Own or operate a commercial AC Unit?

You Can’t Spell rEPAir Without EPA in the US

What is a Commercial HVAC System? - let's start with the basics

A commercial HVAC (heating, ventilation, and air conditioning) system is a complex network of components designed to provide a comfortable indoor environment for occupants of commercial buildings. Unlike residential HVAC systems, commercial systems are larger, more complex, and require specialized knowledge and expertise to install, maintain, and repair. These systems are essential for ensuring that large spaces, such as office buildings, shopping centers, and hospitals, maintain optimal temperature and air quality.

Commercial HVAC systems are tailored to meet the specific needs of each building, taking into account factors like size, occupancy, and local climate conditions. This customization ensures that the air conditioning system operates efficiently, providing consistent comfort while minimizing energy costs. Whether it’s cooling a high-rise office in the summer or heating a warehouse in the winter, commercial HVAC systems are designed to handle the unique demands of commercial environments.

Understanding the Basics

Commercial HVAC systems are designed to meet the unique heating and cooling needs of commercial buildings, which can vary greatly depending on factors such as building size, occupancy, and climate. These systems use a combination of heating, ventilation, and air conditioning to control temperature and humidity levels, ensuring a comfortable and healthy indoor environment.

The primary goal of a commercial HVAC system is to provide a stable and comfortable indoor climate, regardless of external weather conditions. This involves not only heating and cooling but also managing humidity levels and ensuring proper ventilation. By doing so, these systems help maintain indoor air quality, which is crucial for the health and productivity of building occupants.

Key Components and Functions

A commercial HVAC unit consists of several key components, including:

• Heating and cooling units: These units provide the necessary heating and cooling to maintain a comfortable indoor temperature. They can include boilers, furnaces, heat pumps, and air conditioners, each serving a specific purpose depending on the building’s needs.
• Air handlers: These units distribute conditioned air throughout the building. They work in conjunction with the heating and cooling units to ensure that the air is properly circulated and reaches all areas of the building.
• Ductwork: This network of ducts carries conditioned air from the air handlers to various parts of the building. Properly designed and maintained ductwork is essential for efficient air distribution and energy efficiency.
• Controls: These systems regulate temperature and humidity levels, ensuring optimal performance and energy efficiency. Modern control systems can include programmable thermostats, building automation systems, and advanced sensors that provide precise control over the HVAC system’s operation.

Each of these components plays a critical role in the overall performance of the commercial HVAC system. Regular maintenance and timely repairs are essential to keep these components functioning efficiently, which in turn helps reduce energy costs and extend the lifespan of the system.

How Commercial HVAC Systems Work

Warm or Cool Air Distribution

Commercial HVAC systems use sophisticated methods to distribute warm or cool air throughout a building, ensuring a comfortable environment for all occupants. One common method is through a duct system, which employs fans to circulate air via a network of ducts. This system is highly effective in distributing conditioned air evenly across large spaces, making it ideal for office buildings, shopping centers, and other commercial facilities.

Another advanced method is the Direct Digital Control (DDC) system. DDC systems utilize sensors and automated controls to manage temperature schedules and lighting operations. These systems can be customized to meet the specific needs of a business, providing precise control over the indoor climate. Whether using a traditional duct system or a modern DDC system, the goal is to ensure that cool air or warm air is efficiently distributed to maintain optimal indoor conditions. The regulations dont effect this very much.

Controls and Automation - big topic for 2025

In commercial HVAC systems, controls play a crucial role in regulating temperature and humidity levels. These controls can range from simple thermostats to more complex Direct Digital Control (DDC) systems. Simple thermostats allow for basic temperature adjustments, while DDC systems offer advanced features such as automated temperature schedules and integrated lighting controls.

There are several new advancements in the controls world that will soon touch all of our work lives, they will be known as AFDD (Automatic Fault Detection & Diagnostics), mathematical models that aim to detect and diagnose faults in the mechanical systems by analyzing their sensory data. Pay close attention to ASHRAE Guideline 36 which outlines best practices for implementing automated fault detection and diagnostics systems in HVAC systems.

2 more terms you will need to familiarize yourself with are ALDS and Indirect Leak Detection The Environmental Protection Agency (EPA) requires automatic leak detection (ALD) systems for certain appliances that contain refrigerants or HFC substitutes: 

• Appliances - New and existing commercial refrigeration and industrial process refrigeration (IPR) appliances that contain 1,500 lbs or more of refrigerant or HFC substitute with a GWP of 53 or higher 
• Installation - New equipment must have an ALD system installed within 30 days of installation, and existing equipment must have an ALD system installed within one year of the final rule's publication date 
• Compliance dates - New appliances must comply with the ALD system requirements by January 1, 2026, and existing appliances must comply by January 1, 2027 
• Leak rates - If a direct ALD detects a leak at the 100ppm threshold, the leak rate must be calculated or the leak must be repaired 
• Indirect ALDs - These are special new tools, that monitors various operating parameters like pressure, temperature, and compressor current within a refrigeration system to identify potential leaks by analyzing deviations from normal readings, rather than directly detecting the presence of refrigerant in the air alarm threshold for indirect ALDs is the lesser of 50-pound refrigerant loss or 10% of the chargeOverview of System Variations

Some common types of commercial HVAC systems include:

• Packaged systems: These systems combine heating and cooling units in a single package, making them ideal for smaller commercial buildings. They are typically installed on the roof or a concrete slab near the building, providing a compact and efficient solution for heating and cooling needs.
• Split systems: These systems separate the heating and cooling units, allowing for greater flexibility and customization. Split systems are often used in larger buildings where different areas may have varying heating and cooling requirements.
• Modular rooftop units: These systems consist of multiple units that can be combined to meet the heating and cooling needs of larger commercial buildings. Modular rooftop units offer scalability and can be easily expanded or modified as the building’s needs change.
• Traditional systems: These systems use a combination of heating and cooling units, air handlers, and ductwork to provide a comfortable indoor environment. Traditional systems are versatile and can be customized to suit a wide range of building types and sizes.

Each type of commercial HVAC system has its advantages and disadvantages, and the choice of system depends on factors such as building size, occupancy, and climate. Regular maintenance and repair are essential to ensure optimal performance, energy efficiency, and indoor air quality. But now, you have to know how the system will be able to be supported in 12 years when access to common refrigerants run out and your CFO still has 20 years left on the depreciation table :(

Selecting and Sizing Your Commercial HVAC System - whats changing?

Factors to Consider

When selecting and sizing a commercial HVAC system, several critical factors must be taken into account to ensure optimal performance and energy efficiency. The size of the building is a primary consideration, as it directly impacts the system’s capacity requirements. Additionally, the number of occupants and the type of equipment used within the building can influence the heating and cooling needs.

Climate is another essential factor, as it determines the system’s workload throughout the year. For instance, buildings in colder climates may require more robust heating solutions, while those in warmer regions need efficient cooling systems. Insulation, windows, and overall building design also play a role in determining the appropriate HVAC system size.

Energy efficiency and indoor air quality are paramount when choosing a commercial HVAC system. Look for systems with high energy efficiency ratings, as these can help reduce energy costs and minimize environmental impact. Features such as air handlers can further enhance indoor air quality by ensuring proper ventilation and filtration.

The system’s capacity, measured in British Thermal Units (BTUs), is crucial for sizing. A system that is too small may struggle to meet the building’s heating and cooling demands, leading to discomfort and higher energy consumption. Conversely, an oversized system can be inefficient and waste energy. A well-sized system, tailored to the building’s specific needs, can provide consistent comfort while optimizing energy use.

Selecting and sizing a commercial HVAC system involves careful consideration of building size, occupancy, equipment type, and climate. Additionally there are regulatory and possible obsolescence issues that are effected by regulations, pay close attention to federal and state regulations./. Historically, prioritizing energy efficiency and indoor air quality, to ensure the system is appropriately sized, to achieve a comfortable and cost-effective indoor environment was enough but now the paradigm has shifted and your team needs to look ahead make sure the equipment survives its planned depreciation period and right now, most equipment will be obsolete in 12 years.

How to End the Year Like a Pro: A 2024 Update

Every year I write one of these, its been going on for 10 years, and just like all the others, some important things have changed and soon more things will change, how we all work and with that in mind, it’s critical to reflect on significant changes in refrigerant regulations at the state and federal levels.

As far off as updates to in California, New York, Colorado or Washington’s may seem if you are in Tennessee, Texas or Florida, federal advancements under the AIM Act—including new Federal regulations under Subsection H and the Technology Transition as well as state level requirements will change how we all do business.

Just like, Understanding British Thermal Units (BTUs) is crucial for determining the cooling capacity of commercial HVAC systems, the math applies differently everywhere. BTUs measure the amount of heat removed by air conditioning systems, and one ton of cooling capacity is equivalent to 12,000 BTUs.

Whether you’re new to this area or seasoned in the field, these developments demand attention to ensure your company remains compliant while optimizing operations and sustainability.

Refrigerant Regulations Compliance for AC Owners and Operator: Why It Matters

Regulatory compliance is no longer just about avoiding penalties. It’s a business advantage. Companies that prioritize refrigerant management:

• Gain access to funding opportunities through ESG (Environmental, Social, and Governance) initiatives.
• Improve equipment efficiency and reduce operating costs.
• Enhance their reputation by mitigating climate impacts from refrigerant leaks and emissions.

We’re all used to boundary lines and guides—they limit us, focus our efforts and even empower us to work more effectively. Regulations are no different. They are simply another set of criteria to navigate. The EPA didn’t invent leaks; they are just responsible for managing how we deal with them. And let’s face it, nothing in life is free—ignoring regulations is no different than ignoring a budget, a customer’s request, or a key priority. The costs will catch up to you eventually.

The world is narrowing the individual control we have over these systems, and the good news is that regulations provide us with cover. When something goes wrong, you can say, “Hey, it’s not my fault—these systems are built by humans, and I have rules to follow.” Capacitors, for example, only last so long. If one fails, it can cascade into other issues, and refrigerant loss is no different. When refrigerants leak, the ripple effects include discomfort, spoiled food, skyrocketing energy bills, and hefty maintenance costs.

So, let’s get ahead of this. As Benjamin Franklin once said,

"An ounce of prevention is worth a pound of cure."

By proactively managing refrigerants and aligning with regulations, you’re not just following the rules—you’re building a resilient and efficient operation that benefits everyone involved.

This proactive approach is even more critical when considering how interconnected we are. For instance, regional challenges—like high humidity in Florida shortening the lifespan of AC capacitors—show how local conditions influence system performance. Similarly, evolving regulations in California and Washington set trends that eventually impact the entire country. By paying attention to these developments and embracing your role as a leader in compliance, you position your team as problem solvers equipped to navigate a dynamic regulatory landscape.

Think of regulations like guardrails on a highway. Sure, they might seem restrictive, but they’re there to keep you on track and help avoid costly mistakes. Plus, compliance doesn’t have to be all doom and gloom. Imagine telling someone, “I’m a pro at managing refrigerant leaks!” It’s oddly satisfying, right? A little humor goes a long way in making a technical subject approachable—and showing your team that compliance can be both important and manageable.

Regulations like California’s SB 253 and SB 261 further emphasize the importance of detailed disclosure and tangible reductions in Scope 1 emissions. These rules require companies to report on greenhouse gas emissions—including those from refrigerants—and to implement reduction strategies. Similarly, Washington State’s regulations on hydrofluorocarbons (HFCs) underscore the shift toward next-generation refrigerants. This is a regulation that will impact businesses that have activity in California, do a $ Billion in business and could be headquartered or operational anywhere - so this is very broad.

Key Federal Updates: AIM Act and Subsection H

At the federal level, the AIM Act continues to drive the phase-down of HFC production and consumption. Recent updates include:

• Technology Transition Rules: Accelerated adoption of climate-friendly alternatives to HFCs across multiple industries.
• Subsection H Provisions: New mandates for leak detection, reporting, and repair, with stricter thresholds for high-GWP (global warming potential) refrigerants.

The EPA’s enhanced reporting requirements mean companies must document refrigerant usage, leaks, and end-of-life management with precision. Failure to comply could result in significant penalties.

Executing as a Proper maintenance professional

1. Evaluate Your Compliance Program

One of the key steps to doing your job, is understanding their impact and ensuring your internal policies reflect the expectations of leadership and your authority and responsibility for delivering:

• Are your policies up to date, or are they the type you write but never apply?
• Are they overly complicated, or do they address the right things in a relatable and actionable way?

To benchmark your program, use the Department of Justice’s Evaluation of Corporate Compliance Programs as a guide:

• Are your policies and procedures effective?
• Have you disciplined non-compliance consistently?
• Do you regularly assess and improve your refrigerant management practices?
• Is your documentation complete and readily accessible?

A well-structured compliance program isn’t just a check-the-box exercise. It’s about creating policies that are relevant, clear, and actively used. Make them relatable to your team by connecting them to real-world scenarios. For example, explain how proper refrigerant management prevents major operational issues like spoiled food, discomfort, or skyrocketing energy bills.

This exercise isn’t just about meeting regulations; it’s about making your policies practical and ensuring they work in the context of day-to-day operations.

2. Understand State-Specific Regulations

• California: SB 253 requires companies to report Scope 1 emissions and disclose progress toward reduction targets. SB 261 mandates climate risk reporting. Additionally, California’s Air Resources Board (CARB) has introduced the R4 Program, which focuses on managing high-GWP refrigerants. The R4 Program enforces rigorous leak detection and repair protocols, equipment registration, and phase-out requirements for certain refrigerants. Businesses operating in California must comply with these standards to reduce their climate impact and avoid significant penalties.
• Washington: F-Gas regulations promote low-GWP alternatives and restrict high-GWP refrigerants in certain applications.
• Colorado: Proposed GHG regulations for refrigerant tracking and leakage control.

Manufacturers tend to standardize their equipment production to meet the most stringent regulations. As rules like these gain traction, manufacturers often adjust inventory and phase out older, non-compliant models. This means that equipment no longer allowable in certain states will soon become unavailable nationwide. Think of it like the Pontiac—once discontinued, parts became harder to source. Unlike collectible cars, HVAC equipment is not a luxury but a necessity, and obsolescence can create significant operational challenges.

Pay close attention to regulatory trends in other states because they will likely affect you eventually. None of us are immune to regional challenges. For instance, the lifespan of an AC capacitor is heavily influenced by local conditions. High humidity areas like Florida can cause rust and quicker breakdowns, showing how regional factors shape the way we work and apply solutions. For those in states like California and Washington, understand that you’re not at a disadvantage but at the forefront of pioneering solutions. Leverage this position to highlight your expertise in navigating these new paradigms and providing resilient, climate-controlled environments for your customers.

3. Set the Record Straight: Enhance Documentation and Reporting

When it comes to documentation, think about it the same way you audit your expenses or financials. Ask yourself:

• Is every leak repair completed within the required timeframe? Just like, did you pay your bills on time?
• Are vendors including critical details such as calculated leak rates on invoices or work orders? Or is this information missing altogether?

Just this past November, I reviewed over 1,000 work orders and found that none included a calculated leak rate—a glaring gap in record-keeping. This kind of oversight not only hinders compliance but also leaves your company vulnerable to penalties.

To address this, establish clear policies and procedures for documentation. Train your staff and vendors to prioritize accurate record-keeping. Schedule training sessions specifically for leak detection and documentation—even if you’re already doing a good job, this is a chance to reinforce best practices. And if it’s been a while since your last training, now is the time to set the record straight.

4. Reducing Leak Rates

Here’s an idea for reducing leak rates: Take a close look at your refrigerant usage. If you can’t measure it accurately for 2024, start planning now. Engage your vendors and request their input on creating a roadmap for 2026. This approach takes the pressure off 2025 while setting a clear long-term goal. Midway through 2025, remind them about the 2026 plan and encourage them to start earlier if possible.

Additionally, calculate refrigerant usage across all systems, not just the largest ones. Track how long it takes to repair every leak. This data will reveal patterns and help identify opportunities for efficiency improvements. By setting benchmarks for repair timelines and usage tracking, you’ll be better positioned to meet compliance goals and reduce overall leak rates.

5. Leverage Technology

Invest in tools that automate compliance tracking and reporting. For example, software solutions can:

• Monitor refrigerant usage in real-time.
• Generate reports aligned with state and federal requirements.
• Identify inefficiencies and opportunities for improvement.

Here’s an idea: Take a step back and assess your current technology. Did you implement it through a formal RFQ (Request for Quote) or RFP (Request for Proposal)? Or did you simply purchase something to try it out? If you’re already invested in a system, switch the script—set measurable goals and expect your existing vendors to help you achieve them. Engage them in discussions about your specific needs and ask how they can support your regulatory compliance and sustainability goals. If they can’t rise to the occasion, consider finding new vendors who are more aligned with your objectives. It’s not just about their sales—it’s about their commitment to your success.

You Can’t Spell rEPAir Without EPA in the US - The end of the year is a time to review your performance and set objectives. Consider these actionable steps:

• Conduct an end-of-year compliance review: Talk to peers, staff, and associations to gather insights and share best practices.
• Develop a refrigerant management plan: Start simple and build from there. Even a basic plan is better than none.
• Host regular meetings/training sessions: Schedule four sessions per year, each lasting 30 minutes, to align your team on regulatory changes and best practices.
• Reach out for resources: Email me at ted@tedatwood.com, and I’ll share some sample compliance policies—no strings attached. I want us all to win and do our best.
• Identify gaps and assess risks: Look for holes in your current program, ask who is responsible, and follow up by asking, "What’s the risk? and Who's to blame if things go south?"

Let’s finish strong and head into the next year with clarity, confidence, and a commitment to doing things the right way.