Rebecca von dem HagenAlternatives and Emissions Reduction BranchOffice of Atmospheric ProgramsU.S. Environmental Protection AgencyEPA Update on Proposed SNAP Regulationsand Section 609SAE International Thermal Management Systems SymposiumDenver, ColoradoSeptember 22-24, 2014Clean Air Act Title VI Regulations on MotorVehicle Air Conditioners (MVAC)Section 612: Significant New Alternatives Policy (SNAP) ProgramSNAP evaluates and lists substitutes thatreduce overall risk to human health &the environment in various sectorsconsidering: ozone-depletion potential,global warming potential,flammability, toxicity, local air quality, ecosystemeffects, occupational & consumer health/safetyLists substitutes as acceptable, acceptable subject to use conditioners or unacceptableSection 609: Servicing of Motor Vehicle Air ConditionersRequires technician certification & use of approved servicing equipmentSection 608: Recyling and Emissions ReductionsProhibits intentional release (venting) of any refrigerant, unless specifically exempted2MVAC Refrigerant TransitionHFC-134a most common MVAC refrigerant since 1990sThree climate-friendly MVAC substitutes are currently listed as acceptablesubject to use conditions under SNAPCars using HFO-1234yf on the road todayAdditional substitutes being consideredEnvironmental Impacts of MVAC RefrigerantsGlobal WarmingPotentialOzone Depleting?CFC-1210,900 YesHFC-134a1,430 NoHFC-152a124 NoHFO-1234yf4 NoCO2(R-744)1 No3President Obama’s Climate Action PlanDirects EPA to Take Action on HFCsReleased June 2013Continue International Diplomacy on HFCsLead negotiations under the Montreal Protocol to phase down HFCsGlobal phase down could reduce over 90 gigatons of CO2eq by2050, equal to roughly two years worth of current global GHG emissionsWork with partners in theClimate and Clean Air Coalition to Reduce ShortLived Climate Pollutantsto promote climate-friendly alternatives to highGWP HFCs, address technical standards, and reduce emissions from HFC useAddress HFCs through Domestic ActionsUse existing Clean Air Act authority ofSignificant New Alternatives Policy(SNAP) Programto approve climate-friendly chemicals, prohibit some uses ofmost harmful•Provide federal leadership bypurchasing cleaneralternatives to HFCswhenever feasible and bytransitioning to equipment using safe, moresustainable alternatives4Why are HFCs a Concern?HFCs are synthetic fluorinated greenhouse gases (GHGs)Use and emissions of HFCs are growing rapidly, because they are replacementfor ozone-depleting substances (ODS) being phased out under the MontrealProtocolGlobally, 2004 to 2008 emissionsincreased by about 8% per year;left unchecked, emissions couldrise to nearly 20% of totalcarbon dioxide emissions by2050In the U.S., emissions of HFCsare expected to double fromcurrent levels of 1.5 percent ofgreenhouse gas emissions to 3percent by 2020 and triple by2030UNEP 20115Actions Being Taken under SNAP inResponseEPA Took Immediate Steps to EvaluateOpportunities/Develop Proposed RulemakingsSought deeper understanding of the range of alternatives,ongoing transitions, where & why options are limited, and moreEngaged with stakeholders:Held two large stakeholder meetings to discuss initial thinkingHeld seven sector-specific workshopsHeld numerous other meetings with individual stakeholdersEvaluated the potential benefits of various optionsDeveloped two proposed rules under EPA’s SNAP program:First proposes to expand the list of acceptable alternativesSecond proposes to find certain HFCs unacceptable for specific end uses7Lower-GWP Refrigerants Proposed RuleRefrigerant GWPEnd Use and Application

Household Refrigerators Retail refrigerator stand-alone Vending Very Low Temp Ref Heat Transfer Home ACSelf-containedEthane 6 

#  Iso-butane 8 

#  Propane 3 

#  R-441A (HC blend) <5 

#  HFC-32 675 

# SNAP continues to add new climate-friendly optionsThese flammable refrigerants were recently proposed as acceptable with use conditionsthat adopt safety standardsPublished July 9, 2014 (79 FR 38811); comment period closed Sept. 88Proposed Status Change RuleProposed rule published on August 6, 2014Comment period extended 14 days to October 20, 2014Available at 79 FR 46126 or at regulations.gov in docket EPA-HQ-OAR-2014-0198Proposes certain HFCs unacceptable for specific end-uses with compliance datesstarting over the next few yearsIncludes aerosols, foams, MVAC, and commercial refrigerationRelied on same SNAP principles we have used for past 20 years:SNAP rules consider individual end-usesNo across the board GWP cut offsNo prohibition on HFCs as a whole, or in any one sectorNew HFCs or blends (e.g., HFC/HFO blends) may be listed for an end use if risk notgreater than other available substitutesRecognize timing is a critical dimension and that each end use has unique considerationsProposal seeks comments on technical challenges such as availability of alternatives,need for changes to manufacturing processes, safety upgrades and the ability tomeet the proposed compliance dates9Sector or End-UseProposed DateProposed Changes to SNAP Listings for CertainHFCsMotor vehicle A/CModel year 2021HFC-134a unacceptableSupermarket systems: remote condensingunits, new (and retrofits from ODS)January 2016Certain HFCs unacceptable:R-404A, R-507AAlso HFC-227ea, R-407B, R-421B, R-422A, R422C, R-422D, R-428A, R-434AStand-alone retail foodrefrigeration, vendingmachines: newJanuary 2016Certain HFCs unacceptable:HFC-134a, R-404AR-407A, R-407C, R-507ASeveral other HFC blendsStand-alone retail food refrigeration,vending machines: retrofits from ODSJanuary 2016Certain HFCs unacceptable:R-404A and R-507AFoamsJanuary 2017HFC-134a and blends thereof unacceptableHFC-245fa and HFC-365mfc and HFC blendsunacceptable except for spray foam applicationsAerosolsJanuary 2016HFC-134a unacceptable exceptfor some technical andmedical aerosols including MDIsHFC-125, -227ea (except MDIs) unacceptable10Proposed Status Change Rule:MVACProposed Status Change Rule: MVACProposing to find HFC-134aunacceptableAs of MY 2021New vehicles onlyProposing to find several HCFC refrigerant blendsunacceptableSP34E, R-426A (aka RS-24), R-416A (aka HCFC Blend Beta orFRIGC FR12), R-406A, R-414A (aka HCFC Blend Xi or GHG-X4),R-414B (aka HCFC Blend Omicron), HCFC Blend Delta (aka FreeZone), Freeze 12, GHG-X5, and HCFC Blend Lambda (aka GHG-HP)As of MY 2017New vehicles only12Proposed Status Change Rule: MVACImports & exportsServicing of existing vehiclesProposed rule does not affect ability to service existing vehiclesdesigned to use HFC-134aEPA seeking commentImpact on Credits under Light-Duty Greenhouse Gas (GHG) RuleThe proposed SNAP rule will not change credits available under theLight-Duty GHG Rule13Estimated U.S. Emissions Reductions14Near-term changes canprovide both near- andLong-term benefitsAvoided emissions fromproposal estimated31-42 MMTCO2eq in 2020Internal and DeliberativeNext Steps for SNAP RegulationsDevelop final regulationsLow GWP Refrigerants RulePublic comment period closed September 8, 2014Status Change RulePublic comment period closes October 20, 2014Continue to consider the SNAP listAdditional alternatives under evaluationNotices and proposed rulesThese rules should be seen as part of the seriesContinue to engage with stakeholders15Other HFC ActivitiesNational & International Efforts on HFCsU.S. pursuing HFC Phasedown Amendment to the Montreal ProtocolJoint proposal by Canada, Mexico and the United StatesPhase DOWN, not OUTFor consideration at Montreal Protocol Meeting of the Parties (17-21November 2014, Paris)White House event September 16Industry and government announced commitments to curb HFC emissionsG7 Summit statement, June 5, 2014:“We will work together and with others to phase down the production andconsumption of hydrofluorocarbons (HFC) under the Montreal Protocol. Wewill also continue to take action to promote the rapid deployment of climatefriendly and safe alternatives in motor vehicle air-conditioning and we willpromote public procurement of climate-friendly HFC alternatives.”UN Climate Summit September 23, 201417Other MVAC ActivitiesOther MVAC ActivitiesUpdate to Section 609 Technician Certification and TrainingProgramsGoal: Prepare technicians entering the industry today for variety ofMVAC refrigerants; shift focus away from CFC-12Website UpdatesIncrease awareness of alternative refrigerantsReworking information on CFC-12 servicing and retrofitsJust the Facts for MVACs:http://www.epa.gov/ozone/title6/609/justfax.htmlMVAC Refrigerant Transition & Environmental Impacts:http://www.epa.gov/ozone/title6/609/transition.html19Other MVAC ActivitiesPlan to Incorporate by Reference (IBR) new SAE standards forrecovery, and recovery/recycle equipment through rulemakingSAE J2843 R-1234yf Recovery/Recycling/ Recharging Equipment forFlammable Refrigerants for Mobile Air-Conditioning SystemsSAE J2851 Recovery Equipment for Contaminated Refrigerant FromMobile Automotive Air Conditioning SystemsSAE J3030 Automotive Refrigerant Recovery/Recycling EquipmentIntended for Use with Multiple Refrigerants20Contact Information:Rebecca von dem Hagenvondemhagen.rebecca@epa.gov(202) 343-9445Thank You!