{"id":3708,"date":"2022-07-18T18:11:34","date_gmt":"2022-07-18T16:11:34","guid":{"rendered":"https:\/\/www.matelex.com\/?p=3708"},"modified":"2024-10-20T00:11:46","modified_gmt":"2024-10-19T22:11:46","slug":"the-aim-act-refrigerant-regulations","status":"publish","type":"post","link":"https:\/\/www.matelex.com\/en\/the-aim-act-refrigerant-regulations\/","title":{"rendered":"The AIM Act is Here – Are You Ready for New Refrigerant Regulations?"},"content":{"rendered":"\n
The American Innovation and Manufacturing Act<\/a> or AIM Act<\/a> is a very complex subject, and many aspects have not yet been defined. The law passed in 2020 gave the Environmental Protection Agency (EPA)<\/a> the authority to regulate hydrofluorocarbons (HFCs)<\/a> and their use in commercial HVAC & Refrigeration. It allowed for the following categories of regulation: <\/p>\n\n\n\n In early 2022, the EPA<\/a> began announcing their initial actions regarding Refrigerant Production restrictions. In addition, they have started the EPA <\/a>rule making process to develop the regulations and restrictions for the remaining two categories. Since they are still in the early stages of this process, the exact ways in which the agency will regulate use of refrigerants is not yet fully known or developed.<\/p>\n\n\n\n In October 2021, a phase-down schedule and allocations for chemical producers in the United States was published. The first phase down, called for as of Jan 2022, set a 10% reduction target from the baseline level. In order to measure impact consistently across chemicals, the EPA<\/a> decided on a methodology called CO2 (carbon dioxide) Equivalency<\/a>, sometimes known at CO2e<\/a>. CO2e essentially tallies up the Global Warming Potential (GWP)<\/a> impact of all the refrigerant constituents and then allocate based on the amount of carbon represented by each refrigerant. This actually incentivizes the producers to produce lower GWP<\/a> refrigerants. The lower the collective CO2e, the more refrigerant they can produce & sell.<\/p>\n\n\n\n Of note is that some US States have already passed laws aimed at HFC restrictions. These pre-existing restrictions cannot be invalidated or preempted by the federal law. The AIM Act<\/a> sets a new model, normative baseline for all states, states that previously passed more restrictive regulation will be allowed to keep those regulations in place. California, New York, Washington State, and Colorado have been the policy leaders among US states. Their pre-existing regulations create a kind of checkerboard effect across the country. Some Localities (Cities or Counties) can be even more restrictive, especially with regard to flammable (A3) and lightly flammable (A2L) refrigerants. Those local restrictions also remain in place. <\/p>\n\n\n\n We are now in the stage of the EPA<\/a> rule making process which requires a public comment period on the rules they intend to put in place. The rule making process is required under the AIM Act<\/a> to conclude within 2 years of the Act\u2019s passage. Thus the rules must be finalized by the end of 2023.<\/p>\n\n\n\n In California, Refrigeration System<\/a> owners\/operators have long been mandated to report refrigerant leakage, and they understand it very well. It is anticipated that the EPA<\/a> will adopt language similar to the CA R4 program. Thus, everyone, including HVAC & Refrigeration owner\/operators, are going to have to start monitoring refrigerant leakage. This means understanding how to report and measure ongoing usage and leak rates.<\/p>\n\n\n\n The biggest impact so far seems to be on the smallest tier players because they have the least capital resources to take action. For everyone in the industry, the reporting requirement for refrigerant usage and monitoring<\/a> will be massive. There is going to be a fairly massive reporting<\/a> requirement for the refrigerant usage, going forward.<\/p>\n\n\n\n
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