Four years after the California (U.S.) state government authorized its Air Resources Board (CARB) to oversee the reduction of HFC emissions, the board on December 10 voted unanimously to approve a sweeping regulatory proposal putting in place stronger restrictions on the use of refrigerants in HVAC&R applications than current rules.
Led by CARB, California has been the most proactive U.S. state in regulating and pursuing further regulations of HFCs in an effort to cut their emissions by 40% under 2013 levels by 2030, per the 2016 law, SB 1383. In 2018, California passed SB 1013, which adopted previously used federal bans on high-GWP HFCs and allocated funding for natural refrigerant systems.
But the new regulations expand the state’s refrigerant restrictions considerably. Starting in 2022, new equipment with more than 50lbs (22.7kg) of refrigerant – typically used by supermarkets and industrial facilities – will be required to use refrigerant with a GWP of less than 150. This applies to new stores and remodeled facilities with new refrigeration systems.
The 150-GWP cap is expected to cut emissions reduction per facility by more than 90%, said CARB.
In addition, food retailers with 20 or more stores would need to comply with one of two options for existing stores: maintaining a weighted average refrigerant GWP below 2,500 by 2026, or reduce GWP potential (charge size times GWP) by at least 25% by 2026. All stores would need to have an average GWP below 1,400 or reduce GWP potential by 55% by 2030.
In existing non-retail facilities, new systems used for industrial refrigeration could use refrigerants with a GWP between 1,500 and 2,200.
On the air conditioning side, beginning in 2023 new room air conditioners (RACs) and dehumidifiers must use a refrigerant with a GWP of less than 750. Larger stationary AC used in residences and commercial/non-residential buildings will have until 2025 to meet that requirement to allow A2L updates in the existing UL 60335-2-40 standard to be adopted by California building codes. Variable refrigerant flow (VRF) units will have until 2026.
The Environmental Investigation Agency (EIA), with support from 120 industry and other stakeholders, lobbied CARB regarding the GWP of refrigerant in new ice rink systems, and the agency agreed to lower the requirement to 150 GWP for new equipment (750 GWP in existing facilities). The move sent “a strong signal to that sector globally that sufficient alternatives are available using ultra-low GWP ammonia [R717] and CO2 (R744), without the need for HFC blends,” said EIA.
“Until now U.S. policies have only skimmed the surface on these super pollutants.” said Christina Starr, EIA Senior Policy Analyst. “This regulation sets a higher bar for other states and the Biden Administration to follow. It will begin to curb California’s rapidly growing HFC emissions downward in this decade.”
“CARB and industry leaders alike recognized the threat posed by common refrigerants and worked tirelessly over a four year period to get to this point,” said Tristam Coffin, president of California-based Livingston Consulting, and former Director of Sustainability and Facilities for Whole Foods Market’s Northern California Region.
“However,” added Coffin, “now the important work begins to address the regulatory actions, achieve compliance, and solidify critical steps toward a more sustainable future. From the supermarket industry, to cold storage, to ice rinks, action is required.”
Boon for NatRefs
In regard to particular refrigerants, the new regulations should help drive adoption of natural refrigerants in supermarket and industrial applications. Already, more than 80 supermarkets in California employed low-GWP refrigerants in 2019, said CARB, including a number with CO2in transcritical systems.
This year, Raley’s installed an ammonia/CO2 system in a new store in Sacramento, California. Ed Estberg, a refrigeration consultant to Raley’s who was previously the 130-store chain’s longtime senior director of facilities, persuaded the chain’s ownership that, given the impending 150-GWP cap, Raley’s “really [doesn’t] have a choice” but to invest in natural refrigerant-based technology for future stores, he explained in 2019 at the IIAR Natural Refrigeration Conference and Expo.
For RACs, the prospects for natural refrigerants are not as immediately promising. Currently, A3 (flammable) refrigerants like propane (R290) are not allowed in ACs in California due to “the restrictive UL standard,” noted Starr. A2Ls are available for RACs, though R32 (GWP 675) is expected to be the refrigerant “mainly” used, she added.
However, in Augustan International Electrotechnical Commission (IEC) working group released a proposal to update the safety standard (IEC 60335-2-40) for room air-conditioning (AC) systems, heat pumps and dehumidifiers, which would allow larger amounts of flammable refrigerants around the world. Expected to be approved by the end of 2021, this update would eventually “be helpful to A3s as well as A2Ls,” said Starr, though potentially not until 2026 in the following building code cycle.
In commercial and industrial chillers/ACs, CO2 and R717 can be used in California.
Recycling program for ACs
In exchange for extending the deadlines for larger AC equipment, CARB obtained an agreement from AC manufacturers to launch a Refrigerant Recovery, Recycle, and Reuse (R4) Program. Under the program, AC manufacturers would be required to use 10% of recovered R410 refrigerant from retired equipment.
EIA, which had proposed an HFC recycling plan to CARB, is looking forward to help “kickstart and successfully implement a pathbreaking new R4 program that can become a national model,” said Starr.
Final amendments to accommodate the AC sector changes for extended deadlines and the R4 Program will be subject to a 15-day notice and comment period before entering into effect early next year, EIA noted.
This regulation sets a higher bar for other states and the Biden Administration to follow.Christina Starr, EIA