As Jennifer Butsch and I discussed in our most recent E360 Webinar, the California Air Resources Board (CARB) has adopted the Environmental Protection Agency’s (EPA’s) Significant New Alternatives Policy (SNAP) regulations 20 and 21. ACHR NEWS, which attended our webinar and CARB’s most recent public stakeholder meeting, has compiled a report on the implications of CARB’s hydrofluorocarbon (HFC) phase-down efforts. Below is a synopsis of their article, which you can read here in its entirety.
In early March, CARB held its first of several public technical working group meetings of the year. While the focus of this workshop was on stationary AC equipment, the scope of the issues discussed also extended to matters impacting commercial refrigeration. The purpose of these meetings is to gain insights into the many questions surrounding the implementation of its current and future regulations governing the state’s HFC phase-down. In this session, CARB posed several questions related to equipment costs, refrigerant leaks, the intersection with energy efficiency regulations and incentives for making the transition to lower-GWP refrigerants. And while these questions were targeted to California stakeholders, their relevance extends to the larger United States, where it is estimated that a federal mechanism to phase down HFCs will eventually be reinstated.
First costs, installation and maintenance
As we discussed in our most recent webinar, the commercial refrigeration sector is where the industry will continue to experience a proliferation of refrigeration systems. But this presents a series of challenges for OEMs and component manufacturers as we attempt to balance refrigerant GWP limits with economic viability — with hopes to minimize first costs, install costs and long-term service expenses of new equipment.
Opinions about cost considerations varied at the CARB meeting, though attendees generally agreed that first costs on AC equipment could range from 5 to 15 percent in various categories of equipment. CARB estimated that install and maintenance costs could increase anywhere from 5 to 10 percent, especially considering the need for additional contractor and technician training and tools to work with lower-GWP refrigerants such as A2Ls.
Factoring energy into the equation
For OEMs, meeting CARB’s GWP limits is only one of the regulatory milestones they will face in the next few years. The Department of Energy’s (DOE’s) new energy efficiency requirements are scheduled for 2023, which means OEMs need to factor both energy-related equipment upgrades and the refrigerant transition into their design cycles. This was another topic of debate at the CARB meeting.
CARB members suggested that OEMs could try to offset upgrade expenses and achieve economies of scale by combining design cycles. Representatives from the Air-Conditioning, Heating and Refrigeration Institute (AHRI) took the position that these upgrades would require separate efforts. To help CARB understand the implications of these scenarios, AHRI cited survey data in which its members considered the costs of efficiency upgrades before addressing required refrigeration changes.
Leak reduction and prevention
Meeting attendees reached a consensus when discussing the problem of refrigerant leaks. As an AHRI representative pointed out: none of California’s GWP targets will be attainable if the industry can’t figure out this critical issue. They cited a UN Environmental Program report that estimated up to 60 percent of GWP sources from HVACR equipment can be traced to leaks.
And as we reported in our recent webinar, supermarkets that in the EPA’s GreenChill program have achieved drastically reduced leak rates, sometimes more than 50 percent. It’s also a reminder that as California and the rest of country continue their transitions to lower-GWP refrigerant alternatives, proper reclamation, recycling and disposal of HFCs will be extremely important.
When the California Senate Bill No. 1013 (aka the California Cooling Act) was passed in 2018, it included an incentive mechanism via the Fluorinated Gases Emission Reduction Incentive Program. To date, this program has remained unfunded in the 2019 budget, although there still is yet a possibility for budget adjustments this year.
As was noted in the article, California’s tradition of incentives has helped create momentum to move the state toward lower-GWP refrigerants, systems with lower leak rates and better recordkeeping. Regardless, early adopters of climate-friendly cooling will have a variety of options from which to choose for new low-GWP systems, retrofits and upgrades.
CARB has stated that it will hold further stakeholder meetings this year, including a workshop focused on commercial refrigeration at the end of May. These meetings will conclude with a draft of the proposed new rulemaking along with continued economic analysis. As the industry awaits an update from the EPA on HFC-related regulations, California continues to be the country’s torchbearer for low-GWP refrigeration and cooling systems. As I was quoted in the article, our industry still has a lot of learning to do in the next four or five years, as the refrigerant transition will continue to drive equipment changes.
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