The California Air Resources Board (CARB) has led the way in reducing hydrofluorocarbon (HFC) emissions. These are a class of long-lasting greenhouse gases widely used in refrigeration, air conditioning, and other industrial applications. The phasedown regulations are now in effect and have prompted California businesses to get up to speed on compliance requirements.
A clear understanding of the compliance requirements and available funding programs is crucial for food retail, industrial cold storage, and food and beverage processing facilities as they move forward.
Recently, General Manager of CoolSys Energy Design Ben Rosenzweig and Janelle Trebizo, Compliance Manager of CoolSys, were featured on a podcast. Both shared their expert insights on the subject. Below is a summary of some of their comments on this important matter, presented in a Q&A format:
Q: Please provide a high-level overview of CARB regulations and how they relate to the HFC phasedown.
Ben: The CARB FRIP program, or F Gas Reduction Initiative Program, was developed in California due to the state realizing that the transition to low and ultra-low GWP (Global Warming Potential) refrigerants is a costly but necessary transition for the environment.
Effective as early as January 1, 2022, CARB enacted regulations that required retail food refrigeration facility systems with over 50 pounds of refrigerant to only install new equipment and systems with a GWP of 150 or less.
Going forward, the additional rules stated companies owning 20 or more stores in California, with equipment containing 50 pounds or more of refrigerant in at least one system, would need to attain a companywide weighted average GWP of less than 2,500 or demonstrate a 25% reduction in greenhouse gas potential below 2019 levels by December 31, 2026.
In addition, companies owning fewer than 20 stores will need to comply with similar requirements, but a GWP weighted average of 1,400, or a 55% or greater reduction in greenhouse gas potential emissions, by January 1, 2030. These are very aggressive goals that will be very costly for retail and other refrigerated space owners. Thus, the state came out with an incentive program funded by $45 million to help owners make the refrigerant transition to low and ultra-low GWP refrigerants.
Q: Are the CARB regulations more restrictive than what we’re seeing on a federal level?
Ben: The CARB regulations are stricter, or in line with some of the EPA’s federal regulations. However, in California, almost all the triggers are earlier. So, as I mentioned before, on January 1, 2022, the limit of a GWP of 150 or less on new equipment and systems containing 50 pounds or more of refrigerant went into effect.
Federally, the Technology Transition Rule — part of the AIM Act — was finalized. The triggers for those start over the next couple of years for different types of equipment and systems with varying GWP limits between 150 and 300 for different types of refrigeration systems, and 700 for HVAC systems. So, the federal rules that are coming are as strict as CARB regulations, and they’ll be challenging to adopt. However, they don’t include enterprise-wide weighted average GWP requirements that will force retailers to do retrofit and replacement projects across their enterprise of sites and assets throughout the state of California to comply with those deadlines that come due in 2026.
WATCH:
Q: What do clients need to know about the process for applying for the CARB FRIP funds?
Ben: To apply for CARB FRIP funds, one must be eligible to apply for CARB FRIP funds. And while the full format rules have been finalized and published, the folks eligible to apply for CARB FRIP funds have a site.
It’s the site that’s eligible for funds. It’s a refrigerated facility that has a system or equipment with more than 50 pounds of high-GWP refrigerant in at least one of those pieces of equipment or systems. The applicant and facility must also be registered under the Refrigerant Management Program (RMP) and comply with all the associated federal and state laws, including CARB’s regulations around the 2020 HFC regulations that were published in the state.
The existing system eligibility to apply is by sector. So those sectors are: retail food refrigeration, industrial process refrigeration, and cold storage and other refrigeration. The minimum GWP for all existing systems to be replaced is 1,300 for retail food, 1,800 for industrial processes, and 1,800 for cold storage and other.
Additionally, the minimum refrigerant charge for the sum of the existing systems to be replaced in the application is 2,000 pounds for industrial process refrigeration and 1,000 pounds for cold storage and other refrigeration. There is no limit, or minimum refrigerant charge, for retail food refrigeration.
So, if you qualify for those it is worth checking in the full format FRIP guidelines for other eligibility criteria related to the applicant. Also, you can go to the FRIP funding website to create a profile and apply.
Q: Can you give us some highlights of the key dates and timeline for applying?
Ben: The CARB FRIP program that has currently been issued and finalized has two different windows for application, and the funding is available on a first-come, first-served basis. The first application window opened October 14, 2024 and closes January 31, 2025. The second opens March 3, 2025 and closes May 30, 2025.
The funding has to be available in order to be used. It’s on a first-come, first-served basis. Applicants also must confirm that projects will be completed, in terms of execution in the field, by December 31, 2026.
Related to reimbursement payments for the technical grantees or the approved applicants for the FRIP program, if you’ve submitted your request for reimbursement, your project is complete, and you’ve met all the other criteria by December 31, 2026, applicants can expect their reimbursement payments for approved requests no later than April 30, 2027.
It’s important to understand that this is not a rebate program or incentive program that provides you money up front to fund your project. It’s meant to be assistance to reimburse you for executing the actual projects so that there’s a way for the state to ensure the impact on the climate and reduction in greenhouse gas emissions is actually executed.
Q: With CARB FRIP funding, how much money can clients that are approved expect to get for their site? What’s the breakdown, and does it vary by sector?
Ben: The incentives will differ by sector and scale, with the size and scope of the replacement. Higher incentives are offered to facilities located in priority communities and independently owned and operated food retailers, as opposed to mass merchants with multiple sites throughout the state or country.
By sector, there are full replacement and partial replacement incentives. Those are designated for retail food refrigeration based on linear feet of cases being replaced or dollars per square foot of walk-in coolers and freezers. If you’re located in a priority community, the incentive rates per linear foot or square foot are higher.
For industrial process refrigeration, the incentive for full replacement is essentially $1,500 per cooling load ton, and $900 per cooling load ton for partial replacement. Lastly, for cold storage and other refrigeration categories, depending on the equipment you’re replacing, the incentives could be rated based on linear feet of case, square foot of refrigerated space, or cooling load per ton based on the type and scale of the system.
Q: How do you integrate the environmental goals, such as reducing the greenhouse gas emissions into the design and engineering?
Ben: At CoolSys, we consider the environmental impact of the systems we’re designing for new construction and retrofit projects in a couple of different ways.
The systems that we design, whether they’re MEP, refrigeration, or other building systems, have multiple different sources of emissions in the environment — namely scope one and scope two emissions. This refers to both direct emissions at the building, as well as emissions at the power plants providing the electricity or producing the electricity for your building.
CoolSys likes to look at it through the lens of the owner in terms of what drives them, as well as through the lens of the regulations that are out there. We look at the intent of the project and propose system designs that meet the regulations, but hopefully beat them, in terms of exceeding the minimum requirements.
For instance, CO2 as a refrigerant has a GWP of one. It’s essentially future-proof when it comes to GWP limits of 150, 300, or higher in terms of the federal and state GWP limits that we’re all facing. Looking at this industry today, we can help you understand how to transition to ultra-low GWP refrigerants like CO2, propane, and many other natural refrigerants. However, there are many solutions out there that will help you get from point A to point B based on your available capital. So, we like to look at all of those different facets in helping you understand the best solution to the multiple problems you’re trying to solve with your individual project.
Q: Are there any emerging technologies or innovations in the refrigeration systems that will really support the HFC phasedown requirements?
Ben: Today, there are many solutions that end users can consider in terms of technologies and system types when it comes to low GWP refrigerants. While systems like CO2 refrigeration systems and hydrocarbon refrigeration systems have been around for quite some time, technology has evolved significantly. The ability to implement a transcritical CO2 system or a cascade system with CO2 as a secondary refrigerant, all can be thought of through a new lens.
In terms of how we can get funding through the program, how we can design it, what type of equipment is available for retrofit projects, and new construction projects, opens us up to a bit more of a solution-based approach when it comes to solving those problems. The manufacturers continue to innovate in terms of the size, scale, and performance of the equipment. We’re happy to be in a place where we truly do have a number of solutions on the table for almost every different type of store format and system out there.
As California continues to lead the charge in climate action, companies that proactively adopt eco-friendly technologies and phase out HFCs will be better positioned to thrive in a low-carbon economy. Now is the time to assess, adapt, and leverage compliance opportunities for a greener, more sustainable future.
CARB Funding: CoolSys Is Your FRIP Application Partner
On that note, CoolSys is uniquely positioned to help retailers, owners, and others with refrigerated facilities and equipment in California apply for the FRIP process. CoolSys is not only an HVAC and refrigeration service and installation contractor, but also an engineering expert in the design of low GWP systems. We will help you develop your plans and programs to get from where you’re at today to the GWP levels that comply with California’s rules related to weighted average GWP. CoolySys is the ultimate partner for the full scope of your buildings and assets through construction service, commissioning, and recommerce of your equipment.
CoolSys understands what’s going on with the program as it relates to your refrigeration equipment and can help you not only apply for funding but come up with the most meaningful programs for equipment replacement. From design through execution, we help you not only get the most out of the program but make the most of it for your company. To learn more about how to transition to CO2 refrigerant systems and start the FRIP application process, contact CoolSys today!
