Regulatory Updates: Refrigerants and EnergyE360 Forum • Houston, TX • October 25, 2018

Jennifer ButschRegulatory Affairs Manager, Air ConditioningEmerson

Dr. Rajan RajendranV.P., Systems Innovation Centerand SustainabilityEmerson

This presentation is intended to highlight changing developments in the law and industry topics. The law is frequently evolving and information and publications in this presentation may not reflect the latest changes in the law or legal interpretations. The statements and information provided in this presentation should not be construed as legal advice or legal opinion regarding any specific facts or circumstances, but is intended for general informational purposes only. The views and statements expressed during this presentation are the personal opinions of the presenter and do not represent those of Emerson Climate Technologies, Inc. or its affiliated companies. You should consult an attorney about your situation and specific facts and you should not act on any of the information in this presentation as the information may not be applicable to your situation. Although all statements and information contained herein are believed to be accurate and reliable, they are presented without warranty of any kind. Information provided herein does not relieve the user from the responsibility of carrying out its own tests and experiments. Statements or suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patents. This presentation may not be copied or redistributed without the express written consent of Emerson Climate Technologies, Inc.

Disclaimer

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Refrigerants

Kigali Amendment to Montreal Protocol — October 15, 2016

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• Global agreement on HFC phase-down reached by 197 countries of the world in Kigali, Rwanda “38th Meeting of the Parties to the Montreal Protocol on Substances That Deplete the Ozone Layer”

• Still under consideration by the White House

• Ratification in the U.S. could lead up to 33,000 additional manufacturing jobs and increased global market share

Kigali Amendment* ratified by 53 countries;goes into effect Jan. 1, 2019

* http://conf.montreal-protocol.org/meeting/mop/mop-28/final-report/English/Kigali_Amendment-English.pdf

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A2 Countries(U.S., Canada, etc.)

A5 CountriesGroup 1

A5 Countries Group 2(India, Iran, Pakistan, Iraq, GCC)A2 Countries

(Belarus, Russian Federation, Kazakhstan, Tajikistan, Uzbekistan)

2024 Freeze

2028 Freeze

Europe and Canada HFC Phase-down Quotas and Application Limits

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E.U. F-Gas phasedown more aggressive than Kigali. Refrigerant price pressures over the last two years. Canada following Kigali phasedown steps.

A2 Countries

(US, Canada)

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A5 CountriesGroup 1

A2 Countries(Belarus, Russian Federation,

Kazakhstan, Tajikistan, Uzbekistan)EU F-Gas

A5 Countries Group 2(India, Iran, Pakistan, Iraq, GCC)

Domestic refrigeration

U.S. EPA Continues to Roll Back Previous Regulation

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• SNAP Rules 20/21– Currently in litigation, EPA not enforcing HFC delistings– New regulation forthcoming (draft regulation by January 2019)

• Clean Air Act Section 608– Proposal to exclude HFCs from Section 608 Refrigerant Management Program (RMP)

• Would still apply to ozone-depleting substances– Appliances with 50 or more pounds of refrigerant would no longer be subject to:

• Conduct leak rate calculations when refrigerant is added to an appliance• Repair an appliance that leaks above a threshold leak rate• Conduct verification tests on repairs• Conduct periodic leak inspections on appliances that exceed the threshold leak rate• Report to EPA on chronically leaking appliances• Retrofit or retire appliances that are not repaired• Maintain related records

EPA looking for stakeholder feedback on how to proceed with SNAP rules, given the court’s ruling. States may continue to adopt SNAP rules 20/21 as they were and follow existing RMPhttps://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations

California Leads the Way in Reducing HFC Emissions

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• California SB 1383: The Super Pollutant Reduction Act of 2016– Established HFC reduction goal of 40% by 2030– California Air Resources Board (CARB) proposed two phases of implementation

• CALSNAP: Adopt Select SNAP Rules to Prevent Backslide – Adopted March 23, 2018– The regulation prohibits the use of HFCs in new equipment and materials in California

for the following end uses:• Supermarkets and remote condensing units• Refrigerated food processing and dispensing equipment• Stand-alone or small self-contained refrigeration units• Refrigerated vending machines• Foams used in buildings and other places

– Compliance dates modified from original SNAP rules

Scope of March regulation limited to certain commercial refrigeration and foam end useshttps://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383https://www.arb.ca.gov/regact/2018/casnap/15daynotice.pdf

California Adopts Complete SNAP Rules 20 and 21

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• California Senate Bill 1013: California Cooling Act– Signed into law Sept. 2018

– Requires the adoption of SNAP rules 20 and 21 as they read on January 3, 2017, with the ability to modify dates

– Allows CARB to list or delist refrigerants, regardless of status, at a federal level

– Prohibits selling, leasing or renting equipment inconsistent with provisions

– Establishes incentive program to promote the adoption of new refrigerant technologies

Adopted into law, in effect now. Will not require additional rulemaking by CARB

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB1013

Pending CARB Rulemaking: SLCP Proposals to Reduce HFCs to Fill Gap

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AC will begin first; board meeting and final regulation scheduled for Dec 2019• GWP<750: Stationary air conditioning — effective 2023• No additional rule making for chillers — will rely on SNAP rule 21 now in place per SB 1013

Commercial refrigeration will follow; board meeting and final regulation scheduled for Mar 2020• GWP<150: Stationary refrigeration >50 lbs — effective 2022

Sales Restrictions on Refrigerants• No production, import, sales, distribution or entry into commerce of refrigerants with

GWP≥1,500 effective in 2022• Open to use of reclaim for service, proposed sales exemption for 410A

AHRI and NRDC jointly released a statement in favor of CARB implementing a low-GWP limit effective January 1, 2023 for stationary AC and January 1, 2024 for chillers.

https://ww2.arb.ca.gov/resources/documents/workshop-hydrofluorocarbon-emission-reduction-measures

Other States

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• U.S. Climate Alliance states likely to adopt similar HFC reduction goals/regulation– New York, Maryland and Connecticut have

already announced plans to do so

AHRI and NRDC have jointly asked for states to be consistent in approach to California.

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The Global Refrigerant Standards and Codes ‘Process’

ASHRAE 34 Designation and Safety Classification

of Refrigerants

Refrigerant Standards/Regulations

Safety StandardsBuilding & Other Codes Local Codes

ISO-817Refrigerants —

Designation and Safety Classification

ASHRAE 15Safety for Commercial Refrigeration Systems

UL 621Ice Cream Makers

UL 471Commercial Refrigerators

and Freezers

UL 60335-2-40 3rd

Heating and Cooling Equipment

ISO-5149Safety and Environmental

Requirements

IEC 60335-2-40 6th

Heating and Cooling Equipment

IEC 60335-2-24Refrigerating Appliances,

Ice Cream and Ice Makers

IEC 60335-2-89Commercial Refrigerating

Appliances

IMC/UMC — International Mechanical Code

NFPA 1 — Fire Code

Country-specific Building and Fire Codes

State, County and City Building Codes

Local Building Codes?

U.S.-specific

International

DOT TransportationStandards

GHS TransportationStandards

EPA SNAPSignificant New

Alternatives Policy Program

EN-378Refrigerating Systems and

Heat Pumps

Insurance Company Rules

Insurance Company Rules

Pressure Vessel Standard(PED, JIS, etc.)

Equipment Application

ASME Section VIIIPressure Vessels

ASHRAE 15.2Safety for Residential

Refrigeration Systems

IRC — International Residential Code

IBC/IEBC — International Building Codes

IFC — International Fire Code

NFPA 101 — Safety Code

Country Regulations(i.e., Switzerland, Australia

Montreal Protocol(GWP)

(Developing)

Montreal Protocol(GWP)

(Developing)

B52 (Canada)Safety for Commercial

Refrigeration

Source: Richard Lord, UTC Building & Industrial Systems

FlammableRefrigerants

Research

Revisions Required to Support 2L, 2 and 3 Refrigerants

ongoing Jan. 2018 2018–2021 2018–2029

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Summary Regarding Charge Limits — Now and ProposedRefrigeration– UL250 (household refrigerators and freezers)

• A2 – 225g (8.0 oz) • A3 – 50g (1.7 oz)

– UL471 (commercial refrigerators and freezers, incorporated or remote)• A2/A2L – 500g max. (17.7 oz)• A3 – 150g max. (5.3 oz)

– UL60335-2-89 (particular requirements for commercial refrigerating appliances with an incorporated or remote refrigerant unit or compress)• IEC: A2L: 150g now, 1.2kg being proposed, A3: 150g now,

500g being proposed (mitigation required) • Now, charges larger than 150g, use ISO5149

– UL60335-2-24 (commercial refrigerating appliances — ice makers and ice cream appliances)• The second edition increased flammable refrigerants from 50g

to 150g to harmonize the IEC.

– UL1995 (heating and cooling equipment)• Refrigeration condensing units use UL471.

Air Conditioning – UL1995 (heating and cooling equipment), UL 1995 merging into

UL2-40, 2020 new products, 2022 all products– UL 1995 being phased out; 2020 new products, 2022 all products.

Will be replaced by UL 2-40.• A2/A2L – not allowed• A3 – not allowed

– UL60335-2-40 (particular requirements for electrical heat pumps, air conditioners and dehumidifiers)

• A2/A2L/A3 — Based on room size calculations and mitigations used – UL: 3kg for A2Ls, A3s not allowed currently– IEC is aiming for: ~60–80kg A2Ls and 1kg A3s

– UL484 (room air conditioners), merging into UL2-40, 2020 new products, 2022 all products• Based on room size calculations

– Amin = (M/(2.5 X(LFL)(5/4) X h0))– A3s - 114g max

NOTE:Flammable refrigerants are only allowed for new equipment, not retrofits, because OEM design modifications will be needed.

Energy

2023 DOE Rooftop Minimums Can Potentially Drive Major Commercial Equipment Re-designs and New Tiers

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Higher efficiency requirements will lead to increased use of modulation technologies. 30% increase in IEER between 2017 and 2023.

12.912.4

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14.814.2

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+15%+14%

National IEER Minimums, by Tonnage System Architecture Mix

Today Future

2-Circuit Fixed

VS

Tandems, 3+ stages

1-Circuit Fixed

Two-stage

Tandems

2-Circuit Fixed

+15%

Commercial Refrigeration Currently Has Six Significant Targets Over the Next Three Years

2016 2017 2018 2019 2020

Supermarket (Rack)

Walk-In (Remote CDU)CoolersFreezers

Reach-In (Stand-Alone)

Coolers <2,200 BTU>2,200 BTU

Freezers

IceMachines

Soft Serve/Frozen Bev.

<2,500 GWP

<2,500 GWP

20–40%

<600 GWP

<1,500 GWP

30–50%

5–15%

1/1/17

1/1/18

3/27/17

1/1/18

7/10/20

1/1/19

1/1/20

20–30%

<600 GWP

1/1/21

DOE Published Final Rule

EPA no longer enforcing previously prohibited HFC substances, but California is. Additional states likely to follow.

EPA-Approved (Listed) R-452A 7/21/17

7/10/17

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CARB Refrigerants

<1,500 GWP

2021

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U.S. Dept. of Energy Regulations SummaryEnergy Mandates Have Significantly Evolved

• Effective January 2020 on new equipment– MT June 2017: report AWEF/label– MT Jan. 2020: AWEF enforcement– LT Jan. 2020: report/label/enforcement

• Effective January 2018 on new equipment

• ACIM measured in kWh/100 lbs ice• Each equipment class assigned

equation

Walk-In Coolers and Freezers (WICF)3

Automatic CommercialIce Makers2

5–25% Energy Reduction Required

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1.84Baseline

3.92“MaxTech”

4.79STD

3.12FinalSTD

Each dot representsan added technology.

30–37% Energy Reduction Required

2 https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=53&action=viewlivehttps://www.energystar.gov/products/commercial_food_service_equipment/commercial_ice_makers

3 https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=56&action=viewlive

• Measured in three major components using AHRI-1250– Each equipment class assigned

equation– Variable: Q = system capacity

Questions?

DISCLAIMERAlthough all statements and information contained herein are believed to be accurate and reliable, they are presented without guarantee or warranty of any kind, expressed or implied. Information provided herein does not relieve the user from the responsibility of carrying out its own tests and experiments, and the user assumes all risks and liability for use of the information and results obtained. Statements or suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patents. The user should not assume that all toxicity data and safety measures are indicated herein or that other measures may not be required.

Thank You!

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