Significant changes are set to affect the building industry this year. National changes like refrigerant phase-outs due to global warming potential, and regional changes, like the tri-annual code updates. While increased cost of capital may have some owners thinking about delaying projects, other factors should be considered to have a full picture of what that delay could mean.
The American Innovation and Manufacturing (AIM) Act of 2020 is focused on the reduction of HFCs (Hydrofluorocarbons) in the United States. This act affects our industry in determining what refrigerant technologies are available in the near future. A fact sheet on the act can be found here. Barton will be providing an in-depth article in the future to outline this issue, as manufacturers settle on a path forward. In the meantime, here are the highlights as we see them:
- There is no requirement to convert existing equipment.
- Understand your proposed project schedule and plan for legacy or new equipment based upon facility needs and equipment availability.
- The International Code Council (ICC) has requested that each Authority Having Jurisdiction (AHJ) adopt the latest compliance requirements for A2L refrigerant chases.
- Refrigerant piping may need to be routed in ventilated chases.
- Traditional VRF systems may not be viable in the future due to refrigerant concentration concerns.
The Final Rule of the act, effective December 26, 2023, has the following general requirements:
- 2023 – A 10% reduction in HFC production, to 90% of historical levels.
- 2024 – A further 30% reduction in HFC production, to 60% of historical levels.
- 2029 – A further 30 % reduction, to 30% of historical levels.
- “Products”, or assembled equipment that is fully functional leaving the factory, like RTUs, Condensing Units, etc., will have specific sunset dates, some of them very soon.
- “Systems”, or field assembled equipment will not be restricted, so that compressors, condensers, etc., can be replaced or repaired.
- The earliest Product restrictions begin January 1, 2025, and the final restrictions will be in place by January 1, 2028.
The changes taking effect in January of 2025 affect residential and light commercial split systems and heat pumps, chillers for comfort cooling, and retail food refrigerators, among other items. If these items are in a planned project, reach out to your design engineer or vendor to make sure you are planning for the future. While there’s not immediate danger of not being able to get parts or refrigerants, there will likely be a rise in cost similar to the phase outs of R-22 and R-12.
2024 is also the year of the tri-annual code updates. For those working in a majority of Pennsylvania, that will likely mean a change to the 2021 International Construction Codes. In the Philadelphia area, that change may or may not include provisions of the 2024 International Construction Codes, if past processes hold true. This means that any project submitted between October 2025 and April 2025 may comply with either the existing code year or the new version, with a phase out of the existing codes next April.
While the Commonwealth has not announced this change officially, the Pennsylvania statewide code, the “Uniform Construction Code” is required to adopt the next version every three years by law. That change was delayed during the current code cycle due to the COVID-19 pandemic, and any ramifications on the current code cycle have not been announced.
New Jersey and Maryland are in the middle of their code cycles, with the current code being the 2021 International Construction Codes, with no anticipated changes this calendar year. Reliable building code information for your area can be found at a number of resources, such as www.upcodes.com, www.iccsafe.org, among others.
North Carolina is in the process of moving to the 2024 North Carolina Building Codes, and appears to be moving toward a January 1, 2025 acceptance date.
West Virginia generally continues to require the 2018 ICC Codes, with some exceptions and amendments, with a sunset date on this provision to be no later than 2027.
With the required building codes being in a constant state of advancement, the notes above are just a small snippet of applicable requirements for construction in those states. It is important to completely understand not only the applicable laws and codes for when your project begins, but also when it is projected to be issued for permit, and construction. In most cases, it requires a team of professionals from various fields to cover all aspects of a project, so it’s important to make sure your team is looking toward the future. It can save a significant amount of time, money and headaches by being proactive.
Feel free to contact Stephen E. Oskin, PE, LEED AP at 814-237-2180 or seo@ba-inc.com with questions about any items covered in this article.