1 **SNAP/Climate Action Plan HFC**  **Component Stakeholder Meeting February 4, 2014**  **Concept Note**

Last June, President Obama announced the Climate Action P lan (CAP) , and a broad set of initial steps designed to slow the effects of climate change. Among the many actions called for , the CAP outlined a set of measures to address h ydrofluorocarbons (HFCs)

. In the United States, emissions of HFCs are expected to double from current levels of 1.5 percent of greenhouse gas emissions to 3 percent by 2020 and nearly triple by 2030

. 1 HFCs are rapidly accumulating in the atmosphere. For example, the atmospheric concentration of HFC

- 134a, the most abundant HFC, has increased by about 10% per year from 2006 to 2012, and the concentrations of HFC

- 143a and HFC

- 125 have ri sen over 13% and 16% per year from 2007

- 2011, respectively. 2 3

In order to address HFCs, the President directed the United States to lead through both international diplomacy and domestic action . I n particular, he directed the EPA to use its authority through the Significant New Alternatives Policy (SNAP) Program to encourage private sector investment in low

- emissions technology by identifying and approving climate

- friendly chemicals while prohibiti ng certain uses of the most harmful chemical alternatives. In addition, the President directed his Administration to purchase cleaner alternatives to HFCs whenever feasible and to transition over time to equipment that uses safer and more sustainable alter natives.

I n August of last year
, EPA held a broad stakeholder meeting to discuss t he C AP provisions related to HFCs , and our initial thinking on how the longstanding SNAP program could be used to meet the President ’ s goals . We also invited our stakeholder s to share with us their ideas

. EPA has held six sector specific workshops and a large number of individual meetings where stakeholders provided us with valuable input

. T hrough those meetings, we have learned a great deal that will guide both our initial actions, and the longer term measures that we will consider in encouraging development, availability and widespread market acceptance of safer alternatives.

EPA would now like to share with our stakeholders what we have learned to date, and what we are considering by way of next steps . It is our hope that sharing this information at this time will provide a more specific roadmap to facilitate and focus the further input of our individual stakeholders, and that by laying out more detailed near

- term plans, we can continue to gather and exchange information with you that can assist us in this process.

1 http://www.whitehouse.gov/share/climate

- action

- pla n 2 Montzka, S.A.: HFCs in the Atmosphere: Concentrations, Emissions and Impacts, ASHRAE/NIST Conference 2012 3 NOAA data at ftp://ftp.cmdl.noaa.gov/hats/hfcs/2 S pecifically, a t this point, we are planning two separate proposed rules

– a rule expanding the list of low

- GWP alternatives , which w e expect w ill be proposed this spring , and a SNAP alternative s status change rule, which we expect will be proposed t his s ummer

. We expect that these rules will go through the full notice and comment rulemaking process, thereby enabling the Agency and other interested parties to benefit from your formal comments.

The new alternatives listing rule would address a group of key refrigeration and air

conditioning alternatives that we have been hearing about in our sector and individual meetings, and that have been submitted and reviewed under SNAP

. This rule , if finalized, would enhance the SNAP menu of acce ptable alternatives for a number of related end uses by proposing to add several alternatives as acceptable subject to use conditions

. I n keeping with our traditional review of the specific situation prevail ing in each end use, this new listing proposal is likely to include a range of options
, and could include lower GWP fluorocarbons, where such listings would decrease overall risk to human health and the environment

. We expect that market acceptance of the newly listed alternatives will facilitate redu ctions in the use of high GWP HFCs and thus , advance the Climate Action Plan’s goal of deliver ing significant climate benefits. Since SNAP lists are routinely relied upon not just domestically, but worldwide as a resource for transition, we further anticipate that this expansion will advance safer alternatives more broadly as well

. The second rulemaking, the SNAP alternative s status change rule , would respond to the President ’ s direction for SNAP to prohibit certain uses of the most harmful chemical alternatives. W e expect this status change proposal to prioritiz e opportunities with a view
to e nabl ing significant climate benefits

.
W e expect t his rule to maintain SNAP ’ s traditional pragmatic approach . Accordingly, stakeholders should not anticipate a broad review of all listings in this proposal ; on the contrary, we intend to limit this proposal to what we believe are clear opportunities for reducing overall risk and securing cl imate benefits

. Further, and as has historic al ly been the case, o ur review s will be done in a manner that is end

- use specific, and , that does not rely on some preconceived ‘bright line’. In that regard, w e are aware that technological progress and market advances are profoundly case

- specific. Hence, an alternative that i s a comparatively high GWP HFC for one end use, may be very much in the middle of the pack for another end use. In developing this proposal, and consistent with our statutory requirements, we will also carefully consider the availability of alternatives , a nd, a s in the past, we expect to make sure that we have a good understanding of the amount of time it might take to effectuate the conversion to available or potentially available alternatives. Finally, stakeholders may also anticipate that while we are responsive to the direction given us in the CAP, we will continue to consider not only effects on climate related to an alternative, but the full set of SNAP criteria as they pertain to a specific end use in making our decision for any substitute for that end use.3 We are also aware of the various factors that individual stakeholders have raised for us to consider in prioritizing potential actions, such as the number and market penetration of available alternatives, diversity in the class es of alternatives available, the fact that different end uses may need different time periods to convert to new alternatives, and , their desire for EPA to consider allowing for the continued servicing of existing equipment in appropriate cases. Finally, we share the desire of stakeholders to find ways to enhance certainty for investments in low GWP technologies , and to increase the efficiency of EPA ’s review process

.
B ased on the information that we have gathered to date from the s ector specific workshops

an d from our interaction with users and producers from around the world, we currently believe that there are lower GWP alternatives that are available or potentially available for certain end uses in the aerosols, foam

- blowing, air conditioning, and refriger ation sectors. A ccordingly, we have begun to look at individual end use s in these sectors and to focus on whether some high

- GWP HFCs should no longer be acceptable

. In that regard, and b ased

on what we have learned to date, we currently believe that changes for some of the highest G WP HFCs currently listed as acceptable by the SNAP program in the following end uses may merit consideration :

• Non

- Medical and non

- technical aerosols

• Various foam blowing end uses

o Rigid Polyurethane: Appliance ; Commercial Refrigeration, and Sandwich Panels , Slabstock

o Flexible Polyurethane

o Polyolefin

o Polystyrene: Extruded Boardstock & Billet

o Rigid Polyurethane & Polyisocyanurate Laminated Boardstock

o Phenolic Insulation Board & Bunstock

• Commercial Refrigerants: V e nding M achines, S tand

- A lone R each

- I n C oolers, and M ultiplex S upermarket S ystems

• Motor V ehicle A ir C onditioning

G iven the situation currently prevailing in each of the end uses noted above, and in the context of an initial status change action , we believe that the menu of options would likely continue to i nclude a broad range of alternative types (eg: both fluorinated and non

fluorinated alternatives and, in appropriate cases, chemical and not

- in

- kind alternatives

. )

We appreciate the importance of your views , and the primary purpose of this concept paper is to share with you our current thinking to enable you to provide more focused input on these near term actions . In addition, the growing number of SNAP submissions
attests to the dynamic nature of the affected industries, and the likelihood that4 technological advancements will spur future SNAP /Climate Action Plan work

. As a result,

we would also appreciate the continued feedback of individual stakeholders on ways that

we can o ptimize the operation of the SNAP progra m to meet the President’s goal of reducing em issions of HFCs by, among other things, encouraging private sector investment in low emission technology.