Introduction to New York Refrigerant Regulations
Interested in learning about the State of New York’s refrigerant regulations? This article provides an overview of the state’s various refrigerant regulations. Because in addition to the federal EPA regulations (e.g., Section 608) that govern refrigeration and air-conditioning systems in this state, New York has its own set of additional requirements at multiple levels for environmental sustainability.
Such requirements include a new HFC phaseout; 20-year global warming potential (GWP) methodology; mechanical codes; and building emission reduction goals. Let’s get started so you know how you’re expected to manage your environmental footprint – and what you might want to mention in your ESG reporting.
Part 494 HFC Standards and Reporting
First and foremost, in 2018, New York announced it would be proposing and implementing regulations to phase down HFC refrigerants.
As a result, the Department of Environmental Conservation (DEC) adopted 6 NYCRR Part 494, or “Hydrofluorocarbon Standards and Reporting,” which prohibits various HFC refrigerants in certain end-uses, akin to the U.S. EPA SNAP Rules 20 and 21. The Part 494 regulation applies to any person who does the following with any listed prohibited refrigerant in the applicable end-uses:
- offers for sale;
- or, enters into commerce.
The effective prohibition dates started this year in 2021 and go through 2024.
More specifically, at the start of this year, the majority of prohibitions for the refrigeration end-uses went into effect all throughout the State of New York. These prohibitions apply to mostly new but also some retrofit equipment. Other end-uses are at later times, particularly some new air-conditioning end-uses which have a 2024 compliance date.
Now there is an important caveat with HFC compliance in this state with the fact that the State of New York uses a 20-year GWP methodology for HFCs, which brings us to the next point on the Climate Leadership and Community Protection Act.
(If this is getting more complicated and you have a few questions, you’d like answered, I invite you to join the Refrigerant Geeks LIVE next Thurs., May 13th at 1:30pm CST for our next Compliance Open Mic event.)
Climate Leadership and Community Protection Act
Yes, the phaseout of HFC refrigerants established in Part 494 uses the methodology of the 20-year global warming potential (GWP), which is found in the Climate Leadership and Community Protection Act (Climate Act).
Under the Climate Act, New York set the nation’s most comprehensive greenhouse gas limits, and every sector of New York’s economy must reduce its carbon emissions to 40% by 2030 and to 85% by 2050. With these goals, New York state is set to achieve net zero greenhouse gas (GHG) emissions by 2050.
Short lived climate pollutants, like HFCs, are an important element of that.
In fact, HFC emissions will be measured in carbon dioxide-equivalents using a 20-year GWP.
In a December 2020 press release, it states that the regulated greenhouse gas emissions per the Climate Act “will be measured in carbon dioxide-equivalent units using a 20-year Global Warming Potential.” Utilizing the 20-year GWP methodology, the HFC refrigerants you have in your inventory now would have a much higher emissions impact.
In addition to this, there’s another layer of requirements that you should consider in the City of New York—that is, Local Law 97.
Local Law 97
Similar to the Climate Act, the City of New York passed a mandate aimed at significantly reducing greenhouse gas emissions (GHG) by 2050. This mandate, Local Law 97, requires buildings that are larger than 25,000 square feet in size to reduce 40% of its GHG emissions by 2030 and to reduce 80% of its GHG emissions by 2050.
Of course, the term GHG here includes some refrigerant types—namely, hydrofluorocarbons (HFCs).
While the initial compliance periods are a few years away (starts in 2024), building owners and managers should begin planning ahead. Because once the compliance period begins, building owners will be required to submit annual reports that include emissions intensity—or, else have to pay fines.
Now, we’ve mentioned the HFC phaseout, the 20-year GWP methodology, the building emissions reduction targets… there is one more thing that is worth mentioning while we are on the topic of discussing New York’s refrigerant regulations, and that is the state’s mechanical code.
NY Mechanical Code
The state’s mechanical code has its own set of requirements, and not just for HFCs but also for the other classes of refrigerants. The code “governs the design, installation, construction, and repair of refrigeration systems that vaporize and liquefy a fluid during the refrigerating cycle.”
Among many things, there are certain refrigerant restrictions that one must adhere to through refrigerant tracking for corporate sustainability. In fact, “refrigerant applications, maximum quantities and use shall be restricted in accordance with Sections 1104.3.1 through 1104.3.4.” Furthermore, as an example, 1104.3.3 states, “The total of all Group A2, B2, A3 and B3 refrigerants other than R-717, ammonia, shall not exceed 1,100 pounds (499 kg) except where approved.”
Of course, it’s important to note that the NY mechanical code is in the background in addition to the above-mentioned new requirements.
Trakref Can Help You Navigate NY Requirements
Well, that concludes the overview of the New York refrigerant regulations.
We hope this provides an overlook of the requirements you should know about for refrigerant tracking and sustainability audit questions. We will be talking in more detail about what’s going on with refrigerant regulations in the State of New York in our LIVE Compliance Open Mic next Thurs., May 13th at 1:30pm CST.
Reserve your spot now to learn more, and get your questions answered about New York’s refrigerant regulations. As always, thanks for joining us. Right here on the Trakref blog.
And if you’re looking to stay on top of the latest regulations in your own refrigerant tracking, get in touch with Trakref 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 with new regulations. Get in touch with one of our Refrigerant Geeks today.
We are refrigerant geeks with proven techniques to manage leaks in our HVAC/R and refrigerant management software.