CARB Requirements Gathering Input
CARB Requirements are Collecting Feedback
The California Air Resources Board (CARB) as part of the California Code of Regulations is working on creating new requirements intended to help the state achieve the emissions reduction goals for air pollution of SB1383. They are specifically aimed at reducing high global warming potential (GWP) HFCs in stationary refrigeration and air conditioning equipment for environmental sustainability. Last week they invited stakeholders from the HVAC/R industry, including equipment manufacturers and retailers, to a presentation and open discussion of these proposed measures. The goal of the meeting was to get feedback from the people who would be directly affected by these measures to get their input on how to make them feasible.
Stationary refrigeration equipment includes refrigerators, freezers, and other contained systems that use refrigerant to cool items stored inside the system. Stationary AC chillers use the refrigeration process to cool buildings or rooms.
What Was CARB Hoping to Learn?
CARB had completed their own analyses on setting equipment GWP limits, but they wanted to have feedback from people working in the industry and with the equipment so they could properly assess the following and add them to CARB requirements:
✔ Costs and benefits to businesses, individuals and the environment
✔ Impact on jobs, investment, and income in the State of California
✔ Fiscal impacts
✔ Regulatory alternatives
Are the reductions feasible? Are the cost estimates realistic? Do they align with current corporate sustainability initiatives to decrease companies’ environmental footprints? Getting the final measures right for these sectors is crucial to achieving the required 40% reduction in HFC emissions by 2030. And by “getting them right” we mean putting in place measures that businesses will be amenable to, and that will not have a negative impact on the sectors. Especially considering that together they are the sources of the majority of HFC emissions according to CARB 2018 research.
Proposed Equipment GWP Limits
Decisions were not being made on the call, and this was not an announcement of final legislation. CARB presented what they had so far with regard to a fiscal analysis, and then followed with proposed language for the group to discuss the CARB requriements.
Beginning January 1, 2022 new stationary refrigeration equipment containing more than 50 lbs. of refrigerant must use those with a GWP less than 150. This change applies to commercial refrigeration for both retail and non-retail, industrial process refrigeration, and cold storage.
Stationary AC Equipment
Beginning January 1, 2022 new AC equipment must use a refrigerant with a GWP less than 750, and new chillers will follow January 1, 2024 to maintain consistency with SB1030. This affects manufacturers, wholesalers/distributors, contractors and technicians.
In addition to record keeping and reporting, dates and refrigerant types must be included on labeling.
Conversion Can be Tricky
The CARB staff laid out their estimates on costs which generated a good deal of discussion, specifically among the Stationary Refrigeration group. More specifically, the grocers. The definition of “New Refrigeration Equipment” according to CARB’s 2018 regulation is:
(1) Any refrigeration equipment that is first installed using new or used components;
(2) Any refrigeration equipment that is modified such that it is: (i) Expanded after the date at which this subarticle becomes effective, to handle an expanded cooling load by the addition of components in which the capacity of the system is increased, including refrigerant lines, evaporators, compressors, condensers, and other components; o
r (ii) Replaced or cumulatively replaced after the date at which this subarticle becomes effective, such that the capital cost of replacing or cumulatively replacing components exceeds 50 percent of the capital cost of replacing the entire refrigeration system.
How does one define something as a “new system” if most changes are done over a period of time, piece by piece? And have they considered the difference between a retrofit and a full remodel? Each requires a vastly different investment of time and capital. And much of the equipment is not readily available.
The manufacturers had a lot of questions about the proposed labeling requirements. There already is a good deal of inconsistency in the practice. We were recently on some rooftops tagging equipment for trakref® and were seeing labels on some equipment, some with the model year and other information faded or damaged labels, and none at all on others. Manufacturers in attendance were questioning whether they should invest in plastic tags, if it’s feasible to print them directly on equipment data plates, or if instead it should be the responsibility of the owner/user or the installer. There were specific suggestions tossed back and forth, but…
CARB is Not Done Working
While CARB wanted to wrap up January 1, 2020, The CARB staff is going to continue holding stakeholder meetings and public workshops about proposed measures through Fall 2019. The feedback gathered is what will allow them to move on to their deep-dive economic analysis, and they will then publish their findings for public comment spring of 2020. In May of 2020 the staff will present their completed proposal to the Board. At this point the proposed measures will either be passed, or the Board will recommend changes.
~ as presented by globalFACT and AHRI August 2019
How Can You Prepare?
1. Begin to evaluate existing inventory and determine how much of each gas is on hand installed in your systems. Be careful you don’t underestimate your system charges. This could hurt you later on.
2. Determine the age/vintage of all your equipment. Older equipment will be easier to rationalize for replacement, and you will want to anticipate that older systems will need more care and likely more refrigerant.
3. Set thresholds for repair/replacement. For example:
✔ If the leak rate exceeds 20%, replace it.
✔ If the unit leaks more than 3x in a year, replace it.
✔ If the cost goes over 30% of the value of the unit on any given repair, replace it.
4. Meet with your contractor and explain your goals to them.
5. Ensure you have documentation on all maintenance actions, and record them against the equipment. Keep records and be prepared to review/discuss with your contractor or team. It’s best to do this quarterly.
6. Be aware of your options. If you buy/install systems that will be obsolete in the next few years, then you might end up in a situation where you have a hard time servicing the system.
The key is to know what you are working with, to be able to plan for your needs in the future, and to make sure to not over invest in equipment that has a short planned life.
It’s a lot to consider, but trakref® can help. 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 help you with CARB and other compliance initiatives, as well as helping you with ESG reporting and answering sustainability audit questions. Get in touch with a Refrigerant Geek today.
Refrigerant tracking is what we do for a living. Trakref® helps you manage leaks and extend equipment life, guide maintenance technicians, and link teams and property owners together to check off all the boxes on that list. We’ll continue to keep up with refrigerant management regulations as they evolve, so stay tuned. Call (615) 834-0233 to learn more about how our industry-leading software can help you stay compliant!
Ted is the President & CEO of Trakref, a cloud-based HVAC/R and refrigerant management software company that provides unprecedented solutions for commercial properties. He has spent more than 20 years in the HVAC/R industry, even owning and operating one of the nation’s largest refrigerant reclaim and recycling companies.