realestate

Fugitive Emissions: Commercial Real Estate Must Tackle Refrigerants

Real estate tackles carbon with energy efficiency, low‑carbon materials, tenant engagement—now refrigerants too.

R
eal estate has long tackled carbon by tightening energy use, choosing low‑carbon building materials, and engaging tenants. The next frontier is refrigerant emissions—every HVAC‑equipped property faces rising compliance costs and fines as leaks, phase‑outs, and stricter regulations tighten the net.

    Refrigerants are far more potent than CO₂. The chemicals in modern HVAC units can be up to 2,000 times more warming‑potent, contributing roughly 15 % of the built‑environment’s 40 % global emissions. Addressing them can blunt global warming by up to 0.5 °C by 2100, yet they remain an overlooked source of emissions.

    High‑GWP refrigerants such as R‑410A are already being phased out. The U.S. AIM Act, effective 1 Jan 2026, imposes tighter leak‑repair, reclamation, and reporting rules; by 2029 only recycled or reclaimed R‑410A may be used. The Kigali Amendment mandates a global HFC phase‑down by 2047, with many jurisdictions tightening the timeline—e.g., a 2036 target of 15 % of historic baseline levels. State‑level rules add heft: EPA Section 608 can fine up to $37,500 daily for non‑compliance in buildings with >50 lb of refrigerant; Washington’s program inspects and certifies large facilities, capping fees at $5,000 per site; New York’s Part 494 bans bulk HFC sales and requires leak disclosure and labeling.

    ULI Greenprint has been educating members through webinars, working groups, and the annual State of Green report, where members voluntarily disclose refrigerant emissions. These efforts underscore the urgency of proactive management.

    A robust refrigerant plan has four pillars:

    1. **Inventory** – Keep a live list of all refrigerant‑using assets.

    2. **Event tracking** – Log leaks, repairs, inspections, and recoveries with digital sensors or records.

    3. **Compliance servicing** – Use only licensed technicians and maintain documentation for every intervention.

    4. **Strategic retirement** – Replace aging, leaky units with low‑GWP alternatives, recovering refrigerant for reuse.

    Implementing this plan cuts operating costs by eliminating leaks, avoiding fines, and reducing HVAC downtime. It also signals climate responsibility to tenants and investors, strengthening confidence as regulatory pressure mounts.

    By shifting to low‑GWP refrigerants now, real‑estate owners can future‑proof assets, sidestep costly retrofits, and align with the inevitable tightening of HFC restrictions.

Commercial building with HVAC technician inspecting refrigerant leaks.