Air Conditioning Industry Regulations
The air conditioning industry is preparing for the next round of regulations. Although the industry has a significant amount of experience in increasing efficiency requirements and transitioning to new refrigerants, this round will be more complex as both transitions are set to happen concurrently in 2023.
The U.S. Department of Energy (DOE) has the authority to establish minimum efficiency standards for air conditioning and heat pump equipment. The next set of energy efficiency increases will impact both residential and commercial roof top equipment.
Energy Efficiency Requirements
Residential Air Conditioning / Heat Pump Energy Efficiency Standards
The tables below show the minimums for residential air conditioning and heat pumps currently, and the new minimums taking effect in 2023. Along with the increase in efficiency, a new test procedure will also be entering into force: 10 CFR Appendix M1 to Subpart B of Part 430 - Uniform Test Method for Measuring the Energy Consumption of Central Air Conditioners and Heat Pumps. Systems tested for this method will use new nomenclature SEER2/HSPF2/EER2.
Because of the new test procedure, the increase in efficiency is not as transparent as in the past, but effectively there is a 1 SEER increase for both the north and south. To better correlate the old and new, the 2023 table below includes the new SEER2/HSPF2/EER2 and the equivalent SEER/HSPF/EER values in parenthesis.
Minimums for Residential Air Conditioning and Heat Pumps
Today – Appendix M
*11.7 EER limit for equipment ≥ 45K BTU/Hr
2023 – Appendix M1
*9.8 EER2 limit for equipment ≥ 15.2 SEER2
Commercial Air Conditioning
Commercial rooftop efficiency is represented as Integrated Energy Efficiency Ratio (IEER). The 2023 federal minimum efficiency increase is roughly a 15% increase relative to the 2018 efficiency levels.
Solutions to Meet Efficiency Requirements
Defining New Air Conditioning Equipment
As part of the regulatory language, California has defined what they consider to be “New Air Conditioning” and “New Chillers.” This encompasses new equipment and also provides a means to prevent piece-by-piece replacement over a short period of time:
“New Air-conditioning Equipment” means any air-conditioning equipment or system that is first installed using new or used components, or a combination of new or used components, or a new condensing unit in an existing system, or a new evaporator unit in an existing system.
“New Chiller” or “New Chiller Equipment” means any chiller equipment or chiller system applicable to chiller end-use sectors listed in Table 3, section 95374(c) that is:
(A) First installed using new or used components, or a combination of new or used components; or
(B) Modified such that:
(i) The capacity is increased through the addition of motor-bearing components, including evaporators, compressors, or condensers, or
(ii) The system has experienced replacements of motor-bearing components in full or exceeding 50 percent of the capital cost of replacing all the motor-bearing components in the entire chiller system.
Air-conditioning equipment (new), residential and non-residential
Refrigerants with a GWP of 750 or greater
Prohibited as of January 1, 2023
Chillers – Air-conditioning, Industrial Process Cooling
Chillers (new) designed for minimum evaporator temperature > -15°F (-26°C)
Refrigerants with a GWP of 750 or greater
Prohibited as of January 1, 2024
Emerson Residential AC Solutions to Meet Efficiency Requirements
Emerson offers a variety of residential compressor solutions to help achieve upcoming efficiency requirements.
Copeland™ ZPK7 (R410A) / YPKA (R32) / YAK1 (R454B)
Emerson Commercial AC Solutions to Meet Efficiency Requirements
Emerson offers a variety of commercial compressor solutions to help achieve upcoming efficiency requirements.
Copeland™ YPKA (R32) scroll compressor
Copeland™ YAK1 (R454B) scroll compressor
Lower GWP Refrigerants
Refrigerant transitions have occurred several times over the history of air conditioning, with the most recent driven by the signing of the Montreal Protocol.
AHRI Safe Refrigerants Transition Task Force
AHRI has formed a Safe Refrigerant Transition Task Force to evaluate and address gaps across the entire supply chain in the safe refrigerant transition to low global warming potential refrigerants. The task force is made up of AHRI members and stakeholders employed with contractors, government agencies, the fire service, unions, training organizations, and other businesses and consists of the following working groups:
Bulk Storage/Manufacturing Facilities
U.S. Department of Transportation (DOT)/Shipping/Packaging and Handling/Warehouse
Technical experts interested in participating in the working groups are particularly encouraged to contact AHRI.
EPA Section 608 Rulemaking
On March 11, 2020, the EPA published a change to the Section 608 Refrigerant Management Program. This rule modifies the requirements for substitute refrigerants, such as HFOs and HFCs. It does not affect the requirements for ozone-depleting substances. The proposal to rescind parts of Section 608 as they applied to HFOs and HFCs was first presented in October 2018 and was met with strong opposition from AHRI, ACCA, multiple state attorney generals and environmentalists.
Effective April 10, appliances with 50 or more pounds of substitute refrigerants will no longer be subject to the requirements at 40 CFR 82.157, including:
Repairing appliances that leak above a certain level and conducting verification tests on repairs;
Periodically inspecting for leaks;
Reporting chronically leaking appliances to the EPA;
Retrofitting or retiring appliances that are not repaired; and
Maintaining related records.
The EPA is not rescinding the other refrigerant management provisions that were extended to non-ozone depleting refrigerants, including:
Anyone purchasing refrigerant for use in a stationary appliance or handling refrigerants (such as air-conditioning and refrigeration service technicians) must be section 608-certified;
Anyone removing refrigerant from a refrigeration or air-conditioning appliance must evacuate refrigerant to a set level using certified refrigerant recovery equipment before servicing or disposing of the appliance;
The final disposer (such as scrap recyclers or landfills) of small appliances, like refrigerators and window air conditioners, must ensure and document that refrigerant is recovered; and
All used refrigerant must be reclaimed to industry purity standards before it can be sold to another appliance owner.
Phasing Out R-22
The 1987 Montreal Protocol treaty sought to phase out ozone-depleting substances, which included R-22. The treaty, ratified by 197 countries including the U.S., Canada and Mexico, resulted in an HCFC phaseout schedule. As of January 1, 2020, under the Environmental Protection Agency’s (EPA) Clean Air Act, virgin R-22 can no longer be produced in or imported to the U.S. While systems with R-22 can still be serviced, they will rely on existing recycled or stockpiled quantities, meaning this phaseout will likely lead to increased system retrofit solutions as the R-22 supply begins to decrease.
The Transition to Lower GWP Refrigerants
The EPA has the authority to regulate refrigerants through the Significant New Alternatives Policy Program (SNAP). In 2015, the EPA released SNAP rule 20, which began to transition certain end uses to lower global warming potential (GWP) refrigerants. In 2016, the EPA released SNAP rule 21, which added chillers (positive and centrifugal) to the end uses transitioning away from higher GWP refrigerants. A court challenge later vacated both SNAP rule 20 and 21 at the federal level. With that ruling, it was determined that Section 612 of the Clean Air Act did not give the EPA the authority to regulate HFC refrigerants based on GWP, and they are no longer enforcing refrigerant delistings.
In the absence of a federal program, refrigerant phase-downs have begun at the state level. A coalition of 24 states and Puerto Rico, known as the U.S. Climate Alliance, has committed to reducing short-lived climate pollutants (SLCP) and hydrofluorocarbons (HFC). State adoption of the vacated EPA SNAP rules 20 and 21 is the first step for regulating refrigerants being considered by many of these states. California led the way, adopting SNAP rules 20 and 21 in 2019. As mentioned above, the impact on air conditioning end-uses is limited to chillers. Beginning in 2024, positive displacement and centrifugal chillers will no longer be able to use two of the most common refrigerants, R-410A and R-134a, among others. Additional states, including Washington, Vermont, and New Jersey, have followed their lead, with all Climate Alliance states likely to do so in the future.
In addition to adopting the SNAP rules, California has proposed additional refrigerant regulations. As part of this bill, the California Air Resources Board (CARB) has proposed a GWP limit of 750 for all new stationary air conditioning systems in both commercial and residential applications beginning January 1, 2023. The bill also includes the same GWP limit for new comfort cooling chillers beginning January 1, 2024. Many of the most common refrigerants being considered for 2023 are classified mildly flammable, or A2L. Because of the flammable characteristics, codes and standards updates were required to allow for their use in residential and commercial systems. Model code and local building code adoption of these new standards are currently underway.