Carrier believes that condensing units, which were classified by EPA as components should be classified as a subassembly of components in order to uphold the initial intent of the Clean Air Act - to protect the ozone layer when it comes to the phase-out of R-22.

“The EPA never could have intended for so many condensing unit manufacturers to restart production of R-22 units, but that’s exactly what has happened.

R-22 is being phased-out for a reason, and that reason is because it depletes the Earth’s protective ozone shield from the sun’s radiation,” said John Mandyck, chief sustainability officer for Carrier. “Not only is the proliferation of R-22 use counter to environmental goals, it sacrifices energy efficiency because the EPA won’t allow the proper matching of coils through a system change-out.

That’s significant.” According to Mandyck, if 20 percent of the market moves to dry R-22 units, nearly 10 percent of the gains achieved by the entire 13-SEER efficiency rule will be lost. If the market moves to 80 percent dry R-22 units, nearly a third of the gains from the 13 SEER rule will be wiped out.

“The replacement of a condensing unit without replacing the indoor coil is a step in the wrong direction,” he added. “The bottom line is we have to remain vigilant. Continued production of dry R-22 units is inconsistent with the 20-year expectation by our industry. It delays the transition to non-ozone depleting alternatives, and it does not achieve the energy efficiency consumers expect.”