressure to not only lower the energy demand of their refrigeration systems, but also to make the transition to low global warming potential (GWP) and zero ozone depletion (ODP) systems. The permanent ban on R-22, long the industry standard, becomes official on January 1, 2020.

What is news is how intensely suppliers and retailers are focused on and sharing information on sustainability initiatives intended to sharply reduce the costs and impact of their refrigeration systems, both in anticipation of future regulations and to attain long-term economic and environmental sustainability.

As different manufacturers approach these issues with a variety of new technology options, the challenge becomes defining new standards for sustainable products and systems, so that the industry can converge on proven, synergistic solutions.

Taking a full system’s approach to sustainability

At Emerson, our approach to sustainability is based on a multi-faceted goal. First, sustain the environment through lower-GWP refrigerant and technology choices. Second, sustain companies financially from a total cost of ownership perspective. And third, focus on energy efficiency as a path to sustainability through forward-looking engineering and the implementation of new monitoring and control technologies, particularly Internet of Things (IoT) capabilities.

At Emerson, we take a full system approach to evaluate the sustainability of new and existing technologies in the context of multiple key selection criteria. This is part of Emerson’s “Six S’s” approach to refrigeration sustainability: simple, serviceable, secure, stable, smart and sustainable.

(To learn more about the rationale, methodology, application and impact of Emerson’s “Six S’s” philosophy, read the blog found here.)

Exploring the potential of natural refrigerants

One area of Emerson’s focus is our work to better understand and then implement emerging natural refrigerants, such as R-744 (carbon dioxide) and R-290 (propane) for different types of applications.

Recent innovations include the development of an integrated display-case architecture. This R-290 system is designed to use one or more compressors and supporting components within cases, removing exhaust heat through a shared water loop — incorporating our expertise in R-290 compressors and our experience with stand-alone condensing units. We’ve also developed a full range of CO2 system technologies, including valves and controls for both small and large applications. For cold storage applications, our modular refrigeration units utilize both CO2 and ammonia-based refrigerant configurations.

Early adopters pave the road to the future

Over the past decade, there have been many retailers committed to testing sustainable refrigeration technologies and low-GWP refrigerants in their stores. For example, the article quoted Wayne Posa of Ahold Delhaize USA, who discussed the company’s transition from R-22, stating: “Food Lion has been committed to zero-ODP and low-GWP refrigerants for several years.”

Different manufacturers are taking different approaches to studying and applying refrigerants and technologies to reach that goal, from the use of hydrofluoroolefin (HFO) refrigerants (such as R-448A and R-450) in distributed refrigeration systems to proven CO2-based system architectures.

In the area of refrigerants — let alone technologies in development for increased energy efficiency and remote monitoring and control — the refrigeration industry continues its search for a new standard. As Brian Beitler of Coolsys, a consulting and contract engineering firm explains, “Between transcritical, ejector systems, NH3 over CO2, cascade, propane, multidistributed and hybrid gas coolers, the jury is still out.”

As we move closer to the most sustainable standard for refrigerants, Emerson continues its work on total refrigeration system sustainability — in refrigerants, energy efficiency, and control — as guided by our “Six S’s” philosophy. This work is our road map to the future.

 

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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