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## Tao Zhan, Ph.D. California Air Resources Board 

# California’s Regulatory Proposal for Reducing Greenhouse Gas Emissions from 

# Mobile Air Conditioning MACS Worldwide 2011 Convention and Trade Show US EPA Regulatory Session Lake Buena Vista, Florida, January 29, 20112 

# Evolution of Regulations

LEV III 2009 MY 2017 MY 

# CA US EPA Federal Rule

2012 MY Mandatory requirements (proposal): • Low- GWP refrigerant • Low leak rate • Indirect emissions limit 

# New Federal Rule MAC improvements earn credits for GHG emissions Credit method similar to CA Pavley approach via “Rose Garden Agreement” 

# AB 1493 (Pavley)3



# LEV III MAC Requirement 1: 

# GWP ≤ 150 (100% for 2017 MY) • Benefits – Provides a nearly 90% direct emission reduction – Harmonizes with EU’s MAC Directive (Directive 2006/40/EC) 

### • Potential candidates / SNAP approval: HFC - 152a (approved), 

### R744 (CO 2

### ) (pending), and HFO - 1234yf (pending) • Movement toward use of low- GWP refrigerant – GM and Aston Martin plan to introduce HFO - 1234yf for 2017 or prior models – Chemical manufacturers indicated their ability to provide sufficient supply of HFO - 1234yf with firm purchase commitment and sufficient lead time – Several stakeholders have expressed concerns about proposed timeline – A multi -year phase - in as proposed by some stakeholders would delay climate benefits, result in larger HFC banks, and cause more potential cross - contamination during service4 

# LEV III AC Requirement 2: Fleet Average Leak Rate ≤ 9 g/yr • Low leak rate is important, regardless of refrigerant used – Maintain efficiency – Reduce need for maintenance 

### • Leak rate will be evaluated using SAE J2727 -type standards for AC using low- GWP refrigerants 

### • 9 g/yr (refrigerant) is achievable – 18 g/yr around 2003 MY (US EPA), 50% reduction feasible (I - MAC) – 14 - 15g/yr for 2009 MY (Minnesota MAC Leakage Database, CA MAC certification programs, Ward’s Auto data), depending on how leak rates are averaged – Some commercially available AC platforms using premium technologies are already achieving 9 g/yr – Some carmakers appear on track for meeting 9 g/yr – Several stakeholders have expressed concerns about stringency of proposed leak rate limit5



# LEV III AC Requirements 1 & 2: Estimated Emission Reduction Potential emission reduction: ≥ 90% by 20406



# LEV III MAC Requirement 3: Indirect Emissions Standard • ARB is proposing to develop a fleet average AC indirect 

### emissions standard – Evaluate through a Whole -Vehicle Performance Test Procedure 

### • For LEV III going to the Board this year, ARB will propose initial adoption of US EPA’s Idle Test procedure and AC Efficiency 

### Credits scheme as a placeholder – Amend the regulation after developing a performance test procedure and an AC indirect emissions standard in ~2 years – Implementation to begin in 2017 

### • Performance test benefits – Able to evaluate all current and new technologies under realistic solar load and driving conditions – Enforceable7



# LEV III MAC Requirement 3 (Cont.): Proposed Performance Test Procedure SC03 Driving Cycle 

### • Elements of proposed test procedure: – Simulated solar load (e.g., 1 hour soak at 850 W m - 2 ) – Moderate ambient cell conditions (e.g., 25 0 C, 50% RH) – Transient test cycle (e.g., SC03+HWFET) – Evaluate AC during both initial cool down and steady state temperature control 

### • Difference between CO 2 

### from AC -off cycle and CO 2 

### from weighted average of AC -on cycles (cool down and steady state) must be  the standard8 

### • California’s new vehicle GHG emission standards for 2017 MY and beyond will be incorporated into the Low Emission Vehicle regulation (LEV III) 

### • Mandatory requirements for MAC proposed under LEV III: – Low- GWP refrigerant – Limit on leak rate – Limit on indirect emissions (evaluated by performance test) 

### • LEV III is under development, and is expected to go to the Board in October, 2011. We are still accepting comments on all aspects of the proposal. 

# Summary9 

### Direct Emissions • Research Division – Dr. Tao Zhan (staff lead), (916) 445 - 9495, tzhan@arb.ca.gov – Dr. Tao Huai (manager), (916) 324 - 2981, thuai@arb.ca.gov 

### Indirect Emissions 

### • Mobile Source Control Division – Dr. Leela Rao (acting manager), (626) 350 - 6469, lrao@arb.ca.gov 

# ARB Contacts For more information, visit http://www.arb.ca.gov/cc/hfc- mac/hfc- mac.htm http://www.arb.ca.gov/msprog/levprog/leviii/leviii.htm