California has been planning to enact regulations to drastically decrease emissions of super-pollutant hydrofluorocarbons (HFCs) from the cooling sector. The California Air Resources Board (CARB) convened a working group this week to discuss details of the proposed regulations, which aim to reduce HFCs in supermarkets, air conditioners, ice rinks, warehouses and other cooling systems. CARB has its work cut out to meet the state’s 2030 target of reducing HFC emissions by 40% below 2013 levels, about half of today’s levels. HFCs are the fastest growing greenhouse gases in the world, so reducing emissions means curbing growth and bending that curve downward in fast order.
There was much discussion on the details and timing, but overall CARB’s proposal received supportive input from industry stakeholders ranging from manufacturers to supermarkets. Following the meeting EIA sent a letter urging CARB to follow through on the proposed measures, maintain proposed dates, and to examine additional policies addressing end-of-life refrigerant emissions.
Here are four key takeaways from the meeting this week, and what to expect next:
1. HFC bans will apply to replacing existing cooling systems CARB has been proposing for some time to ban HFCs above a global warming potential (GWP) of 150 for most large refrigeration equipment and 750 for air conditioning. The bans are intended to cover purchases of new systems, which includes not just new building construction, but major remodels or replacement of existing systems. CARB requested input on defining inclusion of replacement systems, and stakeholders urged CARB to reach a decision quickly in order to provide certainty ahead of the rules going into effect.
2. Timing is everything Cooling systems like those in supermarkets last for 15-20 years or more, so achieving emission reductions by replacing old HFC systems with new ones takes time. CARB has proposed that bans take effect in 2022 for refrigeration and 2023 for AC so there’s time for enough systems to be replaced before 2030. For refrigeration applications like supermarkets, low-GWP alternatives are already available on the market, while for AC the date provides time for standard and codes updates to allow for their availability to increase in some types of equipment over the next several years. Requests by some companies to delay bans were met with a clear response from CARB: a delay of even one year will cause us to miss the 2030 target. To consider these kinds of requests, industry must propose another cost effective policy alternative that can deliver the required emission reductions.
3. Converting the installed base, servicing ban and incentives are key Meeting the 2030 target will require a significant portion of existing cooling systems, or the installed base, to be replaced with low-GWP alternatives. Some leading supermarkets are already adopting low-GWP cooling solutions, but will have to increase adoption of these alternatives in their existing stores during remodels or when the systems reach the end of their useful life. CARB’s policy proposal must encourage replacement of these existing systems with low-GWP refrigerants (<150), while still allowing lower cost ‘retrofits’ of these systems to drop-in or near drop-in alternative refrigerants with medium-GWPs (600-1500). The two complimentary policy approaches of a servicing ban and incentives can help encourage a more rapid conversion of the installed base. The first is CARB’s proposal to ban the sale of new HFC gases above a GWP of 1500 for servicing the installed base, while still allowing reused or reclaimed HFCs to be used for this purpose. This servicing ban will increase use of reclaimed refrigerant, and encourage retrofits to lower GWP refrigerants under 1500.
The second approach is to offer additional incentive funding for projects replacing existing systems with low-GWP (<150) systems, helping cover any added costs of the more extensive upgrades required to replace an old HCFC or HFC system with a truly low-GWP system. California’s legislature recently approved $1 million in funding for 2019-20 to create an incentive program for reducing F-Gases. It’s a very limited amount, but designed effectively, incentives could make a significant difference and be scaled up over time once demonstrated.
4. Search, Reuse, & Destroy: the biggest mitigation opportunity available California and other states considering how to achieve similar HFC emission reduction goals cannot forget about addressing the full refrigerant lifecycle through refrigerant management: reducing leaks and increasing reclamation or destruction of refrigerants at their end of life. This is the single biggest mitigation opportunity available globally, more than even installing wind turbines or solar panels.
California’s policy efforts to accelerate the replacement of old systems using HFCs could actually accelerate emissions in the near term, unless the gases removed from replaced systems are being reclaimed or destroyed. Right now, only a very small portion are – less than 20%. There are a number of policy approaches to addressing these ‘banks’ of existing refrigerants. Climate leading states including California have a major opportunity to implement policies in this area, such as by incorporating reclamation and destruction into the proposed incentive program, through required reporting and verification of refrigerant stockpiles and disposal by end users of large cooling systems, or through implementing fee/rebates on refrigerant recovery as part of extended producer responsibility schemes similar to those in place in countries like Australia and Canada.
Each pound of refrigerant recovered and destroyed today is a pound immediately not emitted into the atmosphere. If California needs additional emission reductions by 2030, this should be the place to look.
What Next: A Rapid Timeline for Finalizing Rules
CARB is expected to hold one more working group meeting before aiming to approve final regulations in May 2020. A second regulation will follow to implement the servicing ban or other elements of refrigerant management changes needed to meet the 2030 target. They have invited stakeholders to share any additional informal commentary and policy suggestions as soon as possible, with a formal written comment period planned for next April.