Policy Pitfalls: How “Mid-Stepping” Refrigerant Policy is a Mis-Step for the US and Canada

Sometimes it’s good to take make change gradually and sometimes it isn’t.   A recently released report about refrigerant transition policy concretely challenges how the US proposed “mid-step” path for lower GWP refrigerants can damage our health, our economy, and our planet.  Whether the current policy direction is driven by industry incumbency or patent laws, the consequences have potential to be dire for everyone.

A report recently released by the Bonneville Power Administration and written by Ecotope of Seattle WA, examines the path the United States and Canada can take to shift towards using natural refrigerants like propane (R290) in heating, ventilation, air conditioning, and refrigeration (HVAC&R) systems. The report, “Roadmap for Overcoming Barriers to Using Natural Refrigerants in the United States” identifies the pitfalls of the new generation of low GWP refrigerants and contrast them with natural refrigerants that are available but excluded by outdated rules.

The report’s recommendations should be considered by anyone who is involved with electrification and heat pumps. We have a path forward with new heat pumps and new refrigerants, but we’ve excluded a far better path with natural refrigerants that would be less disruptive, less expensive, and reduce exposure to forever chemicals which will eventually end up in our water and then our bodies.

The Ecotope report highlights two reasons why immediate action is important. First, there's the environmental impact of synthetic refrigerants currently in use, known for their high global warming potential (GWP). As the US and Canada moves towards more sustainable solutions, these synthetic options are increasingly being phased out. The report points out that natural refrigerants, on the other hand, have a negligible GWP compared to their synthetic counterparts. The primary example, propane (R290) has a GWP of just 3, making it almost harmless to the atmosphere, especially when compared to common HFCs like R32 and R454b, which have GWP values of 675 and 467, respectively.

One particularly eye-opening aspect of the report is its critique of the next generation of synthetic refrigerants, the HFOs. While these refrigerants have a lower GWP than refrigerants that are being phased out (such as 410A), the report highlights concern about their potential to degrade and release “forever chemicals” which studies show are harmful substances that could contaminate our water supplies. This underscores the report's argument that natural refrigerants aren't just a future alternative but possibly the best choice for both environmental and public health reasons now.

A second reason to move directly to natural refrigerants is economic, and that argument is equally compelling. Propane, being a naturally occurring compound, is far cheaper and more efficient than many synthetic refrigerants. The report notes that R290 can do the same cooling job more effectively and with less material than refrigerants currently in use. Plus, as propane is already widely used in the US for heating and cooking, the infrastructure and familiarity are there. This switch could potentially lower costs for consumers and open new avenues for innovation in the HVAC&R industry.

With such strong arguments for the use of natural refrigerants, it’s difficult to understand why we’re not already using them more extensively.  However, current US regulation make the path forward difficult.  Standards like UL 60335-2-40, which dictate the safety requirements for HVAC&R equipment, are much stricter in the US compared to international norms, severely limiting the amount of propane that can be used in these systems. This discrepancy not only stifles innovation but also puts the US at a competitive disadvantage internationally.

Man sitting in road holding a map

Luckily, the report doesn't just outline problems; it offers a roadmap for change. It suggests a multi-pronged approach to encourage the adoption of natural refrigerants. This includes updating safety standards to align with international practices, which would allow for greater use of propane in HVAC&R systems without compromising safety. Moreover, it calls for federal and state governments to explore alternative pathways for approval, such as recognizing European safety certifications or invoking the Defense Production Act to fast-track the adoption of these greener solutions.

For our part, we’d like to skip the expensive and hazardous “mid-step”.  We also recognize that currently R32 and R454B are what is currently available for climate-conscious consumers.  Our goal is to collaborate with others who are a passionate about moving quickly to allow natural refrigerants.

As a company, we’d like to build and offer a heat pump for our domestic hot water systems with R290 propane. These systems would work better due to R290’s higher output temperatures in cold climates with a third of the working pressure of CO2.   This would result in systems that achieve better performance, are less expensive, and easier to build.

As inhabitants of the planet, we’d like to be able to provide products that are healthy for the earth and its inhabitants long-term.  We will continue to advocate for the use of natural refrigerants while continuing to provide the best products for our customers currently allowed.  If you’d like to help advocate for natural refrigerants, let us know and we’ll notify you when there is opportunity for collaborative advocacy.