The California Air Resources Board (CARB) held its latest public workshop in July to discuss its 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 150 for new stationary refrigeration systems containing more than 50 pounds of refrigerant, starting on Jan. 1, 2022. On the air conditioning side, there is a proposed GWP limit of 750 for all new stationary air conditioning systems (residential and commercial) starting Jan. 1, 2023, and the same GWP limit for new chillers, effective Jan. 1, 2024.
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At the CARB workshop in January, air conditioning OEMs expressed concern about meeting California’s aggressive timeline, citing the lack of clarity in building codes regarding the use of lower GWP, mildly flammable (A2L) refrigerants in equipment. That issue is still a problem, but OEMs are also concerned that impacts from the COVID-19 pandemic could affect their ability to meet the 2023 mandate, so they asked CARB to delay the deadline until 2025. That request met resistance from CARB officials, who insisted on maintaining the 2023 deadline, although they said they were open to listening to suggestions from stakeholders.
Staying The Course
Kathryn Kynett, an air pollution specialist at CARB, led the discussion regarding air conditioning equipment, and she offered an overview of the regulation, as well updates made to the regulatory text. She noted that since the last workshop in January, CARB had received a number of questions from stakeholders about the codes and standards that would allow for lower GWP A2L refrigerants to be used as a compliance option for the regulation. In California, the State Fire Marshal has authority over building codes, so using A2L refrigerants in equipment would require the Marshal to change those codes.
“In 2020, the State Fire Marshal kicked off a work group to consider incorporating updated standards into the triennial California Building Code update, which would allow for the use of A2L refrigerants in time for CARB's effective date,” she said. “By the time CARB holds the board hearing in December, the outcome of the State Fire Marshal workgroup and EPA’s Rule 23 are anticipated to be known. At that time, manufacturers will know what code changes are being recommended regarding A2Ls.”
Kynett conceded that the timing of the completion of standards was not ideal for the model code cycle, because even though both ASHRAE Standard 15-2019 and UL 60335-2-40 (third edition) were recently finalized to allow the use of A2Ls, the uniform and international codes do not allow their use. Given that the 2021 code cycle has closed, and the new code development cycle for 2024 is now underway, some states are looking to amend their state building codes to allow the use of A2L refrigerants. Washington State, for example, has already done this, and California’s State Fire Marshal could allow them to be used in the state as well.
Several OEMs expressed concern about what could happen if they design equipment to use A2L refrigerants, then the State Fire Marshal does not approve their use. On the other hand, if they wait until December to find out if A2Ls are approved, they said that would offer little time to develop new HVAC products, as well as train technicians to safely handle A2L refrigerants, by the 2023 deadline.
Kynett pushed back, noting that OEMs do not have to use A2L refrigerants to meet the 750 GWP limit deadline and that they agreed to the 2023 deadline in order to align with the Department of Energy’s (DOE’s) minimum efficiency requirements. She said that while CARB understands that it is a major undertaking to redesign equipment to meet DOE requirements, OEMs could “leverage the work that's being done [for DOE] and fold in this new change with the refrigerant, which is a relatively smaller part of the redesign.”
“We're still taking comments on the appropriate implementation date, but we also have our legislative mandate, which requires everybody to step up and work on helping us meet these goals on a quick implementation schedule,” she said. “To meet this mandate, we've identified that it is essential for the air conditioning industry to transition as soon as possible. And we understand there are some challenges and barriers, but we're really looking to design this regulation to give the industry its best chance of working through these barriers and getting there together. Each year delay has a significant impact on emissions reductions.”
Pamela Gupta, a manager at CARB, added, “This is nothing new. It’s been going on for several years. The dates that came from the OEMs align with DOE. A lot of testing has been done, and what we're trying to do here is to provide certainty by sticking to the effective date that we have proposed. But we are always open and want to hear if there are any specific issues or concerns.”
Helen Walter-Terrinoni, vice president for regulatory affairs at AHRI, offered such a concern, noting that the pandemic has changed the landscape in the HVACR industry. For this reason, AHRI requested that CARB extend the deadline for its air conditioning equipment mandate.
“We're proposing that CARB consider a Jan. 1, 2025, transition date for 750 GWP for newly manufactured air conditioning equipment,” she said. “Understanding that the safety standards in California Codes need to be aligned, and hopefully that will be done as quickly as possible. Our proposal to compensate for this is to prohibit the sale, resale, transfer, and/or import for use in California of newly produced R-410A, except for export from California at that time. And then to require the collection of all refrigerants at end of life and that reclaimed refrigerant meet purity standards of AHRI 700 and allow reclaimed R-410A to be used in California. The equipment manufacturers will also promote and encourage the recovery of R-410A through education of their service and dealer networks right away.”
Gupta noted that since this was a new proposal from AHRI, CARB would not be commenting on it at the workshop.
VRF OEMs also expressed concern, with one noting that “there is no viable pathway for code changes until after the compliancy date of 2023. As such, a 2023 compliancy applied to VRF will result in banning these systems, which are critical to California's climate codes.”
Kynett noted that while CARB is still actively considering the appropriate implementation date for VRF systems, this technology is included in the 750 GWP limit, which becomes effective in 2023.
“We understand the standards that would be placed on VRF systems to allow A2Ls are very stringent with their requirements for sensors and restrictions on charge sizes,” she said. “We understand that VRFs have a very large charge size with refrigerant, so our HFC team is doing our due diligence to understand those emissions. But as currently written, VRF systems are included, and we don't have any other updates at this time about the VRF systems.”
Kevin Messner, senior vice president of policy and government relations at the Association of Home Appliance Manufacturers (AHAM), reiterated his concern from the January workshop about whether or not an alternative refrigerant will be available for use in dehumidifiers by the 2023 deadline.
“How can you ban R-410A for dehumidifiers when the alternatives under 750 GWP are not able to be used under EPA regulations?” he asked. “And there's practically no time for EPA to approve an acceptable substitute and then allow for the design and safety testing of products by 2023. This proposal is essentially a ban on dehumidifier sales in California, which are important for indoor air quality.”
Gupta responded, “We understand the concern you're raising, but at the same time, this proposal has been discussed for several years. The OEMs really have to take that responsibility to look into the alternatives and make those submissions for EPA to consider.”
Regulatory Text Changes
As for changes made to the regulatory text since the last workshop, Kynett said that a table had been added to show which air conditioning equipment would be affected by the regulation. Effectively, this table shows that all new stationary air conditioning systems are prohibited from using a refrigerant with a GWP of 750 or greater beginning Jan. 1, 2023.
Language has also been added to clarify what activities are prohibited and by whom. Specifically, the prohibition states that no person shall sell, lease, rent, install, use, or enter into commerce in the state of California any end use — in this case, new air conditioning equipment — that does not comply with the 750 GWP limit.
The definition of new air conditioning equipment has also been expanded to include “any equipment that cools or dehumidifies spaces in residential or non-residential settings, for comfort cooling and other purposes, including but not limited to room air conditioners, central air conditioners (ducted and non-ducted), heat pumps, dehumidifiers, computer room and data center cooling, and remote condensing units for air conditioners.”
CARB has defined new air conditioning equipment to mean “any air conditioning equipment or system that is first installed using new or used components, or a combination of new or used components, or a new exterior condenser, condensing unit, or remote condensing unit in an existing system.”
“If a whole unit needs to be replaced, the new unit that replaces it must meet the 750 GWP limit,” said Kynett. “For split systems, end users can continue to repair components within their existing systems, and they can even replace the indoor unit. However, once they replace the outdoor unit, which houses the condenser and compressor, the new equipment that is installed must use a refrigerant that is less than 750 GWP. The logic for this is that the unit that houses the condenser and compressor is essentially the heart of the system, and typically you're going to want to replace the outdoor and indoor unit together for energy efficiency purposes.”
As for enforcement of the new regulation, Kynett said that labeling and recordkeeping by equipment manufacturers would provide the two main avenues to ensure compliance.
“The labeling requirement can be met by labels that manufacturers already use if they display the type and amount of refrigerant and the data manufacturer in a standard format,” she said. “The second tool is recordkeeping for manufacturers. The type of information that will be required includes contract information for the purchaser, identifying information for the equipment, the date of manufacture, the day of sale, as well as the refrigerant type and amount.”
Kynett ended her presentation by noting that through enacting a 750 GWP limit for new stationary air conditioners effective in 2023, CARB expects to see 2.3 million metric tons in CO2 equivalents (MMTCO2e) of reduced annual emissions in 2030.
“This is nearly 25 percent of the progress needed to achieve the [emissions reduction] target for 2030,” she said. “Between 2023 and 2040, the cumulative emissions reductions are even greater at 50 MMTCO2e of avoided HFC emissions. This is equivalent to taking about half a million passenger cars off the road each year from 2023 to 2040.”
Now that the public workshops on the proposed air conditioning and refrigeration 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.
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