Comment Log Display
Below is the comment you selected to display.
Comment 98 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.
First Name: Gary
Last Name: Parker
Email Address: gparker@rsd.net
Affiliation: Refrigeration Supplies Distributor
Subject: F-Gas Mitigation Strategy
Comment:
Thanks to everyone that participated in the SLCP-Public Workshops. As a Refrigeration and Air Conditioning distributor we work very closely with facility operators and mechanical contractors. Over the last decade I have conducted hundreds of educational meetings talking about the HCFC phase out and the importance of moving to (Non-ODP) HFC refrigerants. Although there has been some pushback, the industry as a whole has embraced this change and work is being done on a daily basis to achieve this goal. The sheer number of facilities that this affects, the technical man power required and the cost associated with a refrigerant retrofit has required companies to adopt a gradual conversion programs, with 2020 being the target date for completion. When HFC's were first identifies as having High GWP, some companies simply stopped their retrofit efforts. Clearly making a change now with yet another change on the horizon had many concerned; should they to stay the course, convert their facilities to new unfamiliar and costly technology or wait for yet another retrofit solution? As I am sure you are aware, all of these scenarios are being played out. With respect to HFC’s in general; I am not trying to argue the science, but one area I question in your presentation was the impact our industry has on the HFC usage as whole. Prior to 2010, the majority of HFC’s, particularly R134A were used in Foams, Aerosols and Automotive AC. Now that most of those industries have been or are being converted to other materials, AC-Refrigeration is the predominant share, of what remains. You also indicated that HFC use in the AC-Ref sector was on the rise. With the HCFC conversion still underway, that would only make sense. Our industry has proven that we will work to comply with whatever is legislated. Beyond the retrofit activity, system designs and service practices have lowered both the refrigerant charge and the service leak rates. I don’t have statistics, but it seems we have been able to make progress with minimal economic impact. There are arguments both pro and con on the direction our industry should go. Natural refrigerants like Co2 are certainly viable, but there is some question whether energy efficiency, and by extension water consumption would be negatively affected in high ambient (+95F) Climates. Even if they are able to make an energy neutral design, the initial cost of these systems in well over $1,000,000 per location so a rapid move by even the most well-funded Supermarket chains would be difficult at best. In Europe they are moving in part to self-contained refrigeration cases using natural refrigerants including hydrocarbons. All of these fixtures would need to be water cooled, which given our current state, could present an additional challenge. Also, the adoption of Hydrocarbon refrigerants like Propane or Butane, are strictly limited by UL and the municipal fire and building codes. So, despite their popularity in EU, they would not be easily adopted in the US. With Respect to HFO technology; Unlike the Foams, Aerosols and Automotive industries the development of HFO refrigerants was not considered a priority until the recent move to retire HFC’s . These products are just now becoming commercially available and although they have slightly higher GWP values than naturals, they perform well in existing system with, in some cases improved energy efficiency. Keep in mind that pure HFO’s have lower GWP values than even C02 (based on ICCP -5 data). The limiting factor is their A2L flammability level. These are much lowers those A3-hydrocarbons, but still prohibited by current codes. The coordination of the various regulatory agencies should really be considered before a decision is made. To summarize; Moving from a gradual HCFC to HFC conversion protocol to a rapid HFC to ???, conversion is likely to have far reaching consequences. I would encourage you to review the timelines that you have outlined and consider a more gradual conversion goal. It would be a shame to jump to a new technology that would not only required significant investment but could ultimately, require more energy and result in a higher TEWI (total equivalent warming impact). Thank you Gary Parker Refrigerants Product Manager Refrigeration Supplies Distributor gparker@rsd.net
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2015-10-30 14:52:01
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.