by Charlie McCrudden
Refrigerants are going to be…wait for it…the hot regulatory issue for this industry over the next year.
Yep. I resorted to a terrible old pun. But I did so to highlight the fact that the current climate change discussion doesn’t just involve coal fired power plants and other sources of carbon emissions. The majority of refrigerants used today have a harmful impact on the environment and global efforts to find safe and effective alternatives are starting to take shape.
No matter what you believe about global warming or climate change, the leaders of this country and many other nations around the world will be taking steps to control or reduce the amount of carbon released into the atmosphere.
The phase-out of HCFCs like R-22 isn’t close to the completion, but the discussion is already moved on hydrofluorocarbon (HFC) refrigerants. Although they don’t come out of a smokestack, HFC gases used for refrigeration and air conditioning systems have a high global warming potential (GWP) when they are released into the atmosphere. GWP is a basic measure of a compound’s potential to trap heat in the atmosphere, also known as the greenhouse effect, when compared to carbon dioxide. R-410A, a widely used HFC refrigerant, has a GWP that is 2,088 greater than carbon dioxide. R-407C, another popular HFC, has a GWP of 1,774.
Later this year policy makers from 197 nations will be meeting in Dubai to finalize an agreement on how to phase down the use of HFCs in developed and developing countries and promote the use of low-GWP alternatives.
A little more than two years ago the White House released the President’s Climate Action Plan, a regulatory blueprint for the production of cleaner energy, a more efficient transportation system, the promotion of energy efficient appliances and buildings, and the reduction of non-emissive greenhouse gases. The goal was to reduce America’s greenhouse gas emissions in the range of 17 percent below 2005 levels by 2020, if all other major economies agreed to limit their emissions as well. Nearly all federal agencies have had a hand in pushing the Climate Action Plan domestically, but others, like the EPA and the State Department have been active negotiators in ongoing global treaty negotiations.
A Global Phase Down of HFCs is On the Horizon
A global phase down on the production and consumption of HFCs is coming as more of the developing world choose the benefits of refrigeration and air conditioning. Diplomatic efforts between developed nations are underway in earnest using the regulatory process created by the Montreal Protocol on Substances that Deplete the Ozone Layer. And while the Montreal Protocol on Substances that Deplete the Ozone Layer was convened to address ozone depleting substances like CFCs and HCFCs, the program’s success presents the opportunity to address HFCs.
According to the EPA, refrigeration and air conditioning accounts for nearly half of the world’s HFC consumption. An estimated 11 percent of that was for unitary air conditioning in 2010. But this percentage is expected to increase as the transition from HCFCs to HFCs matures and as more developing nations increase their use of air conditioning and refrigeration.
This past April, the United States, Canada, and Mexico submitted a proposal to phase-down production and consumption of HFCs under the Montreal Protocol. Then in June, the leaders of the G-7 nations expressed their commitment to “continue… efforts to phase down hydrofluorocarbons (HFCs)” and called “on all Parties to the Montreal Protocol to negotiate an amendment this year to phase down HFCs and on donors to assist developing countries in its implementation.” The momentum has been building as meetings over the last year have rounded up nearly all developed nations on board with some form of global action.
The proposal is a gradual phase down of the use of HFCs by developed nations like the United States and most of Europe, not a phase out since there is no dominant alternative for HFCs on the market yet. If it were to be implemented, the phase down would commence in 2019 with a 90 percent reduction to the baseline of average production and consumption in 2011-2013. The phase down would end with production and consumption at 15 percent of the baseline in 2036.
The amendment will be considered for formal adoption at the 27th Meeting of the Parties to the Montreal Protocol in Dubai from early November.
Domestically, Use and Handling Practices Are Likely to Change
Should HFCs come under the Montreal Protocol, the EPA would have to make amendments to the existing Section 608 Clean Air Act rules to add restrictions on the use and handling of HFCs. The EPA is already considering changes to the Section 608 Program and has held large group meetings and smaller discussions with stakeholder groups. The most likely modification would be an expansion of rules to require a Section 608 card to purchase HFCs.
ACCA has pushed EPA to make several other critical changes to the Section 608 rules, including updating the technician’s certification exam. Many of the questions on the exam are not relevant for today’s HVACR technicians and need to be reviewed or deleted. The exam delivery method can be streamlined to accommodate online test taking for all types of exams. And finally, ACCA believes that technicians should be required to recertify every five years to keep up with new technologies and the ever expanding list of refrigerants on the Significant New Alternatives Policy (SNAP) list.
It’s expected that EPA will release a proposed rule later this year with changes to the 608 process in advance of any global treaties.
A Phase Down of HFCs May Not Be Enough for California
Meanwhile, the state of California does not intend to wait for a global treaty to address greenhouse gas emissions. Recently, the California Environmental Protection Agency’s Air Resources Board released a proposal to reduce all hydrofluorocarbon emissions 25 percent by 2020, and 50 percent by 2030 below forecasted emission levels, a more aggressive phase down schedule than through the Montreal Protocol amendments. California is also considering a sales ban on certain equipment that contains a refrigerant with a GWP over a certain limit. In addition, limiting the use of HFC or equipment with HFCs may not be enough; the state is considering a plan that adds new measures to enforce recovery and destruction of HFCs.
As anyone who tracks environmental and energy regulations knows, policy initiatives often start in California and then head east. The state is proud of its progressive stances in favor of the environment and states like Massachusetts and New York are usually quick to follow suit.
What Will Fill the Gap?
The list of approved HFC substitutes is constantly changing as better alternatives come on the market.
In April of this year, EPA finalized a rule that made changes to the SNAP list to include, for the first time, hydrocarbon refrigerants for limited equipment and sized charges. The four compounds are HFC-32, ethane, isobutene, propane, and R-441A. Hydrocarbon refrigerants, which contain propane or other flammable gases, are already in use in many of these applications in Europe and Asia. Effective May 11, 2015, certain household refrigerators and freezers, standalone retail food equipment, very low temperature refrigeration, non-mechanical heat transfer, vending machines, and room air conditioner units can use these refrigerants. The final rule also exempted hydrocarbon refrigerants from Section 608’s prohibition on venting, release, and disposal of ethane, isobutene, propane, and R-441A. HFC-32 may not be vented. In July, the EPA made additional changes to the SNAP program that delisted several compounds used for commercial uses, by end use, since viable alternatives with lower GWP were available.
Hydrocarbon refrigerants may be a low-GWP option, but they do come with complications, such as flammability and toxicity. As existing regulations phase out the use of environmentally harmful refrigerants, the next generation will likely include compounds that are somewhat flammable and less efficient. One of the big questions will be, how will the codes address hydrocarbon refrigerants compounds that are widely used overseas, but not yet adapted here in the U.S.?
You can expect to see more changes to the SNAP list in the coming years as low-GWP options become available. There will be a lot of debate about the safety of hydrocarbon refrigerants and the best way to implement them, but their expansion is inevitable. You can also expect to see movement by the U.S. on reducing the production and consumption of HFCs in the U.S., whether as part of a global treaty or through federal regulations or from states like California.
The process will take a few years to work itself out, but an HFC phase down is not that far away, but the implications are far reaching on the HVACR industry. Don’t forget, the Department of Energy soon will set new standards for central air conditioners and heat pumps that will go into effect in about six years. Imagine how a different refrigerants will impact equipment energy use and service practice
Author's Note: Charlie McCrudden is ACCA Senior Vice President for Government Relations. He represents the indoor environment industry before Congress and federal regulatory agencies.