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EPA Requirements on Refrigerants and Residential Property

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Marina Shlomov - Monday, April 4, 2016

There is a concentrated effort around the world to reduce and eventually eliminate the use of ozone-depleting refrigerants. We want to make you aware that legislation now exists that could have a direct impact in the future on a heat pump or air-conditioning system in a property you may own.

In most residential properties, HCFC (hydro chlorofluorocarbons) R-22 is the most commonly used refrigerant today and believed to contribute to global warming. The trend now is to replace a unit containing R-22 with one that has HCFC R-410A. This is one of the products reviewed and found acceptable by the EPA, the Environmental Protection Agency, under the Clean Air Act.

To put it simply, the EPA is not allowing continued production or importing of R-22. Currently, there is a definite schedule to phase out HCFC R-22 and it is as follows, per the EPA site.

Under the terms of the Montreal Protocol, the U.S. agreed to meet certain obligations by specific dates that will affect the residential heat pump and air-conditioning industry:

    • January 1, 2004: the Montreal Protocol required the U.S. to reduce its consumption of HCFCs by 35% below the U.S. baseline cap. As of January 1, 2003, EPA banned production and import of HCFC-141b, the most ozone-destructive HCFC. This action allowed the United States to meet its obligations under the Montreal Protocol. EPA was able to issue 100% of company baseline allowances for production and import of HCFC-22 and HCFC-142b.
    • January 1, 2010: the Montreal Protocol requires the U.S. to reduce its consumption of HCFCs by 75% below the U.S. baseline. Allowance holders may only produce or import HCFC-22 to service existing equipment. Virgin R-22 may not be used in new equipment. As a result, heating, ventilation and air-conditioning (HVAC) system manufacturers may not produce new air conditioners and heat pumps containing R-22.
    • January 1, 2015: the Montreal Protocol requires the U.S. to reduce its consumption of HCFCs by 90% below the U.S. baseline.
    • January 1, 2020: the Montreal Protocol requires the U.S. to reduce its consumption of HCFCs by 99.5% below the U.S. baseline. Refrigerant that has been recovered and recycled/reclaimed will be allowed beyond 2020 to service existing systems, but chemical manufacturers will no longer be able to produce R-22 to service existing air conditioners and heat pumps.

Here are additional facts you should know

  • For several years, R-22 will continue to be available for servicing existing systems with R-22.
  • Over time, the cost of R-22 will increase as the amount available for use depletes - this means that the cost of repairs for units with R-22 has already escalated.
  • There is no requirement for a property owner to change to a new unit with R-401A or retrofit a unit with an acceptable refrigerant by the EPA if you can have the unit repaired.
  • You cannot retrofit an old unit, using R-22, with the new R-410A because of its higher working pressures - it would require making major and very costly changes to the unit.
  • The Clean Air Act does require repairs on refrigerants be handled responsibly. This means you must use a technician who can successfully recover, recycle, and reduce leaks of R-22 into the ozone. System leaks not only damage the ozone but can also increase maintenance costs.
  • Retrofitting or repairing an old system may be wasting money when a newer system could save overall. It can often be a difficult decision to make.

You may have already encountered problems regarding R-22 in your own personal home or investment property. If not, what do you do if you have a property with a problem regarding a unit with R-22? Depending on the problem, this can mean anything from a reasonable repair to the high cost of complete replacement. This will vary greatly depending on the unit in question. It is important to use qualified technicians and weigh repair vs. replacement carefully.

As your management company, we know this can be a stressful situation for a property owner. If this does happen to your unit, we will assist you with estimates from qualified technicians so you are well informed and can make the best possible decision for your property. One thing we cannot do is ignore the new regulations regarding R-22. You can obtain more information on the topic of eliminating R-22 at

Marina Shlomov, a managing partner at ALH|Podland Rental Homes Property Management is the author of many articles on Landlording, Property Management, and Real Estate Investing. A residential builder in the state of Georgia since 1999 and a property manager, Marina is an investor herself. Her property management company is intended “For Investors” and “By Investors” for a simple reason – she knows what investors’ goals are and she works hard to reach their goals. In her spare time, Marina likes to spend time with her family, friends, garden, read and travel. Check her out at in the About Us/Meet the Team section. You can find Marina’s articles and comments at @rentalhomesatl on Twitter, on Facebook, Google+, Blogger.and YouTube.

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