Rebecca von dem Hagen

Alternatives and Emissions Reduction BranchOffice of Atmospheric ProgramsU.S. Environmental Protection Agency

EPA Update on Proposed SNAP Regu

and Section 609

SAE International Thermal Management Systems Sympos

Denver, Colorado 

September 22-24, 2014
Clean Air Act Title VI Regulations on 

Vehicle Air Conditioners (MVAC

 Section 612: Significant New Alternatives Policy (SNAP) Program

 SNAP evaluates and lists substitutes that

reduce overall risk to human health & 

the environment in various sectors considering: ozone-depletion potential, global warming potential, flammability, toxicity, local air quality, ecoeffects, occupational & consumer health/safety

 Lists substitutes as acceptable, acceptable subject to use conditioners or u

 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 specificall

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MVAC Refrigerant Transition

 HFC-134a most common MVAC refrigerant since 1990s Three climate-friendly MVAC substitutes are currently listed as acce

subject to use conditions under SNAP

 Cars using HFO-1234yf on the road today Additional substitutes being considered

Environmental Impacts of MVAC Refrigerants

Global Warming

Potential

Ozone Depleti

CFC-12 10,900 YesHFC-134a 1,430 NoHFC-152a 124 NoHFO-1234yf 4 NoCO2 (R-744) 1 No

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President Obama’s Climate Action 

Directs EPA to Take Action on HF

 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 by 

2050, equal to roughly two years worth of current global GHG emis

 Work with partners in the Climate and Clean Air Coalition to Reduc

Lived Climate Pollutants to promote climate-friendly alternatives to hGWP HFCs, address technical standards, and reduce emissions from HF

 Address HFCs through Domestic Actions

 Use existing Clean Air Act authority of Significant New Alternatives P

(SNAP) Program to approve climate-friendly chemicals, prohibit some most harmful

• Provide federal leadership by purchasing cleaner 

alternatives to HFCs whenever feasible and by transitioning to equipment using safe, more sustainable alternatives

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Why are HFCs a Concern?

 HFCs are synthetic fluorinated greenhouse gases (GHGs)  Use and emissions of HFCs are growing rapidly, because they are 

for ozone-depleting substances (ODS) being phased out under thProtocol

 Globally, 2004 to 2008 emissions 

increased by about 8% per year; left unchecked, emissions could rise to nearly 20% of total carbon dioxide emissions by 2050

 In the U.S., emissions of HFCs 

are expected to double from current levels of 1.5 percent of greenhouse gas emissions to 3 percent by 2020 and triple by 2030 

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Actions Being Taken under SNA

Response
EPA Took Immediate Steps to Evalua

Opportunities/Develop Proposed Rulem

 Sought deeper understanding of the range of alternat

ongoing transitions, where & why options are limited

 Engaged with stakeholders:

 Held two large stakeholder meetings to discuss initial thinki Held seven sector-specific workshops  Held numerous other meetings with individual stakeholder

 Evaluated the potential benefits of various options Developed two proposed rules under EPA’s SNAP pr

 First proposes to expand the list of acceptable alternatives Second proposes to find certain HFCs unacceptable for spec

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Lower-GWP Refrigerants Proposed R

Refrigerant GWP

End Use and Application 

Household 

Refrigerators

Retail

refrigerator 

stand-alone

Vending

Very Low Temp 

Ref

Heat Transfer

Ethane 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 

that adopt safety standards

 Published July 9, 2014 (79 FR 38811); comment period closed Sept. 8 

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Proposed 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

 Proposes certain HFCs unacceptable for specific end-uses with comp

starting 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 

greater than other available substitutes 

 Recognize timing is a critical dimension and that each end use has uniqu

 Proposal seeks comments on technical challenges such as availability 

need for changes to manufacturing processes, safety upgrades and thmeet the proposed compliance dates 

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Sector or End-Use

Proposed Date

Proposed Changes to SNAP Listin

HFCs

Motor vehicle A/CModel year 2021

 HFC-134a unacceptable 

Supermarket systems: remote condensing units, new (and retrofits from ODS)

January 2016

 Certain HFCs unacceptable: 

 R-404A, R-507A Also HFC-227ea, R-407B, R-421B

422C, R-422D, R-428A, R-434A

Stand-alone retail food refrigeration, vending 

machines: new

January 2016

 Certain HFCs unacceptable:

 HFC-134a, R-404A R-407A, R-407C, R-507A Several other HFC blends

Stand-alone retail food refrigeration, vending machines: retrofits from ODS

January 2016

 Certain HFCs unacceptable: 

 R-404A and R-507A

FoamsJanuary 2017

 HFC-134a and blends thereof unaccept HFC-245fa and HFC-365mfc and HFC 

unacceptable except for spray foam appli

AerosolsJanuary 2016

 HFC-134a unacceptable except for som

medical aerosols including MDIs 

 HFC-125, -227ea (except MDIs) unacc

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Proposed Status Change Ru

MVAC 
Proposed Status Change Rule: MV

 Proposing to find HFC-134a unacceptable 

 As of MY 2021 New vehicles only 

 Proposing to find several HCFC refrigerant blends unaccep

 SP34E, R-426A (aka RS-24), R-416A (aka HCFC Blend Bet

FRIGC FR12), R-406A, R-414A (aka HCFC Blend Xi or GHR-414B (aka HCFC Blend Omicron), HCFC Blend Delta (aZone), Freeze 12, GHG-X5, and HCFC Blend Lambda (aka 

 As of MY 2017 New vehicles only

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Proposed Status Change Rule: MV

 Imports & exports Servicing of existing vehicles

 Proposed rule does not affect ability to service existing vehi

designed to use HFC-134a

 EPA seeking comment

Impact on Credits under Light-Duty Greenhouse Gas (GHG

 The proposed SNAP rule will not change credits available 

Light-Duty GHG Rule

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Estimated U.S. Emissions Reduct

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Near-term changeprovide both near- Long-term benefit

Avoided emissions from proposal estimated 31-42 MMTCO

2eq in 2020

Internal and Deliberative
Next 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 stakeholders

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Other HFC Activities
National & International Efforts on 

 U.S. pursuing HFC Phasedown Amendment to the Montreal P

 Joint proposal by Canada, Mexico and the United States Phase DOWN, not OUT For consideration at Montreal Protocol Meeting of the Parties (17

November 2014, Paris)

 White House event September 16

 Industry and government announced commitments to curb HFC 

 G7 Summit statement, June 5, 2014: 

 “We will work together and with others to phase down the produ

consumption of hydrofluorocarbons (HFC) under the Montreal Pwill also continue to take action to promote the rapid deploymenfriendly and safe alternatives in motor vehicle air-conditioning anpromote public procurement of climate-friendly HFC alternative

 UN Climate Summit September 23, 2014 

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Other MVAC Activities
Other MVAC Activities

 Update to Section 609 Technician Certification and Trainin

Programs

 Goal: Prepare technicians entering the industry today for va

MVAC 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.html

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Other MVAC Activities

 Plan to Incorporate by Reference (IBR) new SAE stan

recovery, and recovery/recycle equipment through ru

 SAE J2843 R-1234yf Recovery/Recycling/ Recharging Equ

Flammable Refrigerants for Mobile Air-Conditioning System

 SAE J2851 Recovery Equipment for Contaminated Refriger

Mobile Automotive Air Conditioning Systems

 SAE J3030 Automotive Refrigerant Recovery/Recycling Eq

Intended for Use with Multiple Refrigerants

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Contact Inform

Rebecca von dem 

vondemhagen.rebecca@

(202) 3

Thank You!