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Centralize Refrigeration Management

by on 1 May 2015in Blog

First published in Frozen & Refrigerated Buyer Magazine May 2015

Store level programs can hide huge dollar losses from refrigeration leaks.

People often ask me to name the single most effective way to cut supermarket refrigeration leaks, based on my time heading up the EPA’s GreenChill Partnership.

My response usually surprises them: Your first priority should be to switch from an individual-store-based refrigerant management strategy to one that is centralized at headquar­ters. This switch produced a 10% re­duction in corporatewide leaks in one GreenChill partner’s first few months in the Partnership. This partner had more than a thousand stores and this 10% reduction equaled at least 150,000 pounds of refrigerant. Mul­tiply that by about $5.00 a pound way back then, and you get a cool $750,000 cost saving off the bottom line.

What do I mean when I recom­mend shifting to headquarters refrig­erant management? Well, refrigerant management has historically been the responsibility of the individual store. In fact, Section 608 refrigerant regulations place the responsibility for record keeping and repair of leaks at the individual store level. That is the single biggest flaw in Section 608 and the reason it has largely been a failure in reducing and preventing harmful refrigerant leaks.

Headquarters management shifts the responsibility for refrigerant tracking, management, and strat­egy to a central person who has the responsibility for all stores. Just to be clear: this does not do away with individual store responsibility under Section 608. I would never encour­age anyone to flout the law, even one that has as its only accomplishment the killing of trees in the name of superior record-keeping.

If headquarters begins managing refrigerants centrally, there has to be a system in place for individual stores to produce all records required under Section 608, should an EPA inspector ask for them. Cen­trally managing all required informa­tion on leaks greatly increases the likeli­hood that a store will be able to produce those records. If left to their own devices, individual stores rarely produce adequate leak repair records. The most likely re­sponse from a store manager when asked for refrigerant records by an EPA inspector is something like “I don’t have anything to do with that stuff.”

So how did a shift to headquarters management lead to such a huge reduction in leaks in such a short period of time in the exam­ple cited above? First of all, calculating a corporatewide leak rate for the first time usually opens the eyes of the top brass to the enor­mous amount of money a company wastes on replace­ment refrigerant. And that’s the key: the realization that the best financial path is to solve this corporatewide problem.

An individual store manager looks at refrigerant leaks as a cost of doing business. He or she is often unaware that something can be done about the problem, or if aware, doesn’t have the time to become a refrigeration expert to figure out how to solve it. The store manager’s job is to sell groceries. A person at headquarters who has been hired to tackle this problem would have the knowledge and the time that individual store managers lack.

Centralized refrigerant manage­ment leads to quick wins by focus­ing attention on the horrendous leak rates at some stores. From the perspective of the individual stores, these leak rates are probably consid­ered normal. But a per­son who has the records for all stores sees that a small number of outliers make up a large percent­age of the leaks. He or she can target those stores as the first priority. Sometimes sending out contractors to investigate the problem leads to the simple solution: finding and repairing the leaks instead of just topping off the refrigerant every month. If the problems are more complex, headquarters can allocate funds to tackle them in other ways, includ­ing investing in a new system if that saves money in the long-term.

$30,000 FINES PER DAY Centralized refrigeration manage­ment often alerts corporate officials to the potential legal liability from non-compliance with refrigerant regulations. At $30,000 per viola­tion, per day, fines can be much more expensive than investing in better refrigerant management.

There are other examples of the benefits in switching to centralized refrigeration management, but they all boil down to the same premise: better companywide refrigeration management results in better com­panywide financial management. The environmental benefits are a pleasant side effect.

Time to Overhaul 608

by on 1 April 2015in Blog

First published in Frozen & Refrigerated Buyer Magazine April 2015

Special interests want to expand Section 608 refrigerant leak regula­tions. But what it needs is a major overhaul.

The Alliance for Responsible Atmospheric Policy, a Washington, D.C., special interest group, petitioned the EPA last year to expand Section 608 refrigerant leak repair regulations to include HFC refrigerants. The EPA’s Section 608 regulations currently apply only to ozone-depleting refrig­erants, and since HFC refrigerants do not harm the ozone layer, they do not now fall under its scope.

INEFFECTIVE REGULATION

The petition from the Alliance has many in the supermarket industry shaking their heads. Expanding Section 608 to include HFCs just takes an ineffective regulation and adds more stuff to it. The regulation already contains everything and the kitchen sink, including several provisions that most agree are pretty useless.

In addition, the petition does noth­ing to solve the real problem that Ti­tle VI of the Clean Air Act is meant to address: our nation’s enormous refrigerant leak problem. The current Section 608 does not mandate that a supermarket leak less — it simply says that once a supermarket leaks 35% of its refrigerant charge, records must be kept to show that leaks are repaired within 30 days of discov­ery. In fact, it’s perfectly legal for a supermarket to double its leak rate every year. You can leak 10,000 pounds of refrigerant every year and still be fully in compliance.

Many in the su­permarket industry are pretty clear on the actions they should be taking to try to solve this problem. At the risk of sounding like Captain Obvi­ous, the solution to supermarkets’ refrigerant leaks is leak prevention. Leak prevention is possible, afford­able, and readily available to every supermarket. Today.

The EPA in 2008 started a program to encourage supermarkets’ invest­ment in refrigeration technologies that prevent leaks: GreenChill’s Store Certification Program. The program gave platinum, gold, and silver awards to stores that achieved very significant refrigerant emissions reductions. After three years, the program had over-performed beyond anyone’s hopes. It wasn’t just reducing refriger­ant emissions; it was preventing them.

Every store that GreenChill had certi­fied as platinum had a 0% leak rate. Let me say that another way: these stores had never leaked a pound of refrigerant since they started operating. The companies behind these stores had completely changed the way they managed refrigeration, investing up front in technology that used very little refrigerant and then leaked nothing during years of operation. Some of the stores used only a few hundred pounds of refrigerant, com­pared to a typical store which uses about 3,500 pounds. One store even operated on less than 100 pounds.

Gold-certified stores averaged a leak rate of 0.5%. Silver-certified stores leaked just 3.8%, compared to a typical store in the United States that leaks 25% of its very large charge size.

While the Store Certification Program proved that certain refrigeration technol­ogy options are better at preventing harmful leaks, namely those that use modular chill­er units, CO2 cascade systems, and natural refrigerant technolo­gies like CO2 transcrit-ical systems, every type of technol­ogy in operation in the country was able to achieve some level of certifi­cation. Even centralized DX systems, which use thousands of pounds of refrigerant and are notoriously leaky, could be greatly improved if de­signed to the certification standards. At minimum, they reduced their charge by 50% and achieved very low leak rates, attaining silver and gold certification awards.

A GOOD QUESTION

So if solutions to the nation’s leak problem are possible, affordable, and readily available right now, why isn’t the Alliance petitioning the EPA to incorporate these solutions into their regulations? Could it be because a regulation that mandated large reductions in charge sizes and technologies that prevent leaks would result in Alliance members selling significantly less refrigerant every year? I’ll let you decide.

Clearing the Cost Hurdle (part 2)

by on 1 April 2015in Blog

First published in Accelerate America Magazine April 2015

On January 8th of this year in Berkeley, CA, Hillphoenix, Emerson Climate Technologies, and AHT Cooling Systems USA brought together supermarket refrigeration executives and representatives from the nation’s major utilities to discuss ways that utilities could help boost demand for energy-efficient natural refrigerant equipment.

After discussing energy incentives for self-contained refrigeration units that employ hydrocarbons (see Part 1 of this article, in the March issue of Accelerate America), the group turned its focus to incentives for supermarket refrigeration systems that use natural refrigerants.

The typical store-wide system uses about 3,000-4,000 pounds of HFC refrigerant, usually R404A, which pound-for-pound has a global warming impact that is almost 4,000 times worse than carbon dioxide’s. Supermarkets leak on average about 25% of that refrigerant every year – about 750-1,000 pounds. To put the problem in perspective, that is about 4 million pounds of CO2 -equivalent leaked every year by each supermarket, or 140 billion pounds leaked by the nation’s 35,000 supermarkets. (That is ten zeroes after the number fourteen.) If you want to see how much that is in terms of number of cars on the road, go to the EPA’s greenhouse gas calculator HERE . It’s a nifty little tool that helps us regular people understand the effect of different greenhouse gas emissions relative to each other.

To be clear though, most utilities don’t care one iota about the direct emissions from refrigerant leaks. In fact, many utility regulatory bodies don’t allow their utilities to look at greenhouse gas emissions. All that matters to most utilities across the country is energy use.

Though many utilities advertise their incentive programs under the auspices of energy efficiency and the corresponding environmental benefits, incentives are a pure cost-benefit calculation for utilities. It is cheaper for utilities to pay people and businesses to use less energy than it is to build a new power plant. Period.

So in order to interest utilities in natural refrigerants, you have to come to them with an energy efficiency argument. As discussed in last month’s article, this argument is a no-brainer when it comes to self-contained equipment. The argument for energy savings with natural-refrigerant systems is equally compelling, but it is not a no-brainer.

The amount of energy saved by a store-wide system depends greatly on the type of technology and natural refrigerant used, as well as the average ambient temperature where a store is located. Add to that the fact that every supermarket refrigeration system is individually designed and individually manufactured, and you have the opposite of a no-brainer. Perhaps we should say that it is a “whole brainer.”

The crux of the complexity in determining how much energy a new natural refrigerant supermarket system is going to use lies both in the lack of actual energy data, because the energy consumption has to be estimated before the new store is built, and in the lack of some kind of a baseline against which you’d measure an energy efficiency improvement, because there is no useful national average for the energy usage of a supermarket.

Aaron Daly, Global Energy Coordinator at Whole Foods Market, cited the analogy of the electric car to describe the wholesale shift in approach necessary for natural refrigerants. “We aren’t talking about a car that uses a more efficient gasoline engine; we are talking about a complete shift in the way we do things – an electric vehicle, if you will,” said Daly.

In order for utilities to take advantage of the energy efficiency opportunities that will come from natural refrigerant systems, they’ll need to change the way they do things to a certain extent. Instead of looking at individual components and adding up the energy savings that are achieved by each component, utilities will have to adopt a whole-system approach to energy savings.

Why should utilities get involved, if this is so complicated? Because the potential savings, ranging from 10% to 30%, are worth it.

In other words, a utility can either try to get 33 homes to stop using electricity completely, or they can help a supermarket install a natural refrigerant system in a new store.

As stated in last month’s article, the main thing that is preventing more supermarket companies from using natural refrigerants in new stores currently is the cost hurdle. Because there are only a few of these natural refrigerant systems in the U.S., equipment manufacturers cannot take advantage of economies of scale.

There just isn’t enough of a market yet for manufacturers to start producing natural refrigerant components here in the U.S. According to Derek Gosselin, Product Manager, Systems Division for Hillphoenix, about 25-30% of the components for a CO2 transcritical system are still imported from overseas.

Tristam Coffin, Energy & Maintenance Project Manager at Whole Foods Market, noted that the lack of trained service techs increases the installation and maintenance costs for natural refrigerant systems. “Many refrigeration contractors remain apprehensive about investing in the training of their techs, because the chances that they’ll have the opportunity to work on a natural refrigerant system are still relatively small.”

For all three of the Whole Foods Market transcritical systems installed in the last two years, Hillphoenix, the system manufacturer, had to take on the responsibility of training the installing/service contractors. In addition, said Coffin, “We received wildly different installation bids from the contractors, because the greater contractor pool simply doesn’t have the experience upon which to base their estimates. Some price low to gain the experience, but the majority pads their pricing, because they are uncertain of what they are getting themselves into.”

Luckily, utility incentives can be quite effective in counteracting the additional costs that often accompany new energy-efficient technologies. This inspires additional sales, which brings costs down, resulting in a virtuous cycle that culminates in the price of natural refrigerant technologies equaling or even beating that of conventional technologies.

GETTING STARTED

So how do we get this party started? Utilities and supermarkets agree on the essential factors in utility programs for natural refrigerant incentives: they have to be easy, transparent, and flexible.

Neither utilities nor supermarkets can afford to take part in a project that takes too much time and too many resources to be worth it. As Paul Anderson, Senior Group Manager of Target Corp. observed “The idea that a utility incentive project would take more time than it takes to actually build a new store is just unworkable for us.”

Ideally, utilities’ methodologies for natural refrigerant incentives would have enough in common across geographies to be somewhat replicable. However this is a challenging notion for individual utilities, which often don’t care about any methodology but their own. But for supermarkets, which may deal with a different utility for every new store, having a methodology that crosses utility borders is essential.

“If we could get utilities to at least agree on a set of principles for how these projects would be handled, it would be enormously beneficial for us,” said Harrison Horning, Director of Energy & Facilities at Delhaize America, which deals with dozens of utilities across the Northeast, the Mid-Atlantic, and the Southeast.

Transparency and flexibility, the other essential characteristics of natural-refrigerant utility incentive programs, might seem to be in opposition to each other, but both are essential for a successful program for supermarkets.

Mitch Knapke, Director of Food Retail at Emerson Climate Technologies, perhaps stated it best when he said, “Many people mistakenly believe that transparency means a lack of flexibility. I disagree. A transparent system can be highly flexible, as it would need to be in the case of utility incentives for natural refrigerant use in supermarket systems.”

As stressed in the Berkeley workshop, a flexible and transparent model is needed to predict the energy consumption of a new store at the design phase, as well as a baseline against which the energy efficiency improvements would be compared.

With a multitude of models available on the market, the hard part isn’t coming up with one. It is to get utilities and supermarkets to agree on which model to use. Every model has its flaws; but for utility incentive projects for new stores that will use natural refrigerants, there is no alternative but to rely on modeling when predicting the energy usage of a store that is yet to be built.

Most at the workshop agreed that the question of a baseline is the more complicated question. Once you have modeled the energy usage of a natural refrigerant system in a new store, what do you measure it against?

The choices are numerous. Do you measure the new store’s energy consumption against a national average for all stores? The only thing that is certain about a national average is that it will likely be irrelevant for any one particular store. What about a regional average? That would be more relevant for a particular store in terms of the ambient air temperature in a region, but it probably won’t correspond to the size or the cooling capacity of a particular store, and it might not have anything to do with the standard refrigeration technology used by a particular company. It wouldn’t make sense to use a centralized DX system as a baseline for a company that hasn’t built that type of system for over a decade.

 

A FLEXIBLE APPROACH

The consensus at the workshop seemed to be that an ideal baseline is whatever the company would have built in that spot instead of the natural refrigerant system. So for a company like Target, for instance, which said last year that its standard system for new stores will be a CO2 cascade system, you’d use a CO2 cascade system as the baseline.

Of course, the chances aren’t high that Target has a store already in operation right down the block that can be used as the baseline. So even in a situation where a company has declared a standard technology, the baseline question still isn’t easy to answer.

You could take actual numbers from a store that is close to the new site, and try to determine the extent to which energy usage would differ at the new store. You could take an average of the energy usage data from the company’s existing stores in the region. You could also ask the company that is applying for the incentive to draw up a store plan for the technology that would have been used, if not for the natural refrigerant choice, and then model the energy consumption of that store. Many would see this as a useless exercise, but it might actually save a lot of time vs. some of the other baseline possibilities.

How to we get utilities to agree on one of these baseline methodologies? We don’t. The purpose of the workshop was not to get everyone to agree on one universally acceptable methodology for every project. The purpose was to come up with a set of transparent methodologies affording the flexibility to pick the best for each individual project.

Perhaps with additional discussion, utilities and supermarkets can come up with a hierarchy of baseline methodologies. If a company has a standard methodology, with actual energy usage data from another nearby store that is relevant, use that as the baseline. If a company has a standard methodology, but does not have actual energy consumption data from an existing store close to the new store’s location, use a regional average of several of the company’s stores that are within a certain radius of the new store. If a company does not have a standard technology that would have been installed in the store under consideration, take the alternative store design that wasn’t chosen, under the assumption that it would have been used but for the natural refrigerant technology chosen instead. And so on.

That might sound complicated and time consuming, but according to all participants in the workshop, it cannot possibly be as time consuming and complicated as starting anew, from scratch, for every new store, in every region, with each different utility. Nothing is worse than that.

potential energy savings

Clearing the Cost Hurdle (part 1)

by on 1 March 2015in Blog

First published in Accelerate America Magazine March 2015 

Those who look to natural refrigerants as the ultimate solution to the cycle of never-ending refrigerant phaseouts have been discussing for several years the hurdles that need to be overcome to accelerate their adoption in the U.S.

Above all, the biggest hurdle is cost. As is usual with technology that has recently come on the scene in the U.S., the cost of natural refrigerant equipment is higher than that of typical HFC equipment.

This is to be expected. The commercial refrigeration industry has had decades to fine tune conventional equipment and drive out inefficiencies. Competition among conventional equipment manufacturers who sell very similar products has kept prices low, and these manufacturers have been able to take advantage of the economies of scale that come with large sales volumes.

Eventually natural refrigerant equipment will get to that point also. In the meantime, the industry is in a catch-22: few are willing to purchase equipment that uses naturals until the price comes down, but manufacturers cannot bring the price down until more people purchase this equipment.

Greater demand in the U.S. would spark a virtuous cycle of events. For example, many of the components for natural equipment are now imported from Europe or Japan, but with increased demand in the U.S., component manufacturers could set up operations here. More customers would also encourage more manufacturers to enter the market, and these companies would compete with each other for business and look for ways to reduce prices.

Other hurdles to natural refrigerants would also be solved with greater volume, including the need for technician training, the lack of real data from stores that allow for equipment improvements, and the shortage of longer-term data on installation and maintenance costs.

If there were enough work on natural refrigerant systems for large numbers of technicians, service companies would invest in training, because they would get a return on their investment. And with greater experience with natural refrigerants across a broader base of end users, supermarkets would share data with each other and work with manufacturers to further improve products. The very fact of more units in use would generate robust data on all facets of the lifecycle cost equation.

So how can we spike demand for natural systems and thereby solve our catch-22?

HELP FROM UTILITIES

An attempt to answer this question took place on January 8th at an industry workshop in Berkeley, California. Sponsored by Hillphoenix, Emerson Climate Technologies and AHT Cooling Systems USA, the meeting brought together supermarket refrigeration executives, utility representatives, equipment manufacturers, and others to discuss ways to boost demand for equipment that uses natural refrigerants and saves energy.

Though the improved energy efficiency of natural refrigerant systems may not be the only — or even the main — reason supermarkets choose these refrigerants, the fact is that most natural
refrigerant equipment brings significant energy savings vs. conventional equipment, which makes them of interest to utilities. Bringing utilities into the equation is a “key stepping stone in the investment and hard work that is going to be required to make natural refrigerants mainstream,” according to Mitch Knapke, Director at Emerson Climate Technologies, one of the sponsors of the workshop.

The day-long workshop tried to “surface some good ideas of how and where to get traction with utility incentive programs,” said Harrison Horning, director of equipment purchasing, maintenance and energy, for Delhaize America.

The most obvious opportunity for utility incentives lies with hydrocarbon self-contained units, which can cost about 20% more than their HFC counterparts. Data from AHT Cooling Systems USA (see chart on page 11) show energy efficiency gains of more than 45% for their new hydrocarbon cases vs. their own new HFC cases. (Incentives for self-contained units using carbon dioxide will be considered in a future article.)

Based on those numbers, an average supermarket with 12 self-contained hydrocarbon units saves about 20,000 kWh annually per store. Multiplying the 20,000 kWh per store by the 37,459 supermarkets in the US (according to the Food Marketing Institute) results in a rough, back-of-the-napkin potential savings for supermarkets of 771,130,974 kWh per year. In fact, the savings would likely be higher than that, because the older HFC units that would be switched out likely use more energy than a new HFC unit. Of course, this quick analysis assumes that all 12 cases in an average store are 4-5 foot self-contained spot cases.

Taking the analysis one step further, if the average kWh price for electricity is a flat ten cents, U.S. supermarkets would save over $77,000,000 per year in electricity costs. That sounds like a lot. And it is, though in total our nation’s supermarkets spend about $8-$10 billion per year on electricity.

The premise at the start of the workshop was that prescriptive incentives for new self-contained hydrocarbon units are as close to a no-brainer as you can get in supermarket refrigeration. It should be as easy as comparing the annual electricity usage of a new hydrocarbon unit with the annual electricity usage of the same new unit that uses an HFC refrigerant. In other words, the hydrocarbon unit is compared to what the supermarket would have bought if the hydrocarbon unit did not exist. Just as with a washing machine or a home refrigerator, the annual energy use of self-contained refrigeration units is tested and listed in the equipment’s spec sheets. If utilities don’t trust manufacturers’ energy usage data, wouldn’t it be as easy as plugging both units into the wall next to each other in an independent lab to measure their energy consumption?

If those numbers still aren’t good enough, there will soon be another source: the Department of Energy. By January 1, 2016, all manufacturers of self-contained commercial refrigeration units must measure, certify, and file with the DoE the daily energy consumption in kilowatt-hours per day of each model they sell. The DoE mandates that manufacturers use the “uniform test method for the measurement of energy consumption of commercial refrigerators, freezers, and refrigerator-freezers.” Utilities can easily use those numbers as the basis for their incentive calculations.

Replacing old self-contained units with new ones is slightly more complex. Does one measure the actual electricity usage of the existing unit first and use that consumption number as the basis for the prescriptive incentive? What about the ancient HFC unit that everyone admits shouldn’t even be used anymore? Is it fair or desirable to use that as a baseline for an incentive? Or does one just assume that every existing HFC unit in stores uses an average amount of electricity and base the incentive on that? Or for simplicity’s sake, how about taking the energy usage of a new HFC unit as the baseline, regardless of how much electricity the old HFC unit consumes?

GETTING STARTED

Utilities, supermarkets, and equipment manufacturers could spend a very long time evaluating all of those options to 2015-06-22_15-00-55determine the perfect methodology. Or they could decide to not let the perfect interfere with the good and pick the most conservative option for utilities and go with that. Supermarkets might not receive as much of an incentive as they would with one of the other options, but at least they’d get more than they are currently receiving – nothing. And they’d start getting something a lot sooner than if utilities spend a very long time figuring out the perfect solution to all of these questions.

Derek Gosselin, product manager for systems at Hillphoenix, perhaps stated it best when he said, “The most important thing is to just get started.”

As with other utility incentives, the role of this incentive is to stimulate sales of new energy-efficient equipment while it is still more expensive, allowing manufacturers to achieve the economies of scale that come with larger volumes. Once the market demand is high enough to justify manufacturing components and cases in the US, the cost of hydrocarbon self-contained units will automatically come down. And once the price comes down to levels that are comparable to those of conventional self-contained cases, utility incentives won’t be necessary anymore.

The ideas discussed in the workshop are already bearing fruit, with innovative utility companies in California hoping to have a prescriptive rebates program in place by mid-summer 2015 for hydrocarbon self-contained units, according to Howell Feig, sales director for AHT Cooling Systems USA.

“The opportunity for prescriptive incentives/ rebates for natural refrigerant solutions is in the very near future,” noted Leigha Joyal, energy analyst at Hillphoenix.

Ready for Prime Time?

by on 1 March 2015in Blog

First published in Frozen & Refrigerated Buyer Magazine March 2015

Moveable, self-contained hydrocarbon cases may be in your future.

Imagine a world where merchandising people and refrigeration people live in perfect harmony. Most people who work in one of these two areas will claim to get along fine, but behind the scenes they’ll admit to frustration with each other. Refrigeration people admit to this frustration more readily, probably because merchandising often comes out on top in situations where the groups’ interests don’t coincide.

HOPE FOR KUMBAYA

There is hope for kumbaya in the future — and it lies in hydrocarbon self-contained units. These cases offer greatly improved merchandising op­portunities, as well as energy savings and decreased maintenance costs.

Imagine being able to move frozen and refrigerated cases around the store wherever and whenever you want. Move chilled whipped cream next to your strawberries. Put some brie and bacon next to your figs and some fresh mozzarella and basil next to your heirloom tomatoes along with recipes for broiled bacon-wrapped figs stuffed with brie and mozzarella caprese. Move your hot dogs and hamburgers next to your beer for the 4th of July holiday. Put your specialty European butters next to your Dunge­ness crabs.

Create space in your store for people to stop in on their way home from work to pick up everything they need for a meal. Put a main course, salad, chilled white wine, and fruit for dessert right at the front of the store and take some business away from your local fast food chains. I’m not a merchandising specialist, but I am a shopper, and I can tell you that I’d appreciate ideas like that.

You know who else might appreciate ideas like that? Refrigeration people. Why? Hydrocarbon self-contained units can achieve energy savings of up to 40%, according to a presentation given by the self-contained case manu­facturer, AHT Cooling Systems, at a utility workshop in January. These cases come factory-sealed for leak tight­ness, which reduces refrigerant expenses and mainte­nance costs, and the installation of the cases is as simple as plugging them in.

Today, most systems have refrigeration equipment in a separate room, with piping running to and from fixed-location cases. This system traditionally used less energy than a store filled with self-contained cases.

But the improved energy efficiency of hydrocarbon self-contained cases may make it more economical to take some cases off the remote system. Savings can be sub­stantial, considering that refrigeration usually accounts for about half of a store’s energy use.

Aaron Daly, global energy manager at Whole Foods Markets, notes that “The hydrocarbon-based self-contained units we’ve deployed have enabled us to achieve energy savings over our previous cases while offering additional merchandising flexibility.”

Compared with earlier self-contained cases, today’s hydrocarbon units feature more display area and packout as well as lower levels of noise and heat generation.

“Modern self-contained units shouldn’t compromise the ‘look and feel’ of a remote fixture,” according to Geoff Amos, head of sales and marketing at Carter Retail Equip­ment Ltd. “Our cases use a horizontal scroll compressor with a low-profile condensing assembly hid­den in the top of the case. Unlike conventional upright compressors, this has no impact on the case’s display area and volume for merchandising.”

TESTS ARE FAVORABLE

Testing has shown that the compressors in new hydro­carbon self-contained cases are quieter than remote case evaporator coil fans, and the heat that would be rejected from the self-contained cases into the store can be elimi­nated by dissipating it through a chilled water loop. This makes it more difficult to move the case around at will, but it doesn’t make it impossible.

I am eager to see some energy numbers from store pi­lot projects with hydrocarbon cases and hear merchan­disers’ opinions on them in real store situations. This may be something that merchandisers and refrigeration people can both embrace wholeheartedly. I suggest you all get started on having conversations about the poten­tial, ideally over a nice, cold beer.

The Great Divide

by on 31 January 2015in Blog

First published in Frozen & Refrigerated Buyer Magazine January 2015

Are you looking in the right places for unbiased opinions about your systems and refrigerants?

One of the first things I learned about refrigerants and supermarkets is that there is never one right answer, regardless of the question.

Doors on cases? It depends on lots of factors, including the case contents, the types of shoppers that frequent your store, how old the cases are, and, perhaps most im­portant, how much deference your management gives to your merchan­dising people.

Best type of refrigeration system? It depends in part on the layout of the store, the location of the store, the amount of money available, and, it seems, a lot of hearsay about the downfalls and dangers of the various types of systems that you yourself have never tried.

I could go on and on. You name an issue in commercial refrigera­tion, and I’ll tell you that the answer depends on X, Y, and Z.

TWO MAIN CAMPS

One of the most polarizing issues in our industry is the right strategy for approaching the environmental harm caused by refrigerant emis­sions. There are two main camps: those who believe that the answer to this problem is leak tightness and those who believe that the answer lies in environmentally friendlier refrigerants.

The leak tightness camp proclaims readily and willingly that the refrig­erant is not the problem. It doesn’t matter if a specific refrigerant harms the ozone layer or if it is the most potent global warming gas on the planet. If the refrigerant doesn’t leak, it doesn’t cause any harm. Therefore, we shouldn’t regulate refrigerant type; we should install commercial systems that never leak and make sure that service techs are trained in best practices.

The people who believe that the answer to the harm caused by refrig­erant emissions lies in using refriger­ants that are not harmful will tell you that there is no such thing as a leak-tight system. They point out that re­frigerant emissions are often outside of human control. Components fail without warning. Natural disasters result in catastrophic leaks. Copper theft can cause a store to lose its en­tire charge overnight. They also refer to human error. I myself am fond of mentioning the inattentive high school forklift driver who bangs into a display case. I have no idea whether high schoolers are even allowed to drive forklifts in supermarkets, but I keep using this example because I think it gets the point across.

So what’s the answer? I’d like to say “it depends.” But this is an issue where “it depends” doesn’t really work. It boils down to your funda­mental world view, similar to wheth­er you believe that guns kill people or that people kill people, or perhaps more aptly, whether the answer to our energy future lies in renewables or cleaner fossil fuels. Needless to say, though I’m saying it anyway, there is a lot of money at stake in all of these areas.

Not surprisingly, many chemi­cal manufacturers and the associa­tions that represent them belong to the camp that professes that the refrigerant is not the problem. As the EPA focuses more on low GWP refrigerants, this camp will become more vocal about the need to better communicate best practices for leak tightness and leak prevention, the need for more training, and better enforcement of Section 608 of the Clean Air Act. They don’t want to seem blind to the problem, so they’ll focus the blame for the environmen­tal harm somewhere other than on the refrigerant.

CHOOSING SIDES

Also not surprisingly, many envi­ronmental organizations belong to the camp that believes that refriger­ants will always leak, so the industry needs to move to refrigerants that do not harm the environment when emitted. This camp often makes broad, sweeping pronouncements about what everyone in the indus­try is doing wrong, without offering much in the way of concrete solu­tions to the hurdles that stand in the way of adopting environmentally-friendlier refrigerants.

Though I find systems manufac­turers to be more agnostic, their agnosticism mainly comes from their desire to sell to all end-users regard­less of their own opinions. Most of these manufacturers will, however, suggest that you try to reduce your HFC charge as much as possible and that you invest in a system that prevents HFC refrigerant leaks. They offer refrigeration systems that reduce the amount of HFC refrigerant needed by anywhere from 75%-90%. They also offer systems that use only natural refrigerants. Depending on how they posi­tion themselves in the market, they will focus more or less on these attributes as the key for your preparation for future regulations and market developments. However, if an end-user comes to these manufacturers wanting the leakiest type of system that uses the most 404A they can pump into it, most will also gladly sell that type of system. They might even take this end-user out to dinner and gladly agree that all this environmental nonsense is a load of hogwash.

If you get the impression that I feel this is an area where beliefs have a lot to do with money, you’d be ab­solutely right. Cynical? Maybe. I prefer the term bluntly realistic. The term “cynical” suggests that I feel there is something wrong with all parties in this industry try­ing to make a living. I don’t see anything at all wrong with that.

The problem in this situ­ation is when end-users, in trying to figure out what is best for their stores, gather information from people who are trying to sell them some­thing and never ask them­selves whether they are being presented with the whole picture. What baffles me is that these end-users are usu­ally the types of people who consult Consumer Reports or some other neutral source of information before purchas­ing a flat screen TV. They ask their friends who have flat screen TVs for their opin­ions on the pros and cons of various models. They under­stand that the flat screen TV salesperson may be trying to push one particular model or another based on the amount of commission he or she stands to earn. Yet when it comes to million-dollar decisions related to refrigerants and refrigeration systems, decision-makers rely on infor­mation from people who have a vested monetary interest in their decisions.

GREENCHILL: A GOOD SOURCE

The best source of neutral, user-friendly information that I know of is the EPA’s GreenChill Partnership. Lest you think that this organization escapes my cynical or bluntly realistic viewpoint, I readily admit that this neutrality is mostly due to the competitors that belong to the partnership keeping each other honest. The vari­ous best-practice guidelines, for instance, are written by groups of competitors. Any hint that a team member is trying to swing the document in his or her company’s favor is gleefully pointed out by multiple parties. Yes, there are situations where a whole group of competitors have the same economic interest, but the guidelines are peer reviewed by end-users and other industry stake­holders, too. They then go through a lengthy process of EPA review, where the pressure to eliminate anything that resembles a definitive statement is great. Neverthe­less, the result of this whole process is a set of pretty good guidelines. The guidelines don’t answer all of your questions on any one topic, but they do point out the questions that you should be asking yourself and anyone who is trying to sell you something.

As long as end-users rely on salespeople for the information they use to make million-dollar deci­sions about which system to install in a new store or which refrigerant to use as their standard, this whole is­sue will, in fact, boil down to “it depends.” Unfortunately, in this case, the factors in the “it depends” equation are who you get your information from, what they are trying to sell you, and how much of it they are trying to sell.

The Final Word on R-22

by on 4 November 2014in Blog

First published in Frozen & Refrigerated Buyer Magazine November 2015

EPA’s determination means a lot less virgin refrigerant will be available. But nobody knows how much R-22 has been stockpiled, or what will happen to pricing.

A few weeks ago, the EPA issued its final determi­nation on the amount of virgin R-22 allowed to be produced and/or imported in the United States from 2015 through the end of 2019. This determination is what everyone with an interest in refrigerants has been waiting for. Chemical manu­facturers, refriger­ant reclaimers, and refrigerant end-users had been metaphori­cally holding their breath until this EPA rule was issued. Those who weren’t holding their breath were sighing and saying “Just tell us what’s going to happen already.”

So now we know.

HALF AS MUCH R-22

There is going to be less R-22 than there could have been. In fact, the EPA is allowing only half as much R-22 as it could have allowed in 2015 and then decreasing linearly the amount it will allow every year from that lower start­ing point.

Evidently, the EPA feels that there is too much R-22 on the market. In order for the R-22 phaseout to work the way it should in theory, the price of virgin R-22 needs to start rising. Those with equipment that leaks a lot of R-22 will find it cheaper to retrofit that equipment to use a different refrigerant, or to replace the old equipment with new. Those with R-22 equipment that is leak-free can con­tinue to use R-22 into eternity, as long as that equipment stays leak-free. People who don’t have to purchase R-22 for leak replacement don’t care how high the price goes.

Until that equipment leaks, that is.

What’s unknown is the amount of R-22 that commer­cial refrigeration and industrial refrigeration end-users have stockpiled. Will they keep that refrigerant for their own use, or eventually sell it back into the market after reclamation? There is no doubt that some supermarket companies have a lot of R-22 stockpiled. The EPA doesn’t know how much. The EPA has a general idea of how much is in banks with reclaimers, and they have information on how much has been sent to reclaim-ers over the past years, but they don’t have much of an idea of how much unreclaimed used refrig­erant from end-users’ own systems is being stored out there.

Short of commanding every commercial and industrial R-22 end-user to provide data on the amount of R-22 they are stockpiling, the EPA has no way of figuring out that number. And that number is the key to the R-22 phaseout working the way it’s supposed to. The EPA asked some supermarkets to voluntarily divulge how much they were storing, but who knows whether supermarkets told the truth, and who knows whether those supermarkets were representative of the industry. If you knew that EPA was asking you to tell them how much R-22 you had, so that they could accurately cut R-22 production to force prices higher, would you be open and honest with that information?

A VOLATILE MARKET

Imagine a scenario where R-22 prices go up, and then down again a few months later because a few supermar­kets have each reclaimed and sold 30,000 pounds of R-22 into the market. And then the price goes up again, and then it goes down again. A market like that would be very volatile, with end-users having no clue whether to buy or sell refrigerant at any point in time.

I have no idea whether that is going to happen. But if I expected to still be an R-22 end-user over the next few years, I’d certainly be sure that I had my own stockpile that met all of my own R-22 needs. That way, I’d be able to thumb my nose at anything that happens with R-22 availability and pricing in the future. At least I’d have certainty. And that is worth a whole lot.

Opportunity in a Snap

by on 1 November 2014in Blog

First published in Accelerate America Magazine November 2014

Those who pay attention to the goings-on at the Environmental Protection Agency (EPA) have probably noticed the recent proposal by the Significant New Alternatives Policy (SNAP) program to make it illegal to use certain HFC (hydrofluorocarbon) refrigerants that are potent global warming gases in new commercial refrigeration equipment and retrofits as of January 2016.

Manufacturers of equipment that uses natural refrigerants may be wondering if this EPA proposal represents an opportunity for them. The answer to that question is a definite “maybe,” depending on the type of commercial equipment they manufacture and where they are in the development process.

Manufacturers of commercial refrigeration systems or the components used in these systems are unlikely to feel a direct effect from the proposal. There are still plenty of HFC refrigerants available for commercial systems, such as R-407A and R-407F, so systems manufacturers are not (yet) being forced into natural refrigerants. Manufacturers may see an indirect effect, however, because even though the proposed rule doesn’t directly dictate that end-users must use natural refrigerants, end- users may view it as the EPA’s first step in that direction and interpret this proposal as a not-so-gentle electric shot to their derrières.

Many supermarket end-users have already been investigating natural refrigerant commercial equipment, perhaps even trying them out in a store or two. When asked by their colleagues why they install these systems even though they are currently more expensive than traditional systems, they usually respond that they think it is important to get out in front of the EPA, so that they are ready when the agency starts to phase down or eliminate HFCs. They want to start evaluating natural refrigerant systems at their own pace and influence the designs where necessary to make the technologies work for them. They realize that the first natural refrigerant system they install may not be the cheapest one available, but they are banking on the fact that they’ll work out the kinks and get to the point where these systems make financial sense. They think that starting with natural refrigerant systems now will give them a competitive advantage later when everyone else is forced to make the switch on the government’s timetable.

The equipment manufacturers now working with these end-users will be ahead of the game when natural refrigerants become mainstream. They will have benefited from the expert input from end-users at all stages of the design phase, as well as from valuable feedback from end-users and service technicians on improvements in the ease and cost of installation. They will have gathered proof that natural refrigerant systems reduce costs through energy efficiency gains, decreased line sizes for piping, etc.

Most of the major systems manufacturers saw the writing on the wall that the EPA was going to start to move the market in the direction of lower-GWP (global warming potential) refrigerants. The EPA has not made a secret of its desire to combat global warming, and it hasn’t minced words about refrigerants being one of the opportunities to quickly make major greenhouse gas cuts.

2015-06-22_14-09-39

The agency has attempted for the past several years to get the Montreal Protocol to act against HFC refrigerants. They have started an international organization called the Climate and Clean Air Coalition with more than 80 partners around the globe to address HFCs and other potent global warming gases. The EPA’s Green Chill Partnership has been consistently preaching that supermarkets should be using the lowest GWP refrigerant that meets their performance needs. EPA plenary presentations at the Food Marketing Institute’s annual Energy and Store Development Conference have focused on the list of power GWP refrigerants that are available for commercial refrigeration and presented the history of refrigerant use as a series of moves over decades that will eventually lead to the use of very low GWP refrigerants (see diagram). The EPA has held numerous webinars on lower GWP refrigerants that are available for commercial refrigeration and focused on CO2 systems, ammonia systems, and hydrocarbons, which are already in use in U.S. supermarkets. The manufacturers that did not see this coming have not been paying attention.

MORE TIME NEEDED

Take the manufacturers of self-contained commercial refrigeration units as an example. Many of them testified at an EPA hearing in August on the proposed delisting rule that they need more time to convert their equipment to use lower GWP refrigerants. There is no doubt that their R&D process will take several years, as will line conversion at manufacturing facilities and the process to get new equipment tested for safety and certified by a Nationally Recognized Testing Laboratory.

That’s not to say that there aren’t plenty of self-contained equipment companies that saw that the EPA was going to move in this direction. There are several that are ready to supply the market demand for self-contained refrigeration units that use hydrocarbon and CO2. They are ready for January 2016, and they definitely have a competitive advantage over companies that lag behind them.

But isn’t that as it should be in our system that thrives on innovation, smart decisions, and visionary leadership? Should the EPA give more time to companies that failed to see or ignored what was coming? Or is this natural selection at work in our capitalist marketplace? Yes, the free market is cruel. Survival of the fittest makes easy prey of those who don’t change with the times.

Whether the EPA gives more time to self-contained equipment manufacturers that lag behind will depend in part on whether companies that already have this equipment will be able to supply 100% of the demand for that equipment as of January 1st, 2016. If they can’t meet the demand, or if there are too few manufacturers to provide healthy competition, the EPA will likely give others a few years to develop their capabilities.

Even if self-contained commercial equipment manufacturers are given more time to bring low GWP refrigerant equipment to market, companies that are ready now will still have an advantage. End-users don’t want to wait until regulations go into effect to start trying out new equipment. They want to figure out whether units that use hydrocarbons or CO2 save energy, whether size requirements will change, even whether it is possible to use self-contained units to refrigerate all the food in small footprint stores. They want equipment now.

Companies that stop everything to try to fit a lot of R&D and manufacturing changes into a few years will also suffer from the disruption to their business caused by having to focus all their human resources, time, and financial resources to make this switch as soon as possible. During this time, they won’t have any people, energy, or money to focus on much else. In the meantime, companies that are ready now can focus on next-generation technology over the next five years to remain ahead of everyone else. And that may be as it should be.

What Is Your Used R-22 Worth?

by on 12 October 2014in Blog

First published in Frozen & Refrigerated Buyer Magazine October 2014

About five years ago at the FMI Energy Conference, I gave a plenary presenta­tion on the EPA’s R-22 phaseout. I posed a question to the audience: Why were supermar­kets paying people to come and haul away their used R-22? I commented, admittedly somewhat facetiously, that paying someone to come and take away your used R-22 after a refrigerant ret­rofit was like finding a suitcase full of money bur­ied in your basement and paying a junk collector to come and haul it away for you.

I was confronted by several reclaimers after the presentation who told me that my analogy was ex­tremely flawed. The money in the suitcase would have to be so dirty that it couldn’t be used unless it was cleaned and made like new. They assured me that I’d gladly pay someone to haul away money that was covered in mud and grease. The conversation then deteriorated into jokes about money laundering, and, as is often the case at the FMI Energy Conference, the conversation resulted in more questions than answers.

Over the past five years, supermarket industry prac­tices with respect to used R-22 have certainly changed. Most recognize now that the value of a pound of used R-22 is about equal to the price you’d pay to pur­chase a pound of new R-22. The common practice is to recycle the used R-22 in-house by running it through a filter drier and storing it for use in the company’s other R-22 systems. Supermarkets save money by not having to purchase as much new R-22, but they also protect them­selves by hedging against future price increases and/or R-22 shortages as the R-22 phaseout progresses to its end stage in 2020.

I know of companies that have not had to purchase R-22 for the past three years because they have their own stockpiles. They watched the R-22 prices rise and fall over the past few years with big smiles on their faces. They aren’t worried about possible price increases when the EPA cuts production of R-22 again next year. Year after year, these companies need less and less R-22, while building up more and more of a reserve. Imagine not hav­ing to worry at all, ever again, about the R-22 phaseout.

Companies do face some challenges in managing these R-22 reserves. How do you transport the R-22 between stores? Where do you store it until it’s needed? Who keeps track of all that R-22? How do you make sure that your refriger­ant doesn’t fall off the back of a truck at some point, especially as the price of R-22 goes up? Finally, how much time do you want your refrigera­tion team to spend on your R-22 stockpile, instead of keeping your display cases cold? All of these issues are manageable, as demonstrated by the numerous companies that have successfully ex­ecuted their plan for used R-22 over the past few years.

DO THE MATH

If a company does 10 R-22 retrofits in a year, pulling out about 3,000 pounds from each of those 10 systems, the company has a stockpile of about 30,000 pounds of R-22. If R-22 costs $10 per pound, you’ve got an asset of about $300,000. Remember that this $300,000 would other­wise be a cost to the company as it purchases new R-22 for its systems. If you take the standard assumption of a 1% profit margin for a super­market, a company has to sell about $30 million worth of goods to earn $300,000.

I have yet to run into a com­pany that can’t find or hire someone to manage an asset of this size. I’d do it. And believe me, if I found a suitcase full of that much money in my basement, I’d find a way to clean the mud and grease off it, too.

What’s All the Hubbub, Bub?

by on 16 September 2014in Blog

First published in Frozen & Refrigerated Buyer Magazine September 2014

What’s legal, and what’s not, under EPA’s proposed new rule? Will 134a be banned? Do you have to use natural refrigerants as of 2016? Here are the answers — well, at least some of them.

A few weeks ago, the EPA pro­posed a new rule that would make it illegal as of 2016 to use R-404A and R-507A in new commercial refrig­eration systems and retrofits. The rationale behind this proposal is that there are numerous other HFCs that can be used, all of which have less global warming impact. These HFCs, like 407A, 407F, and 134a are readily available, and their use instead of 404 and 507 is a no-brainer. Or so I thought.

CONFUSION REIGNS

I have been inundated with calls ever since the EPA issued its proposal. Most of the calls focus on the confusion generated by the wording of the proposal and the errone-ous belief that 134a would not be allowed in commercial systems as of 2016. That is easy enough to clear up. As of 2016, you may use 134a; in fact, of all the HFCs that may be used, 134a is one of the best choices from the perspec­tive of just the global warming potential of the refrigerant.

You may also choose any number of natural refriger­ants for new systems. Though the natural refrigerant choices for R-22 retrofits are not yet well developed, retrofits that convert R-22 equipment into a CO2 cascade system with just small amounts of 134a or a 407 as the primary refrigerant have been carried out successfully.

Some of the other calls are more troubling. I’ve heard from supermarkets that have been scared by chemical manufacturers into thinking that this rule means you must use a natural refrigerant in commercial refrigera­tion systems as of 2016. I’ve heard that it is impossible for supermarkets to make this switch. I’ve heard that various equipment manufacturers would face incredible hard­ships to change their manufacturing processes to comply with this mandate. I’ve heard that service techs cannot deal with this change. I’ve heard that this is just another attempt to kill American businesses.

These calls baffle me.

First of all, if you are in this industry and you did not suspect that this was coming, you haven’t been paying attention.

With regards to the misinformation that might or might not be coming from very knowledgeable and informed industry stakeholders, I can only assume it is based on innocent misunderstandings. If you rely on peo­ple other than the EPA to explain EPA proposals, rules, and such, please be sure that these people have their facts straight. Try to find a source of information that does not have an economic interest in your decisions. The best source of info about EPA proposals and regulations is the EPA. I know it can seem scary to voluntarily call the EPA and ask questions, but I can assure you that many who work there are very eager to explain things to you. Really. I promise.

The point about this switch from 404 and 507 being impossible for supermarkets, systems manufacturers, and service techs is contradicted by the number of supermar­kets that switched years ago to lower GWP alternatives for new systems and retrofits. In fact, supermarkets led the charge toward lower GWP HFCs in 2009 and 2010.

Delhaize America worked directly with the EPA’s GreenChill Partnership to get 407A approved for use in commercial refrigeration by EPA’s SNAP Program, the pro­gram responsible for evaluating and regulating substitutes for ozone-depleting chemicals in all end uses. According to Wayne Rosa, Energy & Maintenance Man­ager at Delhaize America, the company made the decision to switch its standard to 407A due to all the leaks they incurred with R-507 conversions and because the high global warming impact of 507 “was not the right direction for the company or the environment.”

An added benefit of that decision was that retrofit­ting existing systems from R-22 to R-407A reduced the amount of work needed by the refrigeration contractor and reduced the cost of conversions per system. Among the many other companies that have already moved away from 404 and 507 for new systems and retrofits are Walmart, Target, Whole Foods, Sprouts, Supervalu, Pub-lix and Weis Markets. The general consensus seems to be that there is little downside to switching to lower GWP HFCs, and the environmental benefits of the switch are a major upside.

Estimates from the nation’s main systems manufactur­ers show that anywhere from about 40-60% of the com­mercial systems sold in 2014 were for lower GWP HFCs, mainly 407A. According to Dustan Atkinson, supermarket systems product manager at Kysor Warren, “In recent years, we have seen a substantial shift from R-404a and R-507 to the various R-407 blends. Today, R-407 vari­ants account for nearly half of our total business and that percentage is steadily increasing.”

These numbers are backed up by information from major commercial refrigeration service contractors. Sean Patrick, director of field operations at The AMS Group, states that “to date, 100% of our conver­sions have been to a 407 variant.” He agrees with others that occasionally there may be capac­ity constraints for R-22 retrofits to sys­tems where capacity is tight, but these situations are rare.

woman shopping

Bryan Beitler, chief engineer at Source Refrigeration, reports that seven of 15 of Source’s major supermarket accounts already made the switch to lower GWP refrigerants for new stores. He estimates that about 50% of the firm’s new installs use 407A. As far as R-22 retrofits are concerned, “Most are using R407 for this activity. It’s been awhile since we have done any retrofits with R404A or R507, as there were too many things to change.”

Bill Almquist, president and CEO at Almcoe Refrigera­tion, mentions that the climate impact of the increased energy consumption of some of the lower GWP refrigerants has to be counted against the climate benefits of the refrigerants themselves.

What about the final issue: that EPA is out to destroy American business? I could write an entire article about this. At some point in time, I’m sure I will do that. For now, I’ll just say that this seems to be a question that is both asked and answered based on one’s politics, rather than facts. Whether you believe that EPA should be done away with or you think that EPA doesn’t do nearly enough to protect the environment, I doubt that anything I can write will change your mind.

I’m a pretty practical person. I try to concen­trate on areas where I can be of help. What I am going to focus on in relation to EPA’s proposed rule are the questions that I think are the ones we should be asking.

GOOD QUESTIONS What is the definition of a “new” system? If you double the size of your store during a remodel and you double the size of your refrigeration system, can you add new 404A racks onto an ex­isting 404A system? Or does EPA consider the whole system now to be a “new” system, due to the “new” racks being added to the “exist­ing” racks?

Is the EPA going to propose a phaseout of the use of 404A and 507 in existing systems at a later date, only to have us go through yet another series of retrofits?

Is the EPA going to restrict the supply of 404 or 507, so that the prices of these refrigerants increase enough that no one can afford to buy it for existing systems?

Is the EPA going to wait a few years and then restrict the use of 407 refrigerants and/or 134a?

And finally, are we ever going to find a solution to the environmental harm caused by refrigerants, so that it’s not necessary for EPA to regulate them anymore?