For new air conditioning equipment sold in California, a 750 GWP limit was pushed back to January 1, 2025, while VRF system manufacturers have until 2026 in order to comply with the new limit. In exchange for delaying the 750 GWP mandate, equipment manufacturers agreed to sign onto CARB’s Refrigerant Recovery, Recycle and Reuse program – or R4 program. Under this program, the responsibility for refrigerant recycling compliance will be placed on the manufacturers, and they will also be required to use some recycled refrigerant in their air conditioning equipment.

But these regulations will not be enough to meet the emissions reduction requirements outlined in SB 1383, said Glenn Gallagher, an air pollution specialist at CARB. He noted, “Even with all state and national measures in place, we still need additional reductions to achieve the 2030 HFC reductions goal. We're not quite there with current regulations.” Based on projections, HFC emissions will come in at about 12 MMTCO_2e in 2030, instead of the required 10 MMTCO_2e.

He said that one of the reasons for this emissions “gap” is that numerous households and businesses have existing air conditioning equipment that contains millions of pounds of HFC refrigerants. These “banks” of refrigerant can emit over the lifetime of the equipment, usually anywhere between 10 and 20 years. Because there are limited or no drop-in replacements for most refrigerants in use today, this means that even if all HFC production were banned today, the existing equipment would continue to emit HFCs for decades, he said.

“The installed base is equal to 60% of annual statewide greenhouse gas emissions, so that's a lot of HFCs in equipment that we have to manage,” said Gallagher.

Another problem is that California’s push for building electrification encouraged the replacement of gas-powered appliances with heat pumps. Switching from fossil gas to electric heat pump technologies offers benefits for better environmental and public health and results in significant greenhouse gas reductions, he said. However, most heat pump technologies today use HFCs, and as millions of refrigerant-containing heat pumps are adapted for space conditioning, water heating, clothes drying, and heating pools and spas, some of those greenhouse gas benefits will be offset by an increase in HFC emissions, he added.

“Reducing HFCs is critical for California’s short- and long-term climate goals, and we may need to use all policy instruments at our disposal to influence behavior and shift the market towards very low-GWP alternatives,” said Gallagher. “The path to a low- or no-GWP future may need both regulatory and incentive approaches. Regulations are integral to increase the adoption of low- or no-GWP technologies. Some measures we are considering or may include GWP limits for new heat pump sources and tightening GWP limits for existing sources. There's a need to address the banks of HFCs through improving the recovery, recycling, and reclamation of existing high-GWP refrigerants.”

To that end, Gallagher closed his presentation by asking the public for ideas that could further reduce HFC emissions in order to meet the state’s climate goals.

“We would like stakeholder input on what additional strategies could be used to further reduce HFC emissions,” he said. “How should we address the existing banks of the HFC potential emissions? How should we preserve building electrification benefits with respect to HFC refrigerants? We look forward to working with all of the stakeholders to reduce HFC emissions.”

In other words, look forward to seeing even more regulations put in place in California – which could potentially be adopted elsewhere – that are designed to further restrict the use of HFCs in air conditioning and refrigeration equipment.