Summary
New EPA regulations under the AIM Act will require residential HVAC systems to use lower Global Warming Potential (GWP) refrigerants starting January 1, 2025, with an installation extension until January 1, 2026, for pre-2025 equipment. Affordable housing developers should prepare for changes in equipment, cost, and code compliance as manufacturers shift to slightly more flammable A2L refrigerants like R-32 and R-454B. Stay tuned for more on code updates and scope of work impacts. HDJ, Inc. is here to support your design needs—contact us to learn more.
By David Spiegel II
Understanding the new A2L refrigerants is critical in developing a scope of work. This is especially true for affordable housing and low-income housing tax credit (LIHTC) developers working on renovation projects, as there are potential cost and procurement implications.
How did we get here?
In 2020, the American Innovation and Manufacturing (AIM) Act was signed to reduce hydrofluorocarbons (HFCs) use. These HFCs are primarily used to manufacture refrigerants in many applications, including HVAC equipment. Beginning on January 1, 2025, the Environmental Protection Agency (EPA) would require all residential heat pump and air conditioning systems to be installed utilizing refrigerants with a maximum of 700 Global Warming Potential (GWP).
In December 2023, however, the EPA approved a modification to the final ruling, extending the installation deadline of HVAC equipment utilizing older refrigerants until January 1, 2026, as long as the equipment was manufactured before January 1, 2025. This extension was motivated by concerns about lost inventory, especially in the multi-family construction sector, where equipment is purchased before construction.
That said, to be in compliance with the new EPA regulations, manufacturers needed to find a lower GWP alternative refrigerant. The most common refrigerants used to meet this demand are R-32 and R-454B, which ASHRAE classifies as an A2L refrigerant. These A2L refrigerants are slightly more flammable than the older A1 refrigerants but have a lower toxicity level than the B series refrigerants. Due to these refrigerants having slightly more flammability characteristics, the building and mechanical codes have required some revisions to ensure safe installation.
These new HVAC systems using A2L refrigerants will look very similar to what most contractors are accustomed to and should not pose any issues with installation. Smaller HVAC systems, such as packaged terminal air conditioners (PTAC) and window units, have already used these A2L refrigerants for several years.
The Issue.
As noted above, the A2L refrigerants are slightly more flammable than the A1 refrigerants, which has led to changes to building and mechanical codes. A second blog post on this topic will explore the new code requirements and highlight the scope of work implications for developers.
HDJ, Inc. is a leading national design firm providing architectural and engineering expertise to support the affordable housing industry throughout the United States. HDJ’s diverse portfolio includes successful outcomes with adaptive reuse renovation, acquisition rehab, new construction, historic preservation, and RAD. Contact HDJ to learn more about how we can support your design needs with these new systems.
HDJ is a leading national design firm providing architectural and engineering expertise to support the affordable housing and LIHTC industry throughout the United States. HDJ’s large and diverse affordable housing portfolio includes successful outcomes with preservation rehab, adaptive reuse, and new construction projects.
