Q&A: How does the EPA classify ACs in electrical rooms?
Question
Under 40 CFR 84, Subpart C: Phasedown of Hydrofluorocarbons-Management of Regulated Substances, are air conditioning units for electrical rooms considered comfort cooling appliances or industrial process refrigeration?
Answer
Air conditioning units for electrical rooms and other rooms housing computer and electrical equipment are considered comfort cooling.
In a rule, 40 CFR Part 82, Protection of Stratospheric Ozone: Update to the Refrigerant Management Requirements Under the Clean Air Act, published on November 18, 2016, the EPA proposed that the definition of “comfort cooling” include equipment “for climate control to protect equipment within a facility, such as but not limited to computer rooms.” However, this phrase was not included in the final definition under 40 CFR 82.152. But the logic behind the proposal was that the air conditioning systems for equipment rooms function more like comfort cooling system that controls temperature and humidity than industrial process refrigeration. The EPA continues to use this logic in its interpretation of the definition of comfort cooling under 40 CFR 82 and carried that interpretation into 40 CFR 84.
In the final rule, 40 CFR Parts 84, 261, 262, 266, 270, and 271- Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under the American Innovation and Manufacturing Act of 2020, published October 11, 2024, in a response to a comment, the EPA stated a desire that the definitions of 40 CFR 84 and 40 CFR 82 be “parallel” stating that “many of these requirements established for industrial process refrigeration and comfort cooling in this rule are analogous to those that apply under 40 CFR part 82, Subpart F and EPA anticipates that using parallel definitions will facilitate understanding of the rule’s requirements amongst regulated entities and support compliance for those entities that already have established approaches to complying with similar requirements for similar equipment under Subpart F. Accordingly, the appliances that cool data centers, ITEF, computer room cooling equipment, communications rooms, and appliances associated with cooling other spaces dedicated to maintaining the operating temperatures of electronic devices are considered comfort cooling for purposes of the [Emissions Reduction and Reclamation (ER&R)] program established in this rule. [emphasis added]”
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