Examining the AIM Act’s implications for refrigerant choice, compliance, and future design.

At first sight the connection between the American Innovation and Manufacturing (AIM) Leadership Act of 2020 and the fight against climate change might not be obvious, but, like watching a skillful street artist creating a chalk picture, the pieces suddenly snap into place and the link becomes clear.

The opening paragraph says AIM is “A bill to create jobs and drive innovation and economic growth in the United States by supporting and promoting the manufacture of next generation technologies, including refrigerants, solvents, fire suppressants, foam blowing agents, aerosols, and propellants, and for other purposes.” This is eminently sensible and an example of what an inspiring graduation speaker might describe as, “Doing the right thing and doing the thing right.” It’s good either way.

However, it’s not a new thought. The original European Union F-gas regulation of 2006 states (in Article 8) that “the application and enforcement of this Regulation should spur technological innovation by encouraging continued development of alternative technologies and transition to already existing technologies that are more environmentally friendly.” This is handy for America. If the life-sized lab experiment known as Europe has been experimenting in F-gas reduction for the last 16 years, there should be some lessons learned to speed the process west of the Atlantic, or at the very least avoid some potholes and pitfalls. Here are a few of my observations on the story so far.

Refrigeration system owners are sharply divided into two camps. One saw the change coming early and made their move. The other tried to stave off the change for as long as possible. They were generally less successful and didn’t gain any advantage from the enforced change.

One reason for that negative experience is that the targets continually changed. This is not surprising because it is very difficult to coordinate the creation of a complex piece of legislation like the AIM act, but once it is enacted it is extremely easy to twiddle the numbers. In fact, the European experience indicates that politicians just can’t help themselves. Early adopters insulate themselves from that uncertainty, whereas laggards can get caught out with expensive increases in refrigerant costs and retrofit options.

A further consequence of the desperate position slow adapters are often forced to adopt is they are prey to various criminal schemes to dodge the regulations, such as smuggled or counterfeit refrigerants. This can lead to complications both technical and legal.

AIM and F-gas are not identical. AIM has avoided some difficulties introduced by F-gas regulations such as training and certification of technicians and mandatory time schedules for tightness testing of systems. It has introduced some useful additions, for example the possibility of trading schemes with a 5% “tax” on the quantity traded, so the quantity in circulation is always diminishing. The phaseout program in AIM is not as fast as the F-gas regulation, but ends up with a deeper cut, down to 15% of base values by 2036. European experience suggests this is effectively a complete phaseout so nobody should assume refrigerants will be available for their purposes much beyond 2029 when the residual amount permitted drops from 60% to 30%.

AIM has been 25 years in the making, so if you are surprised by its arrival you haven’t been paying attention. Now is the time to get with the program and view it as more of an opportunity than a threat.