California HFC Regulation May Include GWP Limits

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CARB GWP Limit of 750

California HFC Regulation May Include GWP Limits

Are you aware of the new proposed CARB GWP limits for new stationary refrigeration and air-conditioning systems? The California refrigerant law 2020 could impact your facility. It will be important to know these refrigerant tracking regulations to keep your facilities up-to-date, and for ESG reporting and answering sustainability audit questions.

As such, this post covers the latest on the proposed amendments to the California HFC Regulation, including the CARB GWP limit of 750 for certain air-conditioning equipment. 


Proposed CARB GWP Limits

On July 22, 2020, the California Air Resources Board (CARB) held a public workshop on proposed amendments to the California SNAP Regulation that sets new emission reduction measures, including

  • GWP limits for new stationary refrigeration and air-conditioning equipment; and
  • company-wide emissions reduction targets for retail food businesses. 


Amending the California SNAP Regulation

To give you some brief background, in 2018, CARB adopted a new HFC regulation with HFC prohibitions in certain end-uses, including retail food refrigeration, cold storage warehouses, vending machines, residential refrigeration appliances, and chillers. These were adopted to achieve environmental sustainability and decrease companies’ environmental footprints.

More specifically, California’s initial HFC regulation was adopted in March 2018, which incorporated specific requirements of the partially vacated U.S. EPA HFC prohibitions in certain stationary refrigeration equipment. 

Shortly thereafter, in September 2018, SB 1013 became law, and this adopted all of EPA SNAP Rules 20 and 21 (except as it applies to MVAC) into state law.

These two regulatory policies partly coincided in time, and, as you can guess, it produced stakeholder confusion.

Thus, in January 2020, such regulatory efforts were combined via administrative process and consolidated into one California regulation: the California SNAP Regulation. Check out our free and handy chart on California’s existing HFC regulation now. 

The amendments, discussed below, would affect this regulation. 

Let’s get into the details about the proposed amendments, particularly the proposed equipment prohibitions that would have GWP limits for new stationary refrigeration and air-conditioning systems. 

Proposed GWP Limits for Refrigeration Systems

CARB is proposing a GWP limit of 150 in new stationary refrigeration systems containing more than 50 pounds of refrigerant in new facilities starting January 1, 2022.

Stationary refrigeration equipment in new facilities that would be impacted by this prohibition and effective date include the following general end-uses: cold storage warehouses; industrial process refrigeration (excluding chillers); and retail food refrigeration. (See Table 3 and 4 of the draft regulatory text for full details.)

  • GWP limit of 150 in new stationary refrigeration equipment (in new facilities) starting January 1, 2022


Proposed GWP Limits for Air-Conditioning Systems

For air-conditioning systems, CARB has made the following proposals

  • GWP limit of 750 for new stationary air-conditioning systems (residential and non-residential) starting January 1, 2023; and
  • GWP limit of 750; 1,500; or 2,200 for new chillers (depending on the evaporator temperature) starting January 1, 2024.

In addition to these proposed GWP limits for new stationary refrigeration and air-conditioning equipment, the proposed amendments also include company-wide emissions reduction targets for retail food businesses.
california refrigerant law 2020

Company-Wide Emissions Reduction Targets for Retail Food Businesses

The proposed rules for existing retail food businesses requires them to meet emissions reduction targets, using 2019 as a baseline year, with a 2026 or 2030 effective date.

CARB provides two ways to make such target calculations: 1) Greenhouse Gas Potential Reduction, or 2) Weighted-Average GWP Reduction.

In the public workshop, CARB mentioned that these proposed rules were developed by CARB and refrigeration stakeholders interested in corporate sustainability, including major supermarkets and organizations like the NASRC. 

Ensure Management of High-GWP Refrigerants

Well, that concludes the latest with the California HFC regulation. CARB is scheduled to present these proposed amendments in a CARB Board Hearing in December 2020.

The comment and feedback window closed on August 5th, so the refrigerant geeks at Trakref are now awaiting the 45-day notice, which is expected October 23, 2020.

While we are not for certain what will happen between now and then, one thing is for certain: monitor and manage high-GWP refrigerants now.

What do you think of these proposed amendments? Would love to hear your thoughts. Leave a comment below.

p.s., Don’t forget to check out our free chart on California’s existing HFC regulation. 

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As always, thanks for joining, and be sure to tune in next week for the latest HVACR insight. 
And if you’re looking to work with a company that is always staying on top of the latest in compliance, get in touch with us today. We’re a software corporation that has been in the regulatory compliance software and environmental compliance calendar software space for years. As an environmental software provider, we make sure our refrigerant capabilities will keep you in compliance. Get in touch with a Refrigerant Geek today. 

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