Between global policy and federal/state legislation, the arrival of low GWP (global warming potential) refrigerants for new and remodeled HVACR equipment is inevitable. The US EPA is in the process of determining how to administer the phasedown of hydrofluorocarbon (HFC) production and consumption. The final regulation should be finished by October. In some areas of the U.S., the effective date for phasedown is January 2023.
A survey by Emerson Electric shows that well over half (66%) of HVACR equipment suppliers, contractors and refrigeration specialists “have not taken action to prepare” for the implementation of legislated phasedown production and consumption of hydrofluorocarbons (HFC). However, everyone in the building industry, from manufacturers to designers, controls consultants, contractors, owners, operators and occupants – and of course CxPs – will be affected.
Here are 10 ways that commissioning providers and others can engage productively – and provide value – to support the phasedown while building your business, reputation and network:
- Learn it. Find out the what, why and how of policy and technical issues
- Act on it. Participate in developing Cx-related legislation and code language
- Make it so. Work with manufacturers, design teams, owners, facility managers to educate and advise about building systems integration
- Build it. Observe installation, integration with other systems and controls
- Test it. Verify/conduct functional tests and document them
- Run it. Continue to engage through operations phase
- Prove it. Use data analytics to demonstrate optimal performance and efficiency
- Adjust it. Do the inevitable tweaking of new and remodeled systems
- Train it. Offer training to your clients’ operations personnel
- Embed it. Participate in developing rating system language and points
Right now, individual states are setting goals and moving forward on legislation to support and promote the phasedown. The remainder of this article focuses on the background, HVACR systems and alternatives to HFCs, and sample resources for further knowledge.
Background: HFC Policy and Legislation
The Montreal Protocol to eliminate HFCs was ratified in 1987. The effort to phase out/reduce use of HFCs is being driven by the Protocol’s Kigali Amendment, which took effect on a global level on January 1, 2019, ratified by 123+ countries.
In the U.S., Congress passed the bipartisan American Innovation and Manufacturing (AIM) Act of 2020. The AIM Act directs EPA to address HFCs by providing new authorities in three main areas: to phase down the production and consumption of listed HFCs, manage these HFCs and their substitutes, and facilitate the transition to next-generation technologies.
In response, the U.S. EPA announced on May 3rd a prescriptive “phasedown” of the production and use of HFCs by 85 percent over the next 15 years. The Air conditioning, Heating, and Refrigeration Institute (AHRI) has submitted a petition – partially overlapping with NRDC’s – regarding HFC use in a variety of commercial refrigeration applications.
States are also now creating their own regulations:
- Washington has adopted UL 60335-2-40 3rd edition and ASHRAE 15 2019 edition into their state building codes, revised safety standards that address the use of A2L fluids in new equipment.
- California has proposed regulation that would prohibit the use of refrigerants greater than 750 GW, including the ubiquitous R-410A in new air conditioning equipment. Because the new refrigerants are classified as mildly flammable, building code modifications are needed. In California, this may not occur prior to 2023, which could lead to a delay until 2025.
- New York regulations ban the sale, installation and commercial use of certain HFC refrigerants in new or retrofitted food refrigeration equipment, large air-conditioning equipment or chillers and vending machines.
- Colorado HFC regulation (5 CCR 1001-26), contains phase out dates that affect manufacturers and end-users.
Heat Pump Systems: CO2 As Alternative to HFCs
High-efficiency heat pumps, many of which use HFCs as a coolant, are increasingly recognized as energy efficiency and beneficial electrification solutions for commercial and residential building heating and cooling. Heat pumps are energy efficient and are run on electricity rather than fossil fuels, which is becoming increasingly important as carbon emissions and electrification regulations emerge.
One solution for addressing HFC refrigerants is by replacing them with alternative refrigerants that have much lower GWP, including ammonia, captured CO2 (carbon dioxide), and propane. CO2 for high-efficiency heat pumps provides low flammability, low toxicity, and a GWP of 1 – which other refrigerants can’t match in performance – can be a mechanism for commercial water heating.
HFCs, commonly used in heat pumps, air conditioning and refrigeration, have a GWP more than 1,000 times that of CO2 and the commonly used HFC, 410A, which “is 4,340 times more potent than carbon dioxide over a 20-year period.” according to NRDC (National Resources Defense Council). For more than 10 years, R-410A has been the refrigerantused in most rooftop unit (RTU)s manufactured in the U.S. That will be changing.
CO2 is environmentally friendly and will likely not be phased out in the future; however, CO2 operates at a much higher pressure than traditional HFC refrigerants, which may become an issue – for one thing, at high pressure CO2 can transform to a solid, and can result in different crystal structures.
Building Systems and Operations
Many new and renovated building systems will be affected by the phasedown, and questions will abound as stakeholders realize the profound impact of this change, both now and over time as the mandates are implemented. Consequences will roll out as they are met. One recent article in Contracting Business responded to questions from building professionals about the phasedown transition and implementation:
“How will the phaseout affect operations? Equipment designed for currently used A2L refrigerants (ASHRAE designation for lower flammability, lower toxicity), will likely have new embedded sensors and controls; management of proliferation of refrigerant options will be needed; there will be a need to comply with storage and transportation requirements of refrigerant, systems and components; and business owners will need to ensure the safety of its who are employees handling the refrigerants (service and install) along with potentially having to provide an explanation of the system changes to the end users.” (also note, but not stated in this article: A2L refrigerants should never be used to replace non-flammable refrigerants in retrofit situations without a full risk assessment and necessary modifications.)
Although there are numerous resources available to pursue these topics, here are a few for getting started learning about the phasedown and the technologies that will affect commissioning providers:
A Beginner’s Guide to CO2 Refrigeration Systems, article in ACHR
Differences between CO2 and HFC Systems, ACHR online magazine, August 2021, page 28
Introduction to A2L Refrigerants (lower flammability, lower toxicity), report prepared by Federation of Environmental Trade Association (FETA), which represents over 400 manufacturers, suppliers, installers and contractors within the HVACR, building controls and industry to policymakers and the public.
Commercial Heat Pump Water Heaters using CO2 Refrigerant, article in Building Green e-Magazine
How Regulatory Heat is Advancing the Coolant Industry, Article in Environment & Energy Study Institute (EESI) regarding EPA’s HFC Phasedown
Ozone Assessment 2018: Chapter 2 HFCs, NOAA Chemical Sciences Laboratory Report