By Christina Starr, EIA Climate Policy Analyst
The Environmental Investigation Agency (EIA) filed a petition yesterday calling on the U.S. Environmental Protection Agency (EPA) to end the use of powerful greenhouse gases called hydrofluorocarbons (HFCs) in a number of applications, building on the significant progress made in two recent rulemakings under the Significant New Alternatives Policy (SNAP) Program.
Tackling HFCs is a key element of the Obama Administration’s Climate Action Plan. Issuing an additional rulemaking before the end of his term will help to maintain the U.S.’s current position as a global leader and to increase the country’s credibility as such in negotiations for a global phase down of HFCs at the Montreal Protocol. To this end, the EPA must ensure that the new rulemaking sets dates for removing as many of the remaining high global warming potential (GWP) alternatives to ozone depleting substances (ODS) as possible. This will send a clear signal to the refrigeration, air conditioning, foam and other industries that use these chemicals that a transition to the lowest-GWP and most climate friendly alternatives available is now underway.
With this goal in mind, EIA’s petition calls on the EPA to promulgate an additional rule banning a number of HFCs with high-GWP ranging from 600 to 22,800 times as damaging to the climate as carbon dioxide (CO2). These HFCs are currently used in a number of industry sectors, including various refrigeration applications from smaller equipment like household refrigerators and vending machines, to chillers and other large systems used in supermarkets, cold food storage warehouses, and food processing, as well as fire suppression systems. EIA’s voice was joined yesterday by two other environmental organizations, the Natural Resources Defense Council (NRDC) and the Institute for Governance and Sustainable Development (IGSD), who submitted a separate petition calling for the EPA to take similar steps to ban the use of many of the same HFCs.
Most immediately, EIA calls on the EPA to remove the highest-GWP chemicals HFC-23, SF6 and per fluorinated compounds (PFCs) with GWPs from 8,000 to approximately 22,000, as soon as 2017 and no later than 2019. EIA also requested that the EPA ban the use of HFC-507A and HFC-404A, which are widely used in refrigeration and have GWPs of almost 4,000 by 2019. EIA also calls on the EPA to also address other HFCs with GWPs above 1,000 in the same rule. This tier of HFCs should be banned at different effective dates for each end-use classification, ranging from 2019 to 2022 at the latest, depending on the availability of alternatives. This request includes a call to delist HFC-134a, the most widely used HFC, which was already banned for some end-uses in Rule 20, including car air conditioning, for all but essential uses. EIA also requests that the EPA seek to delist HFC-410A and HFC-407C (with GWPs above 2,000) from all possible uses where suitable low-GWP alternatives exist.
Finally, and just as importantly, EIA calls upon the EPA to carefully consider the need for new transitional HFC blends with GWPs from 600 to 1,400 or higher in new equipment and retrofits. These new substitutes which were recently approved on the SNAP list of alternatives and have yet to be taken up by the market, have the potential to cause a major and sustained impact on the climate when compared to other available alternatives with GWPs of 10 or less. Allowing these HFC blends in new and retrofit equipment risks locking in high emissions from these chemicals for decades and undermines the market growth of suitable low-GWP alternatives. The widespread use of the HFC blends would also put the United States on a different transition pathway than many other countries implementing national policies to encourage a more rapid transition to the lowest-GWP alternatives, and threaten to undermine U.S. leadership toward an ambitious global HFC phase down. The EPA should promulgate a rule banning HFC blends from new equipment and strictly limit their use in retrofits of existing equipment in only those end-uses where they replace old substitutes with substantially higher climate impacts.
For a full summary table of the HFCs and end uses covered in EIA’s petition, and the low-GWP alternatives available to replace them, click here.