HFC phaseout will occur in 2024, not the 2025 preferred by AHRI and others
Chiller manufacturers are facing a Jan. 1, 2024, implementation date to phase out the use of hydrofluorocarbons (HFCs) R-134a, R-410A, and R-407C in new liquid chillers, despite Air-Conditioning, Heating, and Refrigeration Institute’s (AHRI’s) efforts to change the proposed effective date to Jan. 1, 2025.
Starting in 2024, the three HFC refrigerants will be deemed “unacceptable” in new liquid chillers under the U.S. Environmental Protection Agency’s (EPA’s) Significant New Alternatives Policy (SNAP) program.
AHRI and the National Resources Defense Council (NRDC) requested the EPA consider the 2025 effective date to ensure the safety of alternatives, the continued improvement of system efficiency, reasonable product development timelines, and the avoidance of market migration. The EPA, however, declined to extend the date.
“We are extremely disappointed the EPA failed to take into account the impact on industry and consumers in making this decision,” said Stephen Yurek, president and CEO, AHRI. “We are very concerned this decision will have an adverse effect on our industry and the 1.2 million Americans we employ. Making compliance a year sooner has a negligible benefit for the environment, but it does create an economic burden for the industry that provides comfort cooling and heating, commercial refrigeration technologies, and hot water for every American.”
Francis Dietz, vice president, public affairs, AHRI, added that product development is a long, multistep process from concept to market, even under “normal” circumstances.
“Manufacturers must do the research, development, demonstration, testing, and evaluation of new equipment, and then retool their lines to manufacture it,” Dietz told The NEWS. “But, in this case, many, if not all, of the replacement refrigerants are currently classified as mildly flammable or flammable. Thus, they cannot be used in the vast majority of applications in the U.S. because of building code restrictions. The research that is about to get underway — which is sponsored by AHRI, the U.S. Department of Energy (DOE), ASHRAE, and the state of California — will provide the information code developers need to decide what changes they should make to safety standards and building codes. Once that happens, only then could these refrigerants be used, which further compresses the equipment development process. So, even though it’s only one year difference, that extra time is needed by many manufacturers.”
David Doniger, director, climate and clean air program, NRDC, noted his association also recommended to delay the use restriction until 2025.
In 2015, NRDC had petitioned the EPA to complete the phaseout of R-134a, R-410A, and R-407C in new chillers by 2023, but in February petitioned jointly with AHRI to make the effective date Jan. 1, 2025.
NRDC said it agreed to recommend the longer timeframe because it increased the likelihood that manufacturers would move to refrigerants with near-zero heat-trapping potency and the highest energy efficiency rather than adopting middle-range potency refrigerants. Additionally, a delay would have helped ensure the EPA would ban all three high-potency refrigerants in all classes of chiller equipment. In addition, a single deadline would allow industry members to chart their own courses to climate-friendlier product portfolios while ensuring product safety and manageable transition costs.
In February, Doniger said, “A willingness to redesign even the most complex chillers within eight years is a strong indicator of the industry’s support for our shared climate goals. Looking at the latest information, the EPA decided this schedule will allow manufacturers to maintain or improve energy efficiency and will leave time for improving building codes to allow high-efficiency chillers that use mildly flammable refrigerants, which are two of NRDC’s main concerns.”
When contacted by The NEWS, the EPA provided this statement: “EPA’s SNAP program reviews substitutes for the risk they may pose to human health and the environment and compares them to other available alternatives for the same uses. Recently, we finalized a change of status for certain substitutes, including listing R-134a and R-410A in chillers as unacceptable starting in 2024.
“When considering the status of substitutes, the SNAP program reviews characteristics of each substitute, including its ozone depletion potential [ODP], global warming potential [GWP], toxicity, flammability, occupational and consumer health and safety, local air quality, and ecosystem effects. The SNAP program also considers current knowledge about available substitutes.
“To develop this final rule, the EPA held multiple stakeholder meetings before proposing the Jan. 1, 2024, change-of-status date for chillers and considered public comments when finalizing the rule. Responses to these comments are discussed in the preamble to the rule.
“Starting in 2024, contractors will not be able to install new chillers that use a number of refrigerants with higher GWPs, including R-134a and R-410A. However, they may continue to service those chillers that are already using those refrigerants.”
SAFETY AND EFFICIENCY CONCERNS
Brian S. Smith, director of global marketing, chiller solutions, building efficiency, Johnson Controls Inc., said the company was disappointed in the ruling for several reasons, but is still moving forward.
“First and foremost, we are concerned about safety,” Smith said. “Many HFC refrigerant alternatives are mildly flammable. Although mildly flammable refrigerants can be applied safely, the use of these refrigerants could become wide-spread and used in applications where the refrigerants have not been previously used and proven. Building codes and equipment safety standards need to be updated to address this fact before refrigerant alternatives can be used safely. Also, service technicians will need to be properly trained and equipped to install and maintain systems safely.”
Smith added that the process of updating codes and standards can take more than 10 years, and something radically different would need to happen to quickly drive the adaption of codes and standards while still ensuring safety.
“The movement of the date up to 2024 means everything will have to move faster, which will allow less time to ensure the safe use of alternatives and improve system efficiencies,” he noted.
Other reasons Johnson Controls was disappointed, according to Smith, include the EPA’s decision to not accept the proposal that was jointly agreed upon by AHRI, NRDC, and other industry representatives, and the fact that the greatest impact chillers have on GWP is their efficiency, not the GWP value of the refrigerant.
“Ninety-five percent or more of the emissions associated with chillers are the result of the energy produced to operate the chillers,” Smith said. “As a result, efforts to regulate the use of a refrigerant without considering a chiller’s energy efficiency miss the mark. In fact, we can help safeguard our environment by raising awareness about the dominant effect of energy production and consumption on climate change. Additionally, by understanding the full impact of a chiller’s operation on the environment, we can help guide customers in meeting their sustainability goals.”
Smith concluded that although the EPA’s rule will challenge all chiller manufacturers that have large existing portfolios, Johnson Controls has experience transitioning its chillers in the past and plans to draw from that experience in this next transition.
“We are working toward optimizing our chiller platform to utilize low-GWP refrigerants by Jan. 1, 2024,” he said. “We are beginning to introduce our low-GWP product portfolio that uses R-513A as an option in our existing centrifugal and screw chiller platforms. Doing so reinforces our position and communicates our available options well before the regulations are implemented. We also offer peace of mind with R-134a chillers, which are future-compatible with R-513A, in hopes of eliminating potential refrigerant regulation from the purchasing decision.”
A SWIFT BLOW
Dietz concluded the EPA’s decision also means contractors will have one less year to become familiar with installation challenges associated with using unfamiliar refrigerants.
“It will be a training challenge for the industry regardless and this will only accelerate it,” he said.
Josh Kahn, vice president of Kahn Mechanical Contractors in Dallas, voiced the frustration many contractors feel when it comes to dealing with a constantly changing refrigerant landscape.
“Kahn Mechanical Contractors will be scrambling to educate its workforce and clients on an evolving list of more than a dozen new refrigerants,” Kahn said. “We entrust our government to provide a stabilizing role for our economy. By bowing purely to political and environmental interests, our government has dealt a swift blow to consumers and our entire industry. We anticipate this market instability will last for a minimum of two to three years.”
At Dwyer Engineering in Leesburg, Virginia, company president Matt Dwyer pointed out designing or specifying equipment that uses new refrigerants can be challenging.
“We need manufacturers to supply us with data on performance based on the refrigerant,” he said. “If a manufacturer has not been able to test the refrigerant completely, the company may be hard-pressed to answer our engineering questions.”
However, as Dwyer concluded, “Even difficult challenges can be rewarding though, and we look forward to improving the environment however we can.”