![]() By Beth Bouvier, PE, CIH, LEED® AP
Does your HVAC system use a chiller? If so, your facility may be subject to new reporting rules set by The New Jersey Department of Environmental Protection (NJDEP). The new rules, which were adopted on June 6th, 2022, require monitoring and reporting on a number of greenhouse gas emissions including certain refrigerants. The regulations require facilities using these refrigerants to be registered and file annual reports on emissions from those refrigerants. If you heard “regulations that apply to facilities using refrigerants” and the first thing to come to mind was large refrigeration systems, you would be correct. These regulations do apply to large refrigeration systems like those found at grocery stores, warehouses, and ice rinks. However, these regulated refrigerants are also commonly found in HVAC systems that use chillers. What You Need to Know: Facilities that have at least one refrigeration system with a full charge capacity of 50 pounds or more of high global warming potential refrigerants are required to register and report their equipment and use of refrigerants. This regulation applies to chillers, as well as refrigeration systems at grocery stores, warehouses, ice rinks, etc. Air conditioning equipment, such as roof top units, air handlers, condensing units, split systems, etc. are excluded from these new requirements, but chillers are not. To ensure compliance, you should review any chillers associated with your HVAC system as well as any other refrigeration equipment to determine if you need to start reporting your emissions under the new regulations. How Quickly Do I Have to Act? If your building is subject to the new requirements, you need to register your facility by November 1, 2022. Then, starting April 1, 2023, you must submit an annual report. So, if you didn’t know about this regulation, or that it may apply to your facility, it is important to identify if you are required to submit as soon as possible. Is This Rule Just About Refrigerants? The requirements are part of an effort by the state of New Jersey to identify significant sources of greenhouse gas emissions and monitor progress towards greenhouse gas emission reduction goals. The newly adopted rules also require facilities that have the potential to emit 100 tons or more per year of methane to report their methane emissions annually beginning May 15, 2023, and include requirements specific to natural gas public utilities. How Do I Find Out If I Need to Act? If you are unsure if your facility is subject to these requirements, you should contact an environmental services professional to help determine your obligations. If you have chillers or refrigeration equipment, an environmental professional can help you determine if they hold enough of a relevant refrigerant to qualify your facility for the mandatory reporting. If you are required to monitor and submit reporting, a qualified professional can help you through the process. # # # LAN Associates is a full-service architecture and engineering design firm that primarily services K-12, higher education, municipal, commercial, ecclesiastical, and private clients. The firm was founded in 1965, and is based in Midland Park, NJ, with offices in Goshen, NY, Voorhees, NJ, Vernon, NJ, and Bethlehem, PA.
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