In hopes of reaching their goal of reducing greenhouse gas emissions to 40% below 1990 levels by 2030, and to reduce HFC emissions to 40% below 2013 levels by 2030, California’s Air and Resources Board (CARB) has proposed regulations that would cap GWP limits on refrigerants and equipment. Throughout their regulatory process, CARB has requested industry and stakeholder comments regarding different aspects of their plans. Recently, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) submitted an alternative regulatory proposal requesting a longer phase-down on GWP limits and changes to what classifies as “new equipment”.
- 150 GWP cap on refrigerant used in new systems with more than 50 lbs of refrigerant by 1/1/2022
- A ban on the sale of virgin refrigerants with a GWP above 1500 by 1/1/2022
- 750 GWP cap for new stationary air-conditioning systems by 1/1/2023
AHRI’s Suggested Changes:
- 1500 GWP cap on medium-sized commercial refrigeration units with between 50 and 300 lbs of refrigerant in 2021 but delaying the 150 GWP cap until 2024, contingent on the adoption of safety standards in the California State Code
- AHRI is also recommending that new remote condensing units and those used in new construction, with 50-300 lbs of refrigerant, have a 1500 GWP cap in 2021, and a 300 (as opposed to 150) GWP cap in 2024
AHRI also hoped to clarify the definition of “new equipment” to which these GWP limits apply. Currently, CARB’s definition encompasses new stores and existing stores with equipment modified to handle an expanded cooling load or where equipment is replaced in whole or part so that the cost of the components exceeds 50% of the cost of replacing the entire system. AHRI’s concern is that under this definition a store’s entire system may need to be replaced long before it is due to be retrofitted. In AHRI’s new proposal they suggested that retrofit, maintenance, and replacement of equipment components “cannot be done for all applications given the current equipment limitations and restrictions of safety codes and standards.”
CARB is expected to approve final regulations in May 2020.