The global transition to low-GWP refrigerants is beginning in a disorderly manner in the United States — the world’s most mature HVAC market. In the absence of a federal framework, individual states are beginning to regulate HFCs. A handful of states are following SNAP Rules 20 and 21, the EPA regulations that were vacated by the courts. California, however, is going much further, proposing regulations for residential and light commercial air conditioning. This state-by-state patchwork of regulations with various timelines is creating serious problems for equipment manufacturers that supply products not to individual states, but to a national market. And given that the new low-GWP refrigerants, compared to their HFC predecessors, have different flammability characteristics and require building codes to be updated, this transition must be managed in an orderly manner to prevent serious consequences for consumers.
The potential consequences of this choppy regulatory landscape are most severe in the residential and light commercial air conditioning market. The EPA’s SNAP Rules 20 and 21 did not impact residential and light commercial AC, which allowed the transition to occur without significant building and fire code updates to accommodate mildly flammable refrigerants.
California, however, is proposing to regulate these sectors to achieve its ambitious climate goals. The next opportunity to update California’s building code is during its triennial code cycle, with publication of the code in January or February 2022. Although work has already begun to prepare for the transition, there is concern about meeting the January 1, 2023 transition date with final codes understood only one year earlier.
The California Air Resources Board (CARB) is the state agency charged with developing the regulations and it is guided by California’s commitment to reduce greenhouse gas emissions from HFCs by 40% by 2030 compared to a 2013 baseline. Thus, California is writing HFC phasedown rules that go beyond those laid out in SNAP Rules 20 and 21 and put it on a pace ahead of the Kigali phasedown schedule.
In terms of the residential and light commercial AC market, CARB is proposing the following:
- A ban on AC systems using refrigerant with GWP greater than 750 GWP by January 1, 2023.
- A ban on servicing existing equipment with refrigerant with a GWP greater than 1,500 GWP by January 1, 2022.
- A potential exemption for reclaimed refrigerant and R-410A remains an option.
Barring the commercial acceptance of R-466A, the only listed lower toxicity refrigerant that does not propagate a flame (A1 refrigerant), these regulations would require the use of A2L (lower flammability) or A3 refrigerants (higher flammability).
Globally, A2Ls have been used safely for years. Today, more than 8 million mini-split systems around the world are using R-32, and 80% of new cars sold in the U.S. use A2Ls in their air conditioners.
The use of A3 refrigerants (e.g., R-290 / propane) is already included in safety standards. Some of the requirements for their use include: no more than 150g per refrigerant loop, no nearby sources of ignition and no use near points of egress. Some manufacturers have redesigned their products to safely use flammables, reducing refrigerant charge and the potential for leaks. One manufacturer reports that 6,000 commercial propane ice machines are operating with no problems.
However, since A2Ls and A3s are new to the United States and these replacement refrigerants have different flammability characteristics, safety, training and building code updates are important considerations.
In my next post, I’ll take a closer look at US codes and standards and the impact on a safe refrigerant transition.