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July 13, 2010 meeting notes

I. International Regulatory Issues 

EU Regulation Overview

Presenter: Klaus Steininger, European Commission

The presentation focused on main regulatory requirements for green house gas (GHG) emission 

control and reduction, measured in terms of CO2.

EU regulations on CO2 have 3 main legal actions:

1- Directive 2006/40/EC  MVAC emissions

2- 2007/40/EC  administrative

3- 2007/37/EC  amendments

EU regulatory actions are applied on a step-wise base:

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st step: 

Control direct emissions of MVACs >150 GWP:

- mandatory as of Jun 21, 2008 (new types of vehicles)

- mandatory as of Jun 21, 2009 (all new vehicles)

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nd step: 

Prohibition of F-gases > 150 GWP

- Starting Jan 2011 (new types of vehicles)

- 2017 (all new vehicles)

Part of the EU regulations on GHG includes:

EC/848/2006

- F-gases not critical, no disproportionate costs

EC/307/2008

- Appropriate qualification of personnel 

Regulations under the European Commission also includes requirements to report CO2 emissions

- Emissions <= 130 g/km CO2 (powertrain improvements)

- Addition of 10g/km CO2 (other tech improvements)
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Thus, to reduce CO2 emissions and achieve EU requirements the following has to be addressed:

- Efficiency improvements on MVAC system

- Fuel efficiency (driving patterns studies)

- Pressure monitoring on A/C system

- Gear shift indicators

For a total of 140g/km of CO2 emissions, it is necessary to attain a reduction of 10g/km

MVAC indirect emissions – test procedures, must consider:

- Cost effectiveness

- Incentive reduction of emissions from MVAC

- Insulation technologies

Draft for MVAC test procedure is anticipated on August 2010

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EPA Ann Arbor Indirect Energy Consumption Developments

Presenter: Brian Nelson, U.S. Environmental Protection Agency

EPA issued a final rule, Light Duty Vehicle Green House Gas Emission Standards and Corporate 

Average Fuel Economy Standards. The main focus of final rulemaking issued by EPA-OTAQ 

with join efforts from NHTSA is to guide toward GHG emission reduction and the approval of 

“GHG credits”. MVAC systems are considered part of GHG emissions from vehicles, thus the 

presentation had particularly focus on A/C credits. 

A/C Credits are evaluated according to:

- MVAC system efficiency

- Type of MVAC refrigerant used

- Other technologies that reduce GHG*

*Other types of credits include: “off-cycle credit”, which is not captured in an existing test cycle. 

However, manufacturers must justify this credit. 

Efficiency credits are evaluated using two methods:

- 1. “Menu” method, which is a table offered on the final rule – manufactures must 

follow this method only for 2012-2013 automobile models.

- 2. “A/C idle test” method, which is used to measure incremental CO2 due to A/C use 

- manufacturers must follow this method for 2014 – 2016 automobile models only

(for these models an adjustment factor must be applied).
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GHG emission, measured as CO2, of 14.9 g/min or less may be eligible to receive credit. 

Starting with 2009-2011 year models, manufacturers may be eligible to receive “early” A/C 

credits if these attain with the minimum A/C emission rate (see final rule for more details, 75 FR 

32324).

The method to evaluate and determine refrigerant emissions from the MVAC system is applied 

referencing the SAE J2727 standard (as of 2008).

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Update on California’s Regulatory Efforts to Reduce Greenhouse Gas Emissions from 

Mobile Air Conditioning

Presenter: Tao Zhan and Leela Rao, California Air Resources Board

MVAC refrigerant emissions are being determined using mass balance:

Refrigerant introduction (into MVAC system):

- Initial OEM charge

- Recharge/ servicing

Refrigerant emission (out to the environment):

- Leakage 

- Accidental break of the A/C system

- MVAC servicing (topping of a leaky system, unintentional venting)

- End-of –life (recyclers/salvage yards) activities

- Containment heel

CARB’s regulatory evolution:

- CA-AB 1493 (PAVLEY)

o Standard to be applied on 2009-2012 automobile models

o MVAC improvement can earn credits for GHG emissions

- LEV III

o Mandatory standard to be applied on automobile models starting 2017

o The use of low GWP refrigerants are required

o Low leak rates on MVAC systems

o Indirect emissions limit

These regulations are intended to complement EPA regulations on GHG credits. CARB expect 

their standard align with federal regulatory activities. 
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LEV III requirements are as follows:

- MVAC refrigerants must have a GWP equal or lower than 150

- MVAC systems must have a 90% reduction of direct emissions

o Average leak rate must be equal or lower than 9g/yr

- OEMs can choose from 3 SNAP refrigerants: HCF-152a, CO2, or HFO-1234yf 

- Indirect emissions standard

o CARB is proposing to develop a fleet average MVAC indirect emission 

standard

o Evaluation through a whole-vehicle performance test procedure (under 

development)

o CARB is evaluating leak rates on MVAC systems using SAE 2727 standard 

o Initial adoption using EPA’s final rule on GHG credit

o However, proposed test procedure adds into consideration solar load, 

moderate annual loading, and A/C during initial cooling and steady-state 

temperature control.

CARB regulatory activities are intended for long term MVAC performance and consumer 

protection. Also main focus is being directed to MVAC efficiency improvement. Comments are 

currently being requested. In addition, CARB is looking forward to address other MVAC system 

improvements, including adequate lubricants. CARB believes a 9g/yr MVAC GHG emission 

rate is achievable and a 18g/yr per USEPA, 50% of goal reduction is feasible.

CARB expressed the need to develop new standards in the US if EU switches to HFO-1234yf.

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Q & A session for the first 3 Presentations:

Q: Is CARB aware of EU direct/indirect emission restrictions?

A (CARB rep.): Yes. CARB is currently determining feasibility of tests and proposed standards. 

A (EU Commission rep.): EU regulations proposed minimum requirements (see presentation and 

EU rulemaking for further information).

Q: What are the plans for enforcement for CARB’s standards

A (CARB rep.): Right now CARB is working on developing standards, Enforcement will be 

determined once the standards are published. 

Q: How will the SNAP approved refrigerants affect efforts to implement low GWP refrigerants?

A (EPA rep.): More information about SNAP is covered during the afternoon session. (see 

afternoon session meeting notes)
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Q: What is being approved regarding highway (heavy duty) equipment?

A (EPA rep.): The current regulatory actions are being focused on light vehicles (i.e., cars, 

SUV’s and light duty vehicles) and primarily on emissions due to leakage. Other types of 

vehicles are targeted for the future.

A (EU Commission rep.): Several mobile air requirements for off-road vehicles are being 

verified. However, regulation for these vehicles may be applied on future regulations. 

Q: Is 1/3 of the overall GHG credit issued for indirect emissions? What is the base to determine 

those emissions?

A (EPA): 13.6g/yr of CO2 based on indirect emissions or 70.6% efficiency improvement of the 

MVAC system could attain the requirements for credits. A leakage inventory was developed by

OAP based on the approximate amount of losses from vehicles. EPA referred to the Vintanging 

model. Other analyses and assumptions were obtained from studies from NREL and standards. 

Q: SAE J2727 standard addresses type of compressor energy penalty due to different type of 

A/C, and system emissions, How has this been addressed in the regulations?

A (EU Commission Rep.): Issue is going to be taken into account.

A: (W. Atkinson, SAE): “If we have control of the refrigerant leakage, e.g. 15g/yr, and in the 

past it was common to recharge the A/C every 90 days, we have measured the efficiency and had 

tried to reduce refrigerant indirect emissions (due to increase of system efficiency)”

Q: What is the emission rate technology?

A (EPA): See EPA final rule on GHG credits. SAE J2727 standard is one of the main bases for 

this.

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OEM Evaluation of MAC1Fuel Consumption by Physical Testing. Comparison of Test 

Benches, Engine Types and MAC Technologies

Presenters: Bruno Rose, PSA; Enrique Peral, Renault

The purpose of the research was to find consistency of efficiency measures for the MVAC

industry. Attention was brought toward the need of express results whether in fuel consumption 

(thus engine efficiency regarding MVAC fuel consumption) or MVAC technical efficiency itself.

 

1 MAC (Mobile air conditioner) = MVAC (Motor vehicle air conditioner)
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Q & A Session:

Q: What is the A/C consumption?

A: Number of energy consumption may be dependent on temperature. If different compressor 

systems are used, with different maximum loads, measurements are going to be different.

Q: What assumptions were used in the study?

A: Constant load on the A/C

Q: Did the study considered different solar load technologies?

A: Not enough tests have been done on that field.

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Quantificational Analysis of Automotive AC Fuel Consumption on EPA Drive Cycles

Presenter: Kelvin Zhai, 

Studies on MVAC systems done in NREL facilities have found that running electrical 

accessories in the automobile reduces fuel economy.by 5-25%

Modeling technologies such as A/C dynamic simulator are options to evaluate energy

consumption, reflected as fuel consumption from the use of A/C systems in vehicles. However, 

great variability exisst due the significant amount of existing driving patterns and conditions.

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HFO-1234yf – Safety When Exposed to Ignition Sources

Presenters: Kai Holtappels, Volkmar Schroder, BAM; Gabrielle Hoffman, Wolfgang Plehn, 

UBA

UBA presented a study (including a video) of ignition inside the passenger compartment when 

“enough” concentrations of HFO-1234yf (900g) and ethane are released into the passenger 

compartment and an ignition source such as a spark is present. The researchers presented 

concerns on HF formation since concentrations surpassed 90 ppm inside the passenger 

compartment. However, the presenter did not say what was the exact concentration and duration. 
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The presenter reiterated that preventive measures regarding HF and flammability are necessary 

but recognized that flammability is not a barrier for HFO-1234yf use on MVAC systems. 

The presenter recognized that HF concentrations above 90 ppm also resulted from HFC-134a 

thermal decomposition. Results did not show the exact concentration.

Q & A session:

Q: Was a Fault Tree Analysis conducted in the study?

A: No fault tree analyses were conducted. 

Q: What was amount of energy released to cause the fire? Were combustible materials identified 

inside the passenger compartment (e.g., textiles)?

A: Amount of energy was not measured during the study. Seat material was not taken into 

consideration.

Q: What is the computation analysis of HF formation?

A: Details of the analysis will be published on their website (UBA’s).

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Review of SAE CRP 1234 Results

Presenter: William Hill

The presentation focused on results of the CRP 1234 risk analyses regarding HFO-1234yf 

toxicity, flammability, and HF, in addition to risks assessments on CO2 refrigerant (For more 

information, the CRP1234 is on EPA’s SNAP rule docket: EPA-HQ-OAR-2008-0644).

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II. ICCC Standards Meeting

Regulatory Updates on Alternative Refrigerants for MVACs

Presenter: Yaidi Cancel, U.S. Environmental Protection Agency

A review on SNAP regulatory actions and current status of EPA rulemaking for CO2 and HFO1234yf refrigerants were presented.

*For further details, please find the presentation on SNAP Rule docket (EPA-HQ-OAR-2008-

0644)

Q & A Session:

Q: Various concerns exist regarding the current SNAP list finding acceptable numerous 

refrigerants that do not have appropriate/approved servicing equipment. What is EPA going to do 

about that?

A: Under current regulations EPA requires the use of unique fittings and labels to avoid crosscontamination of MVAC systems. Also, EPA provides on the regulations requirements for the 

approval of equipment to extract refrigerants, acceptable under SNAP, other than CFC-12 and 

HFC-134a. EPA prohibits intentional venting of any refrigerant. 

Q: The industry understands there are refrigerants (blends) on the market that may be cheaper 

than HFO-1234yf and there are no current industry standards for control and safety of these 

blends. What would be EPA’s actions for that?

A: Based on EPA regulations SNAP is not currently mandating the use of any particular 

refrigerant but offers alternatives to be used under certain specifications described by the 

regulations. When EPA receives a submission under the SNAP program, the agency reviews 

risks on environment and human health prior finding acceptable any refrigerant.

Note: The inquirers expressed concerns of venting due to the lack of control of “SNAPapproved” refrigerant blends in the market since many are accessible to untrained consumers that 

tend to service the MVAC system inappropriately and end up venting the refrigerant into the 

atmosphere because service equipment for most blends are currently unavailable or inaccessible. 

Q: EPA received a petition to “un-SNAP” (remove from the SNAP list) HFC-134a. What is 

being done about that?

A: EPA is currently reviewing the petition and will issue a response as soon as the revision 

process ends. EPA understands it has 90 days to respond after the petition is received. 

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ICCC Meeting

During the meeting attention was brought on the standards with technical issues pending to 

solve. Some of the standards discussed were:

- SAE J639, Safety Standards for motor Vehicle Refrigerant Vapor Compression 

Systems

- SAE J2727, HCF-134a Mobile Air Conditioning System Refrigerant Emission Chart

- SAE J2844, R-1234yf New Refrigerant Purity and Container requirements Used in 

Mobile Air Conditioning Systems 

SAE J639 – Fittings and labeling issues

The industry found issues regarding the similitude of HFC-134a fittings and HFO-1234yf that 

could lead to possible cross-contamination of MVAC systems. 

Labeling issues were discussed as well. Further review of fitting dimensions and labeling color 

was considered and final agreements were going to be presented on Thursday, July 15, 2010, on 

a subsequent ICCC meeting. After revisions and agreements are done, the standards are sent into 

“ballots” where industry members vote to accept or decline the decisions adopted during the 

ICCC meeting. 

SAE J2727 – Under revision

OTAQ’s rule regarding GHG limits on vehicles makes references of a previous version of this 

standard. The Agency may use this standard to issue further regulations on emissions. 

SAE J 2844 – Labeling requirements on containers

ICCC member discussed whether to include a detailed label, describing compliance with the 

standard. Issues were discussed regarding confusion with DOT’s labeling system.

SAE J2844 – HFO-1234yf refrigerant purity issue

Concerns were raised about inconsistent concentrations of “trace impurities” containing HFO1225ye which is considered considerably toxic. Manufacturers discussed issues regarding what 

may be the “safe” concentration of this trace impurity (40 ppm, 70 ppm, or 150 ppm). Consensus 

was not attained on impurity concentration and concerns remains on toxicity of HFO-1225ye. 

Manufacturers agreed to performs further reviews before making a final decision. 
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July 14, 2010 meeting notes

MAC Indirect Emission Workshop

Mobile Air Conditioning Test Development Procedures

Presenter: Klaus Steininger, European Commission

EU commission representative presented an overview on test procedures and conditions to 

develop standards for MVACs. Procedures focused on fuel consumption and overall system 

efficiency. 

National Renewable Energy Lab (NREL) Research on MVACs

Presenter: John P. Rugh

Research was done on effective passenger cabin cooling, analyzing several factors including 

ambient temperatures and humidity, A/C operation (high, low), vehicle operation and driving 

patterns, fuel consumption and solar load. The study assumed the highest load during the first 

minutes of driving, while the A/C is on and steady state conditions while the vehicle was driven 

at constant-like pattern (e.g., highway driving). NREL studies shows glazed windows help 

reduce 5.5% (KW) MVAC load in the vehicle. Furthermore, a 4.5gCO2/mi reduction could be 

achieved with the use of this technology. Further studies may include cooling performance 

analysis when vehicle ignition on and off. 

EPA’s GHG Emissions and CAFE Standards

Presenter: Brian Nelson

EPA’s final rule “Light-Duty Vehicle Green House Gas Emission Standards and Corporate 

Average Fuel Economy Standards” regulates direct and indirect emissions. Based on SAE IMAC team 2 studies, a 50% reduction of refrigerant leakage can be attained. EPA used 50% 

leakage reduction to establish maximum direct credit for vehicles. Higher credits could be 

achieved when sealed electric compressor technologies and/or low GWP refrigerants are used. 

As described in the final rule, CO2 impact due to indirect emissions is 14.9g/mi. Indirect 

emissions can be calculated using the table indicating indirect emission values for certain 

components. Further details on how to determine direct and indirect emission credits may be 

obtained from EPA’s final rule (75 FR 25324).
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CARB’s Indirect Emissions Standards

Presenter: Leela Rao, Ph..D.

The state of California is proposing to issue credits based on “PAVLEY – AB 1493”. If a MVAC 

industry meets all the criteria of a system with reduced emissions of 9.0g/yr CO2 equivalent, it 

may become eligible to obtain CARB’s credits. Methods used to determine CARB’s emissions 

credits includes modeled results presented in NESCCAF (2004), vehicle simulation modeling 

using CRUISE model and other analytic tools. 

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July 15, 2010 meeting notes

ICCC Meeting Conclusions and OEM/Regulator Discussion on Indirect MAC 

Emissions Workshop

ICCC Meeting Conclusions 

ICCC members reviewed issues with SAE J standards 639 and 2844 since those presented the 

most concerns. Members agreed to change the dimensions of the high-pressure side fitting to 

avoid misuse with HFC-134a fittings (since both fitting showed compatibility previously). The 

new dimensions are unique and will help avoid MVAC system cross-contamination and other 

safety issues. Members agreed to continue reviewing alternatives to address refrigerant purity as 

per SAE J2844. Both standards will go to ballot after further agreements within members are 

done (specifically on SAE J2844). Since SAE J639 covers as a summary all MVAC related SAE 

standards. Its finalization depends on total consensus for all other standards. 

OEM/Regulator Discussion on Indirect MAC Emissions Workshop

This meeting focused mainly on fuel efficiency regarding MVAC use. European and US 

industry, research and regulatory sectors are searching for consistent testing methods to evaluate 

fuel consumption and MVAC system efficiency effectively. OEMs and regulators (EPA and 

CARB) agreed to organize periodic meetings (bi-monthly) to discuss technology and regulatory

approaches to assess MVAC and overall vehicle power train efficiency. OEMs recognized that 

MVAC efficiency and GHG reduction may not only be attained by the type of refrigerant used 

but on complex factors such as MVAC system and vehicle components, driving patterns, and 

ambient factors.