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SNAP/Climate Action Plan HFC Component

Stakeholder Meeting February 4, 2014

Concept Note

Last June, President Obama announced the Climate Action Plan (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 hydrofluorocarbons (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.

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 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 risen 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. In 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 prohibiting 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 alternatives.

In August of last year, EPA held a broad stakeholder meeting to discuss the CAP 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 stakeholders 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. Through 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-plan 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/
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Specifically, at this point, we are planning two separate proposed rules – a rule expanding 

the list of low-GWP alternatives, which we expect will be proposed this spring, and a SNAP 

alternatives status change rule, which we expect will be proposed this summer. 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 airconditioning 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 acceptable alternatives for a number of related end uses

by proposing to add several alternatives as acceptable subject to use conditions. In keeping 

with our traditional review of the specific situation prevailing 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 reductions in the use of high GWP HFCs and thus, advance the Climate Action 

Plan’s goal of delivering 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 alternatives status change rule, would respond to the 

President’s direction for SNAP to prohibit certain uses of the most harmful chemical

alternatives. We expect this status change proposal to prioritize opportunities with a view 

to enabling significant climate benefits. 

We expect this 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 climate benefits. Further, and as has historically been 

the case, our reviews will be done in a manner that is end-use specific, and, that does not 

rely on some preconceived ‘bright line’. In that regard, we are aware that technological 

progress and market advances are profoundly case-specific. Hence, an alternative that is 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, and, as 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. 
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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 classes 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.

Based on the information that we have gathered to date from the sector specific workshops 

and 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 refrigeration sectors. 

Accordingly, we have begun to look at individual end uses in these sectors and to focus on 

whether some high-GWP HFCs should no longer be acceptable. In that regard, and based 

on what we have learned to date, we currently believe that changes for some of the highest 

GWP 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: Vending Machines, Stand-Alone Reach-In Coolers, and 

Multiplex Supermarket Systems

• Motor Vehicle Air Conditioning

Given 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 include a broad range of alternative types (eg: both fluorinated and nonfluorinated 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 that 
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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 optimize the operation of the SNAP program to meet the President’s goal of 

reducing emissions of HFCs by, among other things, encouraging private sector investment 

in low emission technology.