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# Climate Benefits of the SNAP Program Status Change Rule March 2016

U.S. Environmental Protection Agency Stratospheric Protection Division

Office of Atmospheric Programs Office of Air and Radiation

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# Climate Benefits of the SNAP Program Status Change Rule March 2016 Executive Summary The U.S. Environmental Protection Agency (EPA) is issuing a proposed rule that would change the status of certain alternatives 1 

### previously found acceptable under the Significant New Alternatives Policy (SNAP) program and would find certain other alternatives acceptable . The EPA is modify ing the listings from acceptable to unacceptable for certain hydrofluorocarbons (H FCs) and HFC blends in foam blowing, refrigeration and air conditioning , and fire suppression end - uses where other alternatives are available or potentially available that pose overall lower risk to human health and the environment . The e missions avoided associated with the proposed rule are estimated to be 6 to 7 million metric tons (i.e., teragrams) of carbon dioxide equivalent (MMTCO 2 

### eq) in 2025 and 10 to 1 1 MMTCO 2 

### eq in 2030 . 

### B ackground In June 2013, the President announced the Climate Action Plan (CAP) stating that “w hile no single step can reverse the effects of climate change, we have a moral obligation to future generations to leave them a planet that is not polluted and damaged. Through steady, responsible action to cut carbon pollution, we can protect our children’s health and begin to slow the effects of climate change so that we leave behind a cleaner, more stable environment.” 2 

### 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 (GHG) emissions to 3 percent by 2020 and nearly triple by 2030. 3 

### HFCs are rapidly accumulating in the atmosphere. For example, the atmospheric conc entration 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 rose over 13% and 16% per year , respectively, from 2007 to 2011. 4 , 5 

### T he President directed the executive branch of the United States government to lead through both international diplomacy and domestic action in addressing HFCs . 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. ” 6

1 For purposes of this document, t he terms “ substitutes ” and “ alternatives ” are used interchangeably. 2 The President’s Climate Action Plan, Executive Office of the President, June 2013. Available at http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf 3 Ibid. 4 Montzka, S.A.: HFCs in the Atmosphere: Concentrations, Emissio ns and Impacts, ASHRAE/NIST Conference 2012 5 NOAA data at ftp://ftp.cmdl.noaa.gov/hats/hfcs/ 6 The President’s Climate Action Plan, Executive Office of the President, June 2013 , page 10 . Available at http://www.whitehouse.gov/sites/default/files/image/pre sident27sclimateactionplan.pdf

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Under the au thority of S ection 6 12 o f t he C lean A ir Act (CAA) , t he EPA is b oth expanding t he lis t of acceptable alternatives and also changing t he s tatus of certain alt ernatives fr om ac ceptable t o unacceptable. The analysis p resented her e concerns the EPA’s propose d action to modify t he lis tings fr om acceptable t o u nacceptable fo r c ertain H FCs an d HFC b lends foam b lowing, refrigeration an d air conditioning , and fir e s uppression end - uses where o ther alternatives are av ailable o r p otentially av ailable that pose le ss overall risk to h uman h ealth a nd the e nvironment . The agency consider s the i ntersection between t he s pecific H FC or HFC b lend an d t he p articular end - use. In t his a ction, the EPA i s n ot listing any specific H FC s as unacceptable ac ross all sectors an d e nd - uses, n or i s th e EPA d etermining , f or any s pecific sector, that n o HFCs a re acceptable substitutes. Th e EPA re cognizes that b oth flu orinated substitutes (e.g., HFCs, h ydrofluoroolefins (HFOs) ) a nd n on - fluorinated substitutes (e.g., h ydrocarbons ( HCs), c arbon d ioxide (CO 2 

### )) can b e u sed . T hus , c onsistent with C AA S ection 612, th e existing SNAP r egulations, and h istorical practice u nder t he S NAP p rogram , the EPA has c onsidered the i ntersection a mong ea ch substitute being evaluated , the particular end -u se, the S NAP c riteria for evaluation, and t he c urrent s uite o f o ther available and p otentially a vailable s ubstitutes in e ach p articu lar end use . 

### An alysis of Climate Benefits The EPA’s SNAP P rogram, pursuant to CAA Section 612, evaluates whether substitutes are safer overall for human health and the environment than other available substitutes . For each end - use, SNAP lists substitutes as either acceptable, acceptable subject to use conditions, acceptable subject to narrowed use limits, or unacceptable. SNAP’s evaluation of th e overall safety of a substitute considers its toxicity, flammability, ozone depletion potential, and global warming potential (GWP) , among other factors. The CAP directs the EPA to use the SNAP Program to encourage private sector investment in low -emissions technolo gy by identifying and approving climate - friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives. To this end, SNAP ’s Status Change Rule change s the listing of certain alternatives in the foams, re fr igeration and air conditioning, and fire suppression sectors from acceptable to unacceptable , from acceptable to acceptable subject to use conditions , or from acceptable to acceptable subject to narrowed use limits . The specific listing changes for each en d- use can be found in Appendix A. M ethodology To estim ate the climate benefits of the rule, the EPA compared a business - as - usual (BAU) forecast of HFC emissions with those derived under various scenarios conforming to the rule. In developing both the BAU forecast and the scenarios , the EPA used its Vintaging Model, 7 

### an emission estimation tool used to derive HFC emission inventories for reporting to the Intergovernmen tal Panel on Climate Change (IPCC) as part of the United States’ obligations under the United Nations Framework Convention on Climate Change (UNFCCC).

7 VM IO file_v4.4_12.16.09_GER_IMAC_Domestic_2013 Options Upda t e_AR4_11 -21-13.xlsm

### 4 The Vintaging Model was developed as a tool for estimating the annual chemical emissions from industrial sectors that have historically used ozone depleting substances ( ODS ) in thei r products. Under the terms of T

he Montreal Protocol on Substances that Deplete the Ozone Layer and the Clean Air Act , the production and import of ODS ha ve been greatly reduced, motivating these industrial sect ors to transition to more ozone - friendly chemicals. As these industries have moved toward ODS alternatives , including HFCs, the Vintaging Model has evolved into a tool for estimating the rise in emissions of these alternativ es and the decline of ODS emissions. The Vintaging Model estimates emissions from five ODS and ODS - substitute sectors: air - conditioning and refrigeration, foams, aerosols, solvents, and fire suppression . Within these sectors, there are 60 independently mod eled end - uses. The model requires information on the market growth for each of the end - uses, a history of the market transition from ODS to alternatives, and the characteristics of each end use such as market size or charge sizes and loss rates. As ODS are phased out, a percentage of the market share originally filled by the ODS is allocated to each of its substitutes. The model, named for its method of tracking the emissions of annual “vintages” of new equipment that enter into service, is a “bottom - up” mo del. It models the emissions of ODS and ODS substitutes based on estimates of the quantity of equipment or products sold, serviced, and retired each year ; the amount of the chemical required to manufacture and/or maintain the equipment ; and the amount emi tted during specific time periods . The Vintaging Model makes use of this market information to build an inventory of the in - use stocks of the equipment and ODS and ODS substitute (s) in each of the end - uses. The simulation is considered to be a BAU baseline case, and it does not incorporate measures to reduce or eliminate the emissions of these gases other than those currently required by statute or regulation, or otherwise common in the industry. Emissions are estimated by applying annual leak rates, servic e emission rates, and disposal emission rates to each population of equipment. By aggregating the emission output from the different end - uses, the model produces estimates of total annual emissions of each chemical. The Vintaging Model synthesizes data from a variety of sources, including data from the ODS Tracking System maintained by the EPA’s Stratospheric Protection Division and information from submissions to the EPA under the SNAP program. Published sources incl ude documents prepared by the United Nations Environment Programme (UNEP) Technical Options Committees, reports from the Alternative Fluorocarbons Environmental Acceptability Study (AFEAS), and conference proceedings from the International Conferences on O zone Protection Technologies and Earth Technologies Forums. The EPA also coordinates extensively with numerous trade associations and individual companies. For example, the Alliance for Responsible Atmospheric Policy; the Air - Conditioning, Heating and Refr igeration Institute; the Association of Home Appliance Manufacturers; the American Automobile Manufacturers Association; and many of their member companies have provided valuable information over the years. Because the Vintaging Model follows a bottom - up a pproach, scenarios of alternate pathways may be developed by changing transition timing, chemical (s) chosen, and emission patterns. For example, because the proposed rule does not allow certain HFCs to be used in certain end - uses, a scenario can be run in the Vintaging Model that assumes that a particular end - use transitions to an alternative that would remain acceptable. As a specific example, the scenario may assu me that all h ousehold refrigerators utilizing HFC 134a switch to using R - 600a. That scenario could vary in timing; for instance, by assuming th is transition

### 5 only begins in 2021 or by assuming it starts earlier , with some new refrigerators using R - 600a in 2020 and the r est in 2021 . Either such transition would be in compliance with the proposed rule assuming the transition is complete by the required date . Likewise, a scenario could assume transition of some refrigerators to R - 450A instead of R - 600a . To analyze the poten tial emissions reductions of the proposed rule , scenarios were developed to estimate the rate at which transition away from higher - GWP HFCs would progress and what would be used in place of the higher - GWP HFCs . The analysis includes three scenarios for comparison: the most likely transition scenario ; a higher, more aggressive transition scenario ; and a lower , less aggressive transition scenario . 8 

### The scenario s differ in their assumptions on transition away from high er - GWP HFCs in four ways: • earlier /later start of transitions, • faster / s lower rise to saturation , • higher /lower saturation level, and • higher /lower preference for lowe r GWP s in end - uses where the options analyzed vary . The specific transitions assumed for each sc enario are detailed in Table 1 . Table 1: Transition Scenarios

End - Use Option Lower Option Description Most Likely Option Description Higher Option Description Centrifugal Chillers HFC - 134a to R - 450A/R - 513A a Ove rnight transition to 90% in 202 4 0% in 2019, Linear increase to 90% by 202 4 0% in 2019, Linear increase to 45% by 202 4 HFC - 134a to HFO - 1234yf NA NA Overnight transition to 45% in 202 4 HFC - 245fa to SolsticeTM - 1233zd( E ) a Overnight transition to 90% in 202 4 0% in 2019, Linear increase to 90% by 202 4 0% in 2017, Linear increase to 90% by 202 4 Positive Displacement Chillers R - 410A/R - 407C to R - 450A/R - 513A a Overnight transition to 90% in 202 4 0% in 2019, Linear increase to 90% by 202 4 Linear 0% in 2019, Linear increase to 45% by 202 4 R - 410A/R - 407C to HFO - 1234yf NA NA Overnight transition to 45% in 202 4 HFC - 134a to R - 450A/R - 513A b NA NA NA Cold Storage R - 404A/R - 507A to R - 407F Overnight transition to 100% in 2023 0% in 2016, Linear increase to 50% by 2023 NA R - 404A/R - 507A to

R - 448A/R - 449A NA 0% in 2017, Linear increase to 50% by 2023 0% in 2017, Linear increase to 100% by 2023 Household Refrigerators and Freezers c HFC - 134a to R - 450A/ R - 513A Overnight transition to 28% in 2021 Overnight transition to 14% in 2021 NA HFC - 134a to R - 600a Overnight transition to 72% in 2021 Overnight transition to 86% in 2021 Overnight transition to 100% in 2021

8 The scenarios analyzed here reflect possible transitions for compliance based on considerations of the market and activity towards lower - GWP solutions. A separate technical support document analyzes the cost of co mplying with the proposed rule.

### 6 End - Use Option Lower Option Description Most Likely Option Description Higher Option Description Refrigerated Food

Processing and Dispensing Equipment d R - 404A/R - 507A to R - 450A NA NA NA

Polyurethane Rigid Spray Foam (High - pressure, two component) HFC - 245fa and HFC 245fa/CO 2 to SolsticeTM - 1233zd( E ) Overnight transition to 70% in 2020 0% in 2017, Linear increase to 70% by 2020 0% in 2015, Linear increase to 70% by 2020 (Low - pressure, two component) HFC - 134a to HFO - 1234ze( E ) e Overnight transition to 30% in 2021 0% in 2017, Linear increase to 30% by 2021 0% in 2015, Linear increase to 30% by 2021 Polyurethane Rigid One Component Foam HFC - 134a to HFO 1234ze( E ) Overnight transition to 100% in 2020 0% in 2017, Linear increase to 100% by 2020 0% in 2015, Linear increase to 100% by 2020 Flexible PU Foam: Slabstock Foam, Moulded Foam Methylene Chloride to HCs b NA NA NA Flexible PU Foam: Integral Skin Foam Methylene Chloride to HCs or CO 2 b NA NA NA Polyolefin Foam Methylene Chloride to HCs b NA NA NA Fire Suppression:

Total Flooding Perfluorocarbons (C 3 F 8 and C 4 F 10 ) to fluoroketone, CO 2 , or water mist b NA NA NA

a In the absence of this proposed rulemaking, by 2022 it is assumed that 10% of the positive displacement and centrifugal chillers markets will have already transitioned away from HFCs or would remain in HFCs under a narrowed use limit . This transition is not reflected in the baseline. This assumption is based on the current commercial availability of R - 513A and SolsticeTM - 1233zd( E ) chillers as well as commitments from chiller manufacturers to introduce lower - GWP refrigerants in their product lines ( https://www.whitehouse.gov/the - press - office/2015/10/15/fact - sheet - obama - administration - and - private - sector - leaders annou nce ) b Zero penetration for original fluorinated or chlorinated compound currently assumed in Vintaging Model; Option not applied. c This analysis assumes that in the lower option transition scenario small manufacturers of household refrigerators and freez ers will transition from HFC - 134a to either R - 450A or R - 513A and large business manufacturers will transition to isobutane (R - 600a). The market penetration assumptions are based on the market share of new sales of household refrigerators and freezers by ma nufacturer developed for the Draft Economic Impact Screening Analysis for Regulatory Changes to the Listing Status of High GWP Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire Suppression for this proposed rulemaking. d Refrigerated food processing and dispensing equipment options were not analyzed, as this end - use was not modeled in this version of the Vintaging Model. e The Vintaging Model spray foam end - use, which assumes the use of HFC - 245fa and HFC - 245fa co - blown with CO 2 blowi ng agents, does not disaggregate spray foam into high - pressure, two - component and low - pressure, two - component foam applications. Low - pressure, two - component foam primarily uses HFC - 134a as the blowing agent; however, the model does not model any use of HFC - 134a in the spray foam end - use. As a proxy, this analysis assumes a portion of the currently modeled blowing agent market (i.e., HFC - 245fa and HFC - 245fa/CO 2 ) represents low - pressure, two - component spray foam that would transition to HFO - 1234ze. Because th is portion of the market would actually be transitioning from HFC - 134a, this analysis underestimates potential reductions from this transition by approximately 50% per year due to the GWP differential between HFC - 245fa and HFC - 245fa co - blown with CO 2 and H FC - 134a (i.e., GWPs of 1,030 , 550, and 1,430, respectively) and the assumed market share of these blowing agents (i.e., 33% HFC - 245fa and 67% HFC - 245fa co - blown with CO 2 ) .

### 7 The U.S. emissions of HFCs from each end - use were estimated for these scenarios and the baseline scenario (i.e., BAU scenario without the rule) using the EPA’s Vintaging Model , and the total GWP weighted emissions were calculated in MMTCO 2 

### eq as shown below in Table 2 and Figure s 1 and 2 . 9 

### The version of the Vintaging Model used is consistent with previous EPA analyses of non - CO 2 

### GHG abatement options . 10 

### Climate Benefits As shown in Table 2 , implementation of the Status Change Rule is estimated to reduce net HFC emissions in 2025 by 6 to 7 MMTCO 2 

### eq and 10 to 1 1 MMTCO 2 

### eq in 2030 , relative to the baseline. Note that this baseline assumes some reductions due to the July 2015 Climate Benefits of the SNAP Program Status Change Rule [EPA - HQ - OAR - 2014 - 0198 - 0239] . For this reason the projected trend of HFC emissions from modeling pe rformed in 2014 for that earlier rule is also shown for comparison. The most likely transition scenario was developed based on EPA experience in the sectors and knowledge of the available , SNAP acceptable alternatives that are currently being tested and implemented. Table 2 . Emissions Profile of Affected Sectors/Applications in Transition Scenarios and Baseline Year 2015 2020 2025 2030 2035 2040 2045 2050 Pre - 2014 emissions trend 215 285 373 420 463 500 531 556 United States baseline including

July 2015 rule 212 255 311 324 351 379 403 422 Lower Scenario Emissions 212 253 306 314 337 361 380 395 Lower Scenario Percent Reduction 0% - 1% - 2% - 3% - 4% - 5% - 6% - 6% Most Likely Scenario Emissions 212 252 305 313 335 359 379 394 Most Likely Scenario

Percent Reduction 0% - 1% - 2% - 3% - 4 % - 5% - 6% - 7%

Higher Scenario Emissions 212 252 304 313 334 358 377 393 Higher Scenario Percent Reduction 0% - 1% - 2% - 3 % - 5% - 6% - 6% - 7%

9 GWPs used are direct, 100 - year values from IPCC, 2007: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA . Where GWPs are not available from that source, values are taken from the literature as referenced in the SNAP decisions first listing such substances as acceptable. 10 Global Mitigation of Non - CO 2 Greenhouse Gases: 2010 – 2030 (EPA Report 430 - R - 13 - 011, September 20 13)

### 8 As seen in 2020, under the “most likely” transition scenario, emissions are projected to be reduced to 252 MMT CO 2 

### eq out of baseline emissions of 255 MMT CO 2 

### eq This represents a 1% reduction in emissions. After 2020, emission r eductions steadily increase to 7 % of baseline through 2050 with some growth in emissions due to continued market growth with all options fully implemented. Figure 1 below shows the potential range in emissions following th e adoption of either the lower, most likely, or higher scenario. In addition, the emissions trend as calculated before the 2015 Status Change Rule is shown for comparison . Figure 1. United States Emissions and Potential Reductions through 2050

The growth in emissions reductions can be seen in Figure 2. A short period of transition, during which the implementation of lower - GWP alternatives is increasing, is complete in all end - uses by 2023. After 2023, emission reductions steadily increase to 5% of baseline through 2050 with some growth in emissions due to continued market growth with all options fully implemented. 

### 200 250 300 350 400 450 500 550 600

2015 2020 2025 2030 2035 2040 2045 2050HFC emissions (MMTCO2eq) 

### United States pre-2014 emissions trend United States baseline including July 2015 rule Range of potential emissions based on scenarios

### 9 By 2023, most of the provisions in the proposed rule would be in effect. The differences in the three scenarios in 2025 and other year s are significant mostly because of the lag between when alternatives are introduced in new equipment and foams, and when the emission reductions are realized. The later and slower transitions in the lower scenario have not yet accrued emissions reductions by 2025 to the extent of those accrued under the most likely scenario, which in turn has not yet reached the levels seen in the higher scenario. Figure 2. Emissions Reductions by Sector in 2025 (MMTCO 2 

### eq) , Most Likely Scenario



### Conclusion The EPA anticipates that 6 to 7 MMTCO 2 

### eq is the most likely estimate for the climate benefits associated with avoided emissions for the SNAP Status Change Rule in 2025 and 10 to 1 1 MMTCO 2 

### eq in 2030 . Three scenarios the EPA considered were developed and compared with a business - as - usual scenario. If the EPA were to consider the emissions reductions in 2035 or another later date, the climate benefits would be greater. Chillers 0.3 Refrigerated Appliances 0.1 Cold Storage 0.8 PU Foam 5.1

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### Appendix A Proposed Listing Changes in the Status Change Rule by Sector

Opt ion Description of Regulatory Change Refrigeration and Air - Conditioning 1 * For new centrifugal chillers , list unacceptable FOR12A, FOR12B, HFC - 134a, HFC - 227ea, HFC - 236fa, HFC 245fa, R - 125/134a/600a (28.1/70/1.9), R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R 410A, R - 410B, R - 417A, R - 421A, R - 422B, R - 422C, R - 422D, R - 423A, R - 424A, R - 434A, R - 438A, R - 507A, RS - 44 (2003 composition), and THR - 03 in 20 2 4 . 2 For retrofit centrifugal chillers , list unacceptable FOR12A, FOR12B, HFC - 134a, HFC - 236fa, HFC - 245fa, R 125/134a/600a (28.1/70/1.9), R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 417A, R 417C, R - 421A, R - 422B, R - 422C, R - 422D, R - 423A, R - 424A, R - 434A, R - 438A, R - 507A, RS - 44 (2003 composition), and THR - 03 in 202 4 . 3 * For new positive displacement chillers , list unacceptable FOR12A, FOR12B, HFC - 134a, HFC - 227ea, KDD6, R - 125/134a/600a (28.1/70/1.9), R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 410A, R 410B, R - 417A, R - 421A, R - 422B, R - 422C, R - 422D, R - 424A, R - 434A, R - 437A, R - 438A, R - 507A, RS - 44 (2003 composition), SP 34E, and THR - 03 in 202 4 . 4 For retrofit positive displacement chillers , list unacceptable FOR12A, FOR12B, HFC - 134a, KDD6, R 125/134a/600a (28.1/70/1.9), R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 417A, R 417C, R - 421A, R - 422B, R - 422C, R - 42 2D, R - 424A, R - 427A, R - 434A, R - 437A, R - 438A, R - 507A, RS - 44 (2003 composition), SP34E, and THR - 03 in 202 4 . 5 * For new retail food refrigeration (refrigerated food processing and dispensing equipment) , l ist unacceptable HFC - 227ea, KDD6, R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407A, R - 407B, R 407C, R - 407F, R - 410A, R - 410B, R - 417A, R - 421A, R - 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 424A, R 428A, R - 434A, R - 437A, R - 438A, R - 507A, and RS - 44 (2003 formulation) in 2021 . 6 For retrofit retail food refrigera tion (refrigerated food processing and dispensing equipment) , l ist unacceptable R - 404A and R - 507A one year after publication of a final rule . 7a * For new household refrigerators and freezers , list unacceptable FOR12A, FOR12B, HFC - 134a, KDD6, R 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 407F, R - 410A, R - 410B, R - 417A, R - 421A, R 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 424A, R - 426A, R - 428A, R - 434A, R - 437A, R - 438A, R - 507A, RS - 24 (2002 formulation), RS - 44 (2003 formulation), SP34E, and THR - 03 in 2021 . 7 b For new household refrigerators and freezers , list unacceptable FOR12A, FOR12B, HFC - 134a, KDD6, R 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 407F, R - 410A, R - 410B, R - 417A, R - 421A, R 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 424A, R - 426A, R - 428A, R - 434A, R - 437A, R - 450A, R - 438A, R 507A, R - 5 13A, RS - 24 (2002 formulation), RS - 44 (2003 formulation), SP34E, and THR - 03 in 2021 . 7 c For new household refrigerators and freezers , list unacceptable FOR12A, FOR12B, HFC - 134a, KDD6, R 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 407F, R - 410A, R - 410B, R - 417A, R - 421A, R 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 424A, R - 426A, R - 428A, R - 434A, R - 437A, R - 438A, R - 450A, R 507A, R - 513A, RS - 24 (2002 formulation), RS - 44 (2003 formulation), SP34E, and THR - 03 in 2025 . 8 For retrofit household refrigerators and freezers , list unacceptable FOR12A, FOR12B, HFC - 134a, KDD6, R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407C, R - 407F, R - 417A, R - 421A, R - 421B, R - 422A, R 422B, R - 422C, R - 422D, R - 424A, R - 426A, R - 427A, R - 428A, R - 434A, R - 437A, R - 438A, R - 507A, RS - 24 (2002 formulation), RS - 44 (2003 formulation), and SP34E in 2021 . 9a * For new cold storage warehouses , l ist unacceptable HFC - 227ea, R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407A, R - 407B, R - 410A, R - 410B, R - 417A, R - 421A, R - 421B, R - 422A, R - 422B,

R - 4 22C, R - 422D, R - 423A, R - 424A, R - 428A, R - 434A, R - 438A, R - 507A, and RS - 44 (2003 composition) in 2021 .

### 11 Opt ion Description of Regulatory Change

9b For new cold storage warehouses , list unacceptable HFC - 227ea, KDD6, R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R - 404A, R - 407A, R - 407B, R - 407C, R - 407F, R - 410A, R - 410B, R - 417A, R - 421A, R - 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 423A, R - 424A, R - 428A, R - 434A, R - 437A, R - 438A, R - 507A, and RS - 44 (2003 composition) in 2021 . 10 For retrofit cold storage warehouses, list unacceptable R - 125/290/134a/600a (55.0/1.0/42.5/1.5), R 404A, R - 407A, R - 407B, R - 417A, R - 421A, R - 421B, R - 422A, R - 422B, R - 422C, R - 422D, R - 423A, R - 424A, R 428A, R - 434A, R - 438A, R - 507A, and RS - 44 (2003 composition) in 2021 . Foam Blowing 11 a For rigid polyurethane high - pressure two - component spray foam , list unacceptable HFC - 134a, HFC 245fa, and blends thereof; blends of HFC - 365mfc with at least 4% HFC - 245fa, and commercial blends of HFC - 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI, in 2019 , except as allowed under a narr owed use limit for military or space - and aeronautics – related applications. 1 1 b * For rigid polyurethane high - pressure two - component spray foam , list unacceptable HFC - 134a, HFC 245fa, and blends thereof; blends of HFC - 365mfc with at least 4% HFC - 245fa, and commercial blends of HFC - 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI in 2020, except as allowed under a narrowed use limit for military or space - and aeronautics – related applications. 1 2 a For rigid polyurethane low - pressure two - component spray foam , list unacceptable HFC - 134a, HFC 245fa, and blends thereof; blends of HFC - 365mfc with at least 4% HFC - 245fa, and commercial blends of HFC - 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI in 2020 , except

as allowed under a narrowed use limit for military or space - and aeronautics – related applications. 1 2 b * For rigid polyurethane low - pressure two - component spray foam , list unacceptable HFC - 134a, HFC 245fa, and blends thereof; blends of HFC - 365 mfc with at least 4% HFC - 245fa, and commercial blends of HFC - 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI in 2021 , except

as allowed under a narrowed use limit for military or space - and aeronautics – related applications. 1 3 a For rigid polyurethane one - component foam sealants , list unacceptable HFC - 134a, HFC - 245fa, and blends thereof; blends of HFC - 365mfc with at least 4% HFC - 245fa, and commercial blends of HFC 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI in 2019 , except as allowed under a narrowed use limit for military or space - and aeronautics – related applications. 1 3 b * For rigid polyurethane one - component foam sealants , list unacceptable HFC - 134a, HFC - 245fa, and blends thereof; blends of HFC - 365mfc with at least 4% HFC - 245fa, and commercial blends of HFC 365mfc with 7 to 13% HFC - 227ea and the remainder HFC - 365mfc; and Formacel TI in 2020 , except as allowed under a narro wed use limit for military or space - and aeronautics – related applications. 14* In flexible polyurethane foam, list methylene chloride as unacceptable 30 days after publication of a final rule. 15* In integral skin polyurethane foam , list methylene chlori de as unacceptable in 2017 . 1 6* In polyolefin foam, list methylene chloride as unacceptable in 2020. Fire Suppression and Explosion Prevention 1 7 a * For total flooding uses, list unacceptable perfluorocarbons (C 3 F 8 and C 4 F 10 ) one year after publication of a final rule. 1 7b For total flooding uses, list unacceptable perfluorocarbons (C 3 F 8 and C 4 F 10 ) and SF 6 one year after publication of a final rule and list HFC - 23 as acceptable, subject to narrowed use limit s one year after publication of a final rule. 1 8 For streaming uses, list unacceptable perfluorocarbon (C 6 F 14 ) one year after publication of a final rule.