Skip to content

Posts tagged ‘SNAP’

Refrigerant Regulations: 2018 Recap and 2019 Impacts

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

Emerson Commercial & Residential Solutions

The year 2018 brought many changes to refrigerant regulations, with additional activity expected in 2019 and beyond. This blog highlights some of the key developments, which were presented in a recent E360 article. Read the full article here.

 

The regulation of refrigerants continues to be a source of great uncertainty in the commercial refrigeration industry. As global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants in recent years, some in the industry have begun the transition toward alternative refrigerants with lower global warming potential (GWP). But these environmentally friendly options raise additional questions about performance and safety.

All in all, it’s a complex regulatory mix that got even more complicated in 2018. But we’re here to recap recent events and place them into a larger context.

The status of EPA SNAP Rule 20

In 2017, the U.S. District Court of Appeals for the D.C. Circuit ruled to vacate the Environmental Protection Agency’s (EPA) Significant New Alternative Policy (SNAP) Rule 20. The court ruled that the EPA did not have authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS) — and thus could no longer enforce its 2015 GWP-based mandates.

In the absence of Rule 20, the commercial refrigeration industry has many questions about what the path toward a more sustainable and environmentally friendly future for refrigerants will look like. Industry calls to overturn the District of Columbia Court of Appeal’s decision were declined by the Supreme Court, which stated it would not hear the HFC case1. Currently, the EPA is drafting new regulations that will clarify its plans to move forward with SNAP. We anticipate details on their position early this year.

EPA rescinds other HFC-related regulations

The EPA has also indicated that it will no longer enforce refrigerant delistings and has proposed to roll back other HFC-related regulations2. In particular, the EPA has proposed excluding HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA.

California adopts Rule 20 as the basis for its initiatives

Regulatory uncertainty at the federal level is not preventing states from adopting their own refrigerant regulations and programs. California Senate Bill 1383, aka the Super Pollutant Reduction Act, was passed in 2016 and requires that Californians reduce F-gas emissions (including HFCs) by 40 percent by 20303. The California Air Resources Board (CARB) has been tasked with meeting these reductions.

Since 2016, CARB had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. Even after SNAP Rule 20 was vacated, CARB moved to adopt compliance dates that were already implemented or upcoming. The passing of California Senate Bill 1013 — aka the California Cooling Act — in Sept. 20184 mandates the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017. The law is currently in effect and does not require additional CARB rulemaking to uphold compliance dates.

CARB is also proposing an aggressive second phase of rulemaking that would further impact commercial refrigeration and AC applications. CARB has held public workshops and invited industry stakeholders to comment on the details of this proposal.

Meanwhile, many other states have announced their plans to follow California’s lead on HFC phase-downs. The U.S. Climate Alliance, formed in 2017 out of a coalition of 16 states and Puerto Rico, is committed to reducing short-lived climate pollutants (SLCPs), including HFCs. Among these alliance states, New York, Maryland, Connecticut and Delaware have announced plans to follow California’s lead on HFC phase-downs.

Refrigerant safety standards and codes under review

Many of the low-GWP, hyrdrofluoroolefin (HFO) refrigerants are classified as A2L, or mildly flammable. R-290 (propane) is also becoming a natural refrigerant option for many low-charge, self-contained applications. Currently, national and global governing agencies are evaluating the standards that establish allowable charge limits and the safe use of these A2L and A3 refrigerants.

Internationally, the International Electrotechnical Commission (IEC) has proposed increasing charge limits for refrigeration systems in IEC60335-2-89 as follows:

  • A2Ls — from 150g to 1.2kg
  • A3s — 500g for factory-sealed systems, and will remain at 150g for split systems

These proposals are still under review and will likely be published sometime in 2019.

Kigali Amendment took effect on Jan. 1

The regulatory uncertainty in the U.S. can sometimes obscure international efforts underway to phase down HFCs. The Montreal Protocol has led the way on this effort for nearly a decade5. In 2016, 197 countries met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. Known as the Kigali Amendment, this treaty has been ratified by 53 countries (including the E.U.) and took effect on Jan. 1 for participating countries. The U.S. is still considering ratification.

As we move into 2019, there are many moving pieces on the regulatory chess board, but also some encouraging signs of progress. We will be providing the very latest regulatory updates in our next E360 Webinar. Register now to stay informed.

  1. https://www.achrnews.com/articles/140040-supreme-court-declines-to-hear-hfc-case
  2. https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations
  3. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383
  4. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB1013
  5. https://en.wikipedia.org/wiki/Montreal_Protocol#Hydrochlorofluorocarbons_(HCFCs)_Phase-out_Management_Plan_(HPMP)

[New E360 Webinar] Regulatory Update: Learn the Latest Rulemaking on Refrigerants

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

Emerson Commercial & Residential Solutions

Join us for our next E360 Webinar that will take a look at the latest refrigerant regulations impacting commercial refrigeration and AC applications on Tuesday, February 26 at 2 p.m. EST/11 a.m. PST for this informative update.

One of the greatest sources of uncertainty in today’s commercial refrigeration and AC industries is the topic of refrigerants. Regulations continue to evolve quickly, primarily aimed at phasing down the use of hydrofluorocarbon (HFC) refrigerants with higher global warming potentials (GWP), which are used in many applications. What’s particularly challenging is how these rules can differ from state to country to region, making it difficult to adopt a common standard.

Globally, these efforts are spearheaded by the Kigali Amendment to the Montreal Protocol, an international treaty in which participating countries are working toward a shared goal of HFC phase-down via mutually agreed upon timelines. In the U.S., the regulatory climate continues to be unpredictable, but states such as California are leading the charge on establishing regulatory standards.

With new updates taking place seemingly every month, it’s becoming increasingly difficult to stay informed. That’s why we’re dedicating our next E360 Webinar to clearing the confusion in this turbulent regulatory climate. This webinar will be hosted by Emerson’s leading experts on refrigerant regulations: Rajan Rajendran, vice president, systems innovation center and sustainability; and Jennifer Butsch, regulatory affairs manager, air conditioning. Jennifer will present the latest updates to the refrigerant rulemaking while Rajan will offer his extensive insights on how to prepare for what’s on the horizon.

Attendees will learn:

  • How recent rulings have changed the scope of the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) program
  • How the California Air Resources Board (CARB) continues to leverage the original SNAP ruling as the foundation for its regional HFC refrigerant phase-down efforts
  • An update on the potential for U.S. ratification of the Kigali Amendment to the Montreal Protocol
  • Status of the standards governing charge limits and safe use of A2L and A3 refrigerants, including the potential impacts on building codes
  • How the vacating of SNAP Rule 20 potentially impacts Section 608 in terms of governing leak repair and maintenance requirements
  • Availability of new low-GWP refrigerants

Register now for this informative and free webinar.

Commercial Refrigeration Industry Prepares for Next Generation of Refrigerants

217-P-E360_Compass_ART5

The commercial refrigeration industry is at a crossroads. In one direction, the Environmental Protection Agency (EPA) is proposing to ban many commonly used refrigerants in favor of low-GWP alternatives. In the other direction, the Department of Energy (DOE) is mandating significant reductions in energy consumption for reach-ins, walk-ins and ice makers by 2017. If that wasn’t challenging enough, the two regulations at times conflict — with the DOE’s new standards based on the EPA’s delisted refrigerants.

Read more

Inaugural E360 Forum Provides Important Exchange of Information

We recently held our very first E360 Forum in Columbus, Ohio, to discuss the refrigeration challenges facing the foodservice industry today. Judging by the number of attendees and the tenor of the conversations that took place, it is clear that our industry is seeking an outlet to discuss the impending regulatory changes and offer insights on how refrigerated system design will be impacted in the near future.

The event was kicked off with an informative keynote address about foodservice trends and equipment by Robin Ashton, president and publisher of Foodservice Equipment Reports. Mr. Ashton informed attendees that refrigeration makes up the largest segment of equipment in the foodservice market, and that while operators are extremely concerned about the Department of Energy’s upcoming efficiency regulations, energy efficiency itself is still not among the most important considerations when selecting equipment. Ashton did, however, forecast an upward cycle for the foodservice equipment market over the next few years.

Robin Ashton in E360 Forum

Emerson’s Dr. Rajan Rajendran then took the floor to discuss the volatile state of refrigerant regulations. Rajan provided a brief history of refrigerant evolution, initially introduced by the Montreal Protocol to lower global warming potential (GWP) with the phase-down of HFC-based refrigerants, and most recently driven by the European Union’s and the Environmental Protection Agency’s (EPA) motions to restrict GWP in refrigerants even further. In particular, the EPA will create a new ruling in 2015 as a part of its significant new alternatives proposal (SNAP) to delist some of the most common refrigerants in use today.

Rajan Rajendran in E360 Forum

Rajan indicated that 404A will likely be delisted, and then explored what these changes mean to equipment design. Finally, he raised the question to which everyone is seeking an answer: “Which refrigerant will the industry use as a replacement?” While there is no one-size-fits all solution, the re-emergence of CO2, propane and other natural refrigerants, and the introduction of synthetic blends with similar pressure characteristics provide the hope for minimal system redesigns. Attendees were most concerned about the potential impacts to system design.

The two keynote addresses set the tone for the day’s remaining six breakout sessions. As topics ranged from retrofit strategies and meeting DOE energy compliance to CO2 system architecture and kitchen design trends, the regulatory landscape framed the discussions. Information was readily exchanged between moderators and attendees, and the event provided ample opportunities to ask questions and interact with peers. Clearly, not all questions could be answered and addressed in a day. But our intent to create an interactive dialogue to help define the path forward in refrigeration had been achieved

E360 Forum  in Columbus Ohio

Our next E360 Forum will pick up the conversations where these left off. To be held at the Embassy Suites Anaheim — South on February 18 in Anaheim, California, these important discussions will take place in conjunction with the North American Association of Food Equipment Manufacturers (NAFEM) show starting on February 19. We hope to see you there. We need everyone’s contributions to help shape the future of refrigeration.

EPA Releases Proposed Timeline for HFC Status Changes

Earlier this year I reported the EPA’s intention to move on the delisting of certain hydroflourocarbons (HFCs) and HFC blends this summer. That process is now officially underway. On July 9, the EPA released the prepublication version of a Notice of Public Rule (NOPR) detailing proposed changes in listing status, tentatively scheduled to take effect as early as January 1, 2016.

The proposed rule is part of the Significant New Alternatives Policy (SNAP) program, which evaluates and revises acceptable alternatives to ozone-depleting substances (ODS) on an ongoing basis. A 60-day comment period for industry stakeholders begins once this NOPR is published in the Federal Register.

Key points in the rule include bans on R-404A and R-507A for new and retrofitted retail food refrigeration, including direct and indirect supermarket systems and walk-in cooler/freezer condensing units. It also proposes bans on R-404A, R-507A and HFC-134a in new, stand-alone refrigeration units and vending machines. Other blends to be delisted as unacceptable for direct and indirect supermarket systems include: HFC-227ea, R-407B, R-421B, R-422A, R-422C, R-422D, R-428A and R-434A.

These changes are intended to drive the market to refrigerants with lower global warming potential (GWP). In the near term, the industry will move toward already-tested, available alternatives, such as R-407A, carbon dioxide (CO2) or R-290, depending on the application. The proposed rulemaking will also accelerate the exploration of emerging alternatives, such as R-448A, R-449A, R-450A and XP10, etc.

Emerson Climate has been actively participating in meetings and discussions with the EPA and industry organizations and will continue to do so throughout the commenting process. It is essential that the move to low-GWP refrigerants continues to progress. But it is also important the rulemaking strikes a balance that accounts for the infrastructure changes and resources necessary to support the transition in an effective, commercially viable manner.

We will continue to work proactively on alternatives to make sure you have access to the products and services you’ll need to remain compliant with SNAP. In many cases viable substitutes are already approved and ready for application. We continue to work on developments that will not only meet this NOPR, but keep you compliant with foreseeable future rulings.

We welcome and encourage your participation and feedback throughout the commenting period. We’ll cover the proposed changes and discuss their implications in more detail in our Making Sense webinar on August 26. Click here to register.

For specific details of the proposed changes, review the Rule and Fact Sheet published by the EPA. Check back here for further updates as new information becomes available. We believe the final rule can be expected sometime in late November or early December.

Rajan Rajendran, Ph.D
Vice President, System Innovation Center and Sustainability
Emerson Climate Technologies

%d bloggers like this: