If you work in the HVAC Industry, it might come as no surprise that changes are on the horizon when it comes to curbing hydrofluorocarbons (HFCs), which are a form of greenhouse gas. This article dives into the deep end of what we can expect when it comes to refrigerant regulations across the US, as we wait for the Environmental Protection Agency (EPA) to provide clear guidelines. In the meantime, the states will decide.
Since the courts ruled that the Environmental Protection Agency (EPA) did not have the authority to phase down HFCs, the commercial refrigeration industry has been in a bit of turmoil. Many manufacturers had already been preparing to transition their equipment to lower-GWP refrigerants, but with no clear guidance coming from EPA, there are questions about which alternatives will emerge as the frontrunners, as well as when this transition will start taking place.
Adding to the confusion are the states — most notably California — that are rolling out their own phasedown schedule of HFCs, which could lead to a patchwork of refrigerant regulations across the U.S. Until EPA issues its final regulations, there will likely continue to be a lot of uncertainty about refrigerant use in commercial refrigeration equipment.
The federal role in leading the phasedown of HFCs is expected to be unclear for some time, said Mark Menzer, director of public affairs at Danfoss.
“We expected to see a proposal [from EPA] by now, but the federal government shutdown earlier this year delayed that,” he said. “Since EPA’s authority seems only to cover the transition from ozone-depleting substances (CFCs and HCFCs, mostly), we might see it focus its rules on users that are still using those refrigerants. EPA might tell those users that ODS replacements can only be low-GWP substitutes. That would be a very different type of regulation from the earlier SNAP [Significant New Alternatives Policy] rules and aimed at a different audience.”
With no clear direction from the federal government about what its long-term approach to managing HFC refrigerants will be, many states — especially California — are developing their own regulations about managing refrigerants, said John Prall, technical support expert for commercial North America, Embraco.
“While it would be ideal to have one regulation across the U.S., we are likely not going to see this in the short term,” he said. “My expectation is that most OEMs will build toward the toughest regulatory environment and consolidate their portfolio around this where they can reasonably do so.”
Richard Gilles, senior product leader of distributed solutions at Hussmann Corp., believes that it will take several years — and perhaps the next presidential administration — before there will be clarity at the federal level regarding HFC refrigerant policies.
“There is a certain level of ambiguity with the rescinding of SNAP Rule 20 [EPA regulation that prohibited the use of certain high-GWP HFCs as alternatives], which has led to individual states to act in their best interests,” he said. “The best strategy for OEMs is to focus on a large-scale, countrywide basis to best serve our customers. This does cause extra planning and logistics to handle the changing regulatory environment.”
Even though SNAP Rule 20 has been vacated, EPA still has the authority to phase out R-22, which will occur as planned on Jan. 1, 2020.
“It may surprise some to learn that there are still a large number of operators with older refrigeration systems that are currently charged with R-22,” said Andre Patenaude, director of food retail marketing and growth strategy — cold chain at Emerson Commercial and Residential Solutions.
After the phaseout of R-22 on Jan. 1, these operators will likely either retrofit their systems with lower-GWP refrigerants, or else keep recovering and reusing R-22 until they’ve exhausted their supplies.
“Very similar scenarios will be taking place in California, where R-404A and R-507A are no longer allowable in many new commercial refrigeration applications,” said Patenaude. “These operators can significantly reduce their carbon footprint by moving to lower-GWP gases, such as R-448A and R-449A, and recover, recycle, and/or reuse R-404A as a service-only refrigerant on remaining legacy equipment.”
WHERE TO GO FROM HERE
Not surprisingly, there will be a variety of ways in which store owners will address the phaseout of R-22, as well as the possible phase down of HFCs.
“Store owners are going to do whatever makes the most financial sense for their businesses,” said Prall. “Most independent store owners will likely not pay attention to what refrigerant is currently being used unless they have to purchase more refrigerant to replace leaked refrigerants. For self-contained equipment that is reaching the end of its useful life, it’s a very easy decision to go to a natural refrigerant. With remote systems, the decision on what direction to go is a much more complex decision and many factors need to be considered.”
The location of the retailer will also make a difference, as environmental awareness, as well as state regulations, will feature more prominently in certain parts of the U.S. than in others.