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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 CO 2 . EU regulations on CO 2 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: 1 st step: Control direct emissions of MVAC s >150 GWP:

- mandatory

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

- mandatory

as of Jun 21, 2009 (all new vehicles) 2 nd step: Prohibition of F - gases > 150 GWP

- Starting Jan 2011 (new ty pes 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 CO 2 emission s

- Emissions <= 130 g/km CO 2 (powertrain improvements)

- Addition of 10g/km CO 2 (other tech improvements)2

Thus, to reduce CO 2 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

- In centive reduction of emissions from MVAC

- Insulation technologies Draft for MVAC test procedure is anticipated on August 2010

.................................... .............................................................................. EPA Ann Arbor Indirect Energy Consumption Developments Presenter: Brian Nelson, U.S. Environmental Protection Agency EPA issued a final rul e, 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 NHT S A is to guide toward GHG emission reduction and the approval of “GHG cre dits”. 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

- Ty pe of MVAC refrigerant used

- Other technologies that reduc e 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).3

GHG emission, measured as CO2, of 14.9 g/min or less may b e eligible to receive credit. Starting with 2009 - 2011 ye ar models, manufacturers may b e eligible to receive “earl y” 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).

....................................................................................... ............ 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 o f the A/C system

- MVAC servicing (topping of a leaky s ystem, 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 model s 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.4

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/y r

- 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 currentl y being requested. Inaddition, CARB is looking forward to address other MVAC system improvements, including adequate lubricants. CARB believes a 9g/y r 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.

....................................................................................... Q & A session for the first 3 Presentations : Q: I s 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 standard s 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)5

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 primaril y on emissions due to leakage. Other ty pes 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: I s 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 w as developed by OAP based on the approximate amount of losses from vehicles. EPA referred to the Vintanging model. Other anal ys es and assumptions were obtained from studies from NRELand standards. Q: SAE J2727 standard addresses ty pe of compressor energy p enalty due to different ty pe of A/C, and system emissions, How has this been addressed in the regulations? A (EU Commission Rep.): I ssue 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 s ystem efficiency)” Q: What is the emission rate technology? A (EPA) : See EPA final rule on GHG cre dits. SAE J2727 standard is one of the main base s for this.

............................................................................................................... ...... OEM Evaluation of MAC 1 Fuel 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 o f efficiency

m easures for the MVAC industry . Attention was brought toward the need of express results whether in fuel consumption (thus engine efficiency

regarding MVAC fuel consumpti on) or MVAC technical efficiency itself.
1 MAC (Mobile air conditioner) = MVAC (Motor vehicle air conditioner)6

Q & A Session : Q: What is the A/C consumption? A: Number of energy

c onsumption may

b e 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.

.............................. ................................................................................. 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 dy namic simulator are options to evaluate energy consumption, reflected as fuel consumption from the use of A/C systems in vehicles. However, great variability

exis st due the significant amount of existing driving patterns and conditions.

.............................. ...... .............................................................................. HFO - 1234yf – Safety When Exposed to Ignition Sources Presenters: Kai Holtappels, Volkmar Schroder, BAM ; Gabrielle Hoffman, Wolfgang Plehn, UBA UB A 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.7

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 analys es 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 analys is of HF formation? A: D etails of the analysis will be published on their website (UBA’s).

......................................................................................................... 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 CO 2 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 CO 2 and HFO 1234yf 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 cross contamination 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 b e cheaper than HFO - 1234yf and there are no current industry standards for control and safety o f these blends. What would be EPA’s actions for that? A: Based on EPA regulations SNAP is not currentl y mandating the use of any p articular 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 “SNAP approved” 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 currentl y 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

S tandards 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

f ound 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 1 5, 2010, on a subsequent ICCC meeting. Af ter 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

– Lab eling 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 HFO 1225ye which is considered c onsiderabl y 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 c oncentration and concerns remains on toxicity o f HFO - 1225ye. Manuf acturers agreed to performs further reviews before making a final decision.10

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 L ab (NREL) Research on MVACs Presenter: John P. Rugh Res earch was done on e ffective pass enger cabin cooling , anal yz ing several factors including ambient temperatures and humidity, A/C operation (hi gh , 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). NRELstudies shows glazed windows help reduce 5.5% (KW) MVAC load in the vehicle. Furthermo re, a 4.5gCO2/mi reduction could be achieved with the use of this technology. Further studies may include cooling performance anal ys is when vehicle ignition on and off. EPA’s GHG E missions and CAFE S tandards Presenter: Brian Nelson EPA’s final rule “ Li ght - Duty Vehicle Green House Gas Emission Standards and Corporate Average Fuel Economy Standards ” regulates direct and indirect emissions. Based on SAE I MAC team 2 studies, a 50% reduction of refrigerant leakage can be attained. EPA used 50% leakage reducti on 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. Indire ct 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 b e obtained from EPA’s final rule (75 FR 25324).11

CARB’s Indirect Emissi ons 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 9.0 g/yr CO2 equivalent, it may b ecome 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 CRUI SE model and other anal ytic tools.

............................................................................................. 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 previousl y). The new dimensions are unique and will help avoid MVAC system cross - contamination and other safety issues. Members agre ed 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 (specificall y 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 e ffectively . OEMs and regulators (EPA and CARB) agreed to organize periodic meetings (bi - monthly) to discuss technology and regulatory approaches to asses s MVAC and overall vehicle power train efficiency . OEMs recognized that MVAC efficiency

and GHG reduction may not only b e attained by

the ty pe of refrigerant used but on complex factors such as MVAC system and vehicle components, driving patterns, and ambient factors.