IIAR

The International Institute of Ammonia Refrigeration and its industry partners have petitioned the Environmental Protection Agency to use its authority under the American Innovation and Manufacturing Act to restrict the use of hydrofluorocarbons within the refrigeration sector. The AIM Act is a new climate law passed in December 2020.

The rule proposes an allowance allocation and trading system, which will determine the amount of HFCs an entity can produce or consume, and it creates the mechanism to phasedown domestic HFCs.

The agency’s first proposed rulemaking under the AIM Act would set the HFC production and consumption baseline levels from which reductions will be made, establish an initial methodology for allocating HFC allowances for 2022 and 2023, and create a robust, agile, and innovative compliance and enforcement system, the agency said. IIAR’s petition, which was sent to EPA Administrator Michael Regan, calls for the EPA to limit the use of refrigerants of 150 or greater GWP in the refrigeration sector in general (both commercial and industrial). The petition identifies several areas, including food retail, cold storage warehouses, and manufacturing, where these limits could be set in place.

In the petition, Gary Schrift, IIAR’s president, said the association believes that California’s framework for HFC phasedown can serve as a good model for EPA’s implementation of the AIM Act. However, IIAR petitions to go further regarding Chillers for Industrial Refrigeration. “Subsection (i) of the AIM Act on ‘Technology Transitions’ authorizes EPA to ‘restrict, fully, partially or on a graduated schedule, the use of a regulated substance in the sector or subsector in which the regulated substance is used,’” according to the petition.

IIAR wrote that the technology has existed for decades in the design and manufacturing of chillers for industrial process refrigeration using natural refrigerants for all temperature ranges. “The use of natural refrigerants including CO2 , ammonia, and hydrocarbons will significantly and positively impact global warming reduction goals using refrigerants with ultra-low refrigerant GWP values and increased operational energy efficiency of these refrigeration systems,” IIAR wrote in the petition.

This partial restriction would apply to refrigerants used in “new” equipment, which includes a replacement of an existing refrigeration system as defined in the CARB Proposed Regulation Order under the definitions for “New Chiller “and “New Refrigeration Equipment”.

The association recommended the chillers for industrial process refrigeration restriction take effect on Jan. 1, 2026, to provide manufacturers, contractors, and owners the time to meet the needs created by this excellent single-step approach. IIAR is joined by co-petitioners, the Refrigerating Engineers and Technicians Association, and the Ammonia Safety & Training Institute.