By Lowell Chandler, EIA Climate Policy and Research Associate
U.S. industry has arrived at a pivotal point, and the Environmental Protection Agency (EPA) has a significant opportunity to guide industry towards a profitable, energy efficient, and climate-friendly future. As the EPA works to finalize a proposed rulemaking prohibiting the use of high global warming potential (GWP) hydrofluorocarbons (HFCs) in certain end-uses, two primary questions are raised: Will the EPA produce a rulemaking that is a catalyst for significantly mitigating HFC emissions, driving U.S. innovation and market development, and supporting international momentum towards a global phase-down of climate-damaging HFCs? Or will the EPA succumb to recent pressure and threats of legal action from some industry representatives and produce a rulemaking that maintains the status quo for an industry already lagging behind much of the world in low-GWP refrigeration and air-conditioning technology?
The EPA’s current proposed rulemaking sets ambitious and achievable timelines for phasing out high-GWP HFCs, by prohibiting the use of some of the most potent HFCs that are currently listed as “acceptable” under the EPA Significant New Alternatives Policy (SNAP) Program. The proposed rule, should it keep this level of ambition, will play a critical role in the mitigation of HFC emissions and accelerate the market development of next generation low-GWP refrigeration, air-conditioning, foam blowing agents and aerosol technologies. Such a rulemaking will also have ripple effects on international momentum towards phasing-down these climate-damaging HFCs.
Several U.S. companies have had the foresight to begin developing and investing in the next generation of low-GWP alternatives to HFCs. In addition to being climate-friendly, these low-GWP alternatives are also already more energy efficient than HFC-based systems. Unfortunately, a few companies that want to continue to profit from the use of HFCs have called for a delay in the EPA’s prohibition dates in the proposed rulemaking. As Europe promotes the development of HFC-free equipment and products, a few vocal members of U.S. industry are dragging their feet, continuing to hold on to outdated, dead-end HFC technologies.
The EPA’s rulemaking is leveling the playing field for U.S. industry, providing incentives for moving away from HFC technologies, and initiating action to mitigate U.S. emissions of HFCs. The EPA is on the right track and needs support so it does not give in to the threats of a minority of U.S. manufacturers. The EPA should finalize its rulemaking to remove the SNAP certification from certain high-GWP HFCs with the same dates put out in the proposal.
As it stands, this proposed regulation could invigorate a slow-moving U.S. industry and ultimately position it favorably in the globalized economy for the next generation of refrigeration, air-conditioning, foam blowing and aerosols. If U.S. industry develops low-GWP equipment and products on a commercial scale, they could lead other countries around the world in the transition to HFC-free technologies. Also, given the U.S.'s leadership in the global arena to address HFCs under the Montreal Protocol, it is crucial that the United States lead by example by promulgating robust domestic regulations that encourage U.S. industry to transition to HFC-free technologies.
“Time and time again, we have heard from industry that they need a clear regulatory signal before they can move production to HFC-free technologies,” said Mark W. Roberts, International Policy Advisor for EIA. “The EPA’s ambitious rulemaking to prohibit the use of high-GWP HFCs sends just such a signal and provides U.S. industry with that necessary guidance to reduce U.S. emissions of HFCs, while also propelling U.S. industry to be global leaders in energy efficient, low-GWP, HFC-free equipment and products.”
As the National Oceanic and Atmospheric Administration has recently reported, atmospheric levels of CO2 are at a point that humans have never before experienced. Phasing-out HFCs is a low-hanging fruit in the battle to mitigate climate change impacts, as the transition to existing low-GWP alternatives would help mitigate up to 200 billion CO2 equivalent tonnes from the atmosphere by 2050.
The EPA is under direction of President Obama under the Climate Action Plan to “use its authority through its Significant Alternatives Policy (SNAP) program to encourage private sector investment in low-emissions technology by identifying and approving climate-friendly chemicals, while prohibiting certain uses of the most harmful chemical alternatives [such as HFCs].” The EPA has made progress on this directive by permitting use of several new climate-friendly HFC alternatives on the U.S. market as acceptable in a recently published rulemaking. The dual approach being taken by the EPA to open up the U.S. market to low-GWP alternatives, while simultaneously prohibiting high-GWP HFCs in new equipment and products, is an effective strategy for transitioning the U.S. market.
If complaints from laggard U.S. companies—who are trying to profit as long as they can from selling and using climate destroying chemicals—undermine the path the EPA has mapped to transition away from HFCs, they will not only hinder global efforts to phase-down HFCs but also impede U.S. industry’s ability to lead in the transition to low-GWP technologies. Support the EPA and progressive companies in the United States by urging the EPA to adopt the strongest possible regulations to eliminate high-GWP HFCs.
Take action by sending a comment supporting robust and ambitious regulations on controlling high-GWP HFCs to EPA Administrator Gina McCarthy and the EPA’s Office of Atmospheric Programs.