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November/December 2023

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rule specified GWP limits and compli- ance dates on HFCs by market sector and subsectors. The proposed GWP limit for HFCs used in new Ice Rink refrigeration systems was 150, with a compliance date of January 1, 2025. The proposed GWP limit caused con- fusion and concern among ice rink owners and operators that were in the process of retrofitting or replacing their existing R-22 (Phased Out in 2020) refrigeration systems. A GWP limit of 150 would've eliminated every HFC refrigerant listed in the EPA's Significant New Alternatives Policy (SNAP) Program as an accept- able substitute for retrofitting or replac- ing existing R-22 ice rink refrigeration systems. This proposed rule would not have affected the future use of Ammonia (R-717) or CO2 (R-744) as neither are classified as an HFC and their GWP val- ues are both ≤ 1. Final GWP Limits Set In early October 2023, the EPA issued Final Rule – Phasedown of HFCs: Restrictions on the use of certain HFCs under subsec- tion (i) of the AIM Act of 2020. This rule restricts the use of higher-GWP HFCs in new refrigeration, air conditioning and heat pump products, equipment, and sys- tems. The GWP limit specified in this rule for HFCs used in new Ice Rink refrigera- tion systems is now 700, with a compliance date of January 1, 2025. It is important to know that this rule only restricts the use of higher GWP HFCs in new refrigeration, air conditioning and heat pump systems. Existing refrigeration, air conditioning and heat pump systems can still be used, maintained, and repaired beyond January 1, 2025. The downside to the final rule for our industry is that after December 31, 2024 there will be far fewer acceptable refriger- ant choices for new ice rink refrigeration systems. But the upside is that there will be no need to replace existing ice rink refrigeration systems until they can no longer be operated safely or become more costly to repair and maintain than replac- ing with a new system. California Phasedown Plan The state of California has gone further than the EPA with their HFC phase- down plan. Their refrigerant GWP limit is 150 for new refrigeration systems in new ice rink facilities, with a compliance date of January 1, 2024. For new refrig- eration systems in existing ice rink facili- ties, the GWP limit is 700, matching the EPA limit, but with a compliance date of January 1, 2024. J USICERINKS.COM NOVEMBER.DECEMBER.2023 / 39 >4,000 <2,500 <1,500 <700 <150 GWP REFRIGERANT COMPARISON R134a-like R404A/R22-like R410A-like GWP ≤ 1 R134a R450A R513A R1270 R600a R1234ze R290 R455A R454C R444B R454A R452A R404A R449A R22 R32 R410A R454B R452B R717/NH 3 R407A/R407F Flammability line A1 - Non-flammable A2L - Mildly flammable A3 - Highly flammable B2L - Toxic less flammable LEGEND R448A R515 R744/CO2

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