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The California Air Resources Board (CARB) held a public workshop in July to discuss its most recent proposals for reducing high-GWP HFCs from stationary refrigeration and air conditioning equipment. Under regulations passed in 2016, California is committed to reducing HFC emissions in the state by 40 percent below 2013 levels by 2030.

To meet this mandate, CARB is proposing a GWP limit of 750 for all new stationary air conditioning systems (residential and commercial) starting January 1, 2023, and the same GWP limit for new chillers, effective January 1, 2024. On the commercial refrigeration side, there is a proposed GWP limit of 150 for new stationary refrigeration systems containing more than 50 pounds of refrigerant, starting on January 1, 2022.



Richie Kaur, Ph.D., an air pollution specialist at CARB, recapped the regulations, as well as described the updates for the proposed regulations regarding commercial refrigeration systems in the retail food sector. To recap, she noted that all new retail food facilities using systems containing more than 50 pounds of refrigerant must use a refrigerant with a GWP value of less than 150 starting January 1, 2022. This requirement will apply to all new facilities irrespective of end use, while in existing facilities, the rules will differ by end use due to the disparate impacts on HFC emissions.

For the purposes of this regulation, new retail food facilities are being defined as those that are newly constructed; those that are repurposed, meaning they were not used for refrigeration before but will be now; or existing facilities that undergo a major remodel. The last point, referring to major remodels in terms of refrigeration, has been edited since the last workshop, said Kaur.

“This particular portion [of the regulation] is now more descriptive and was modified with the input of supermarket companies, so now it says a replacement involves 75 percent or more of evaporators by number and 100 percent replacement of compressors and condensers,” she said. “It seemed clearer to define a new facility like this, rather than just a new refrigeration system to avoid any confusion.”

Since the last workshop, there were also questions regarding what the effective date means for a new facility. Kaur explained that for any system, the effective date is tied to the date of manufacture.

“For supermarket systems, which are built up on site, the manufacturer date is when the system is first charged with the refrigerant and becomes operational,” she said. “But we have added an important exception here, which is that if you have an approved building permit before the effective date -- so before January 1, 2022 -- then that facility would be exempt from the GWP less than 150 rule. It was brought to our notice that facilities like supermarkets start the planning process a year or two in advance, and once they have an approved building permit, all details of the refrigeration systems have been finalized. In that case, that particular new facility will be exempt from the GWP less than 150 rule.”



To comply with the regulation, existing retail food facilities will have two ways by which they can reduce their HFC emissions, see Figure 1. The first option is to reduce their greenhouse gas potential (GHGp), so for supermarkets, this would be the sum total of the potential emissions that could result if all of their systems greater than 50 pounds across their stores were leaking, said Kaur.

Figure 1: Proposed Options for Existing Retail Food Facilities.

Figure 1: Click figure to enlarge.

“The goal is to cut this down by 55 percent below the current levels, meaning this is a relative reduction target, since progress will be measured relative to each company's current baseline,” she said.

The second option is to reduce the average GWP of the supermarket chain. This considers all the systems used by a supermarket company that are greater than 50 pounds, and calculating the average GWP of the company by weighting it by the type of refrigerants being used. The goal with this option is for all companies to have an average GWP below 1,400 by the year 2030, said Kaur. This is an absolute target, meaning all companies have to hit that number of below 1,400 irrespective of where their weighted average GWP (WAGWP) is today.

“Both of these options result in equivalent emissions reductions on a statewide level,” she said. “It is important to note that these are full company targets, or supermarket fleet standards, if you will, which means that companies have the flexibility not to retrofit every single system or store. They also have the flexibility to plan their compliance over the next eight to 10 years, and importantly, it prepares the sector for a future HFC phasedown or a virgin refrigerant sales ban, since they have already begun transitioning towards lower GWP alternatives.”

Companies with 20 or more retail food facilities, or national chains with more than 100 stores nationwide, will have a progress step in 2026, and by that year, they have to attain a WAGWP below 2,500 or a reduction in GHGp of at least 25 percent, said Kaur. By January 1, 2030, all retail food companies large or small in the state of California will be required to attain a WAGWP below 1,400, or a reduction in GHGp of at least 55 percent below their baseline levels.

One important change made to the regulatory text is that in previous drafts, 2018 was listed as the baseline year for GHGp, and that has now changed to 2019, see Figure 2. Another important point is that food retailers no longer have to choose between GHGp and the WAGWP options, said Kaur.

Figure 2: Requirements for Existing Food Retail Facilities.

Figure 2: Click table to enlarge

“In our previous draft regulatory text, we did have an opt-in requirement,” she said. “We have now removed that, because we want the retailers to have the flexibility to try any and all strategies for trying GWP reduction in their stores and then decide whatever strategy suits them best.”

Now that the public workshops on the proposed refrigeration and air conditioning regulations have concluded, CARB will work to finalize its notice package. This consists of a document called the initial statement of reasons, or staff report, which lays out the rationale behind the regulation, summarizes the benefits and costs, and provides details of the amendments. The notice package will also include the regulatory language. Once the notice package is released publicly, it will be followed by a 45-day comment period, which will terminate right before CARB’s board hearing in December 2020. If the board approves it, the earliest effective dates will be 2022 for refrigeration and 2023 for air conditioning.

Check out this this article for updates regarding CARB's proposal for new stationary air conditioning systems.