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### Whiteman, Chad

From: McArver, Rob <rmcarver@aham.org>

Sent: Friday, June 05, 2015 5:47 PM

To: Whiteman, Chad

Subject: Clarification on AHAM Numbers

Attachments: OMB Meeting re EPA SNAP Delisti ng Proposal - 6.03.15 (00038357).pptx

Chad

–

I offer the following to clarify the figures we cited in Wednesday’s presentation on EPA’s SNAP delisting rule. A copy of

the presentation is attached. As explained below, I made one minor clarifying edit on slide 5 (inserting “in 2020” twice

to show that these are figures for just that one year).

The numbers in the second bullet on slide 3 represent EPA and AHAM’s projected CO2eq of the HFC content of foam in

refrigerators produced from 2017 to 2020 under BAU conditions (60 MMtCO2eq and 16 MMtCO2eq,

respectively). These values do not represent what these products will emit during those years, rather they show how the

amount of HFCs that could eventually be emitted exists within the products manufactured during those years. We used

information provided by EPA during a meeting last October to estimate the avoided emissions attributable to HFC

content in refrigerators according to the SNAP proposal. A document EPA shared included a graph of estimated sales of

domestic refrigerators by blowing agent from 2000 to 2014 and a table of domestic refrigerator blowing agent emission

assumptions.

Missing from this document was a forecast of the refrigerator blowing agent market from 2015 through 2020, which is

necessary to establish an accurate base case. After raising those concerns during our meeting, EPA indicated that they

assumed a base case transition from HFCs to low

‐ GWP blowing agents at a rate of 1% per year, beginning in 2015. This

allowed AHAM to calculate EPA’s base case by converting the information in the graph of estimated sales of domestic

refrigerators by blowing agent into percentages and then applying those percentages along with the transition rate

(from HFCs to low

‐ GWP blowing agents) to the number of estimated 2015 shipments from data recently collected

from our members. Specifically, manufacturers provided to AHAM not only forecasted shipments by product class, but

also the type and weight of foam

‐ blowing agent included in those shipments and the dates when each product would

transition to low

‐ GWP blowing agents. This allowed AHAM to calculate more accurately the extent to which our

members have already transitioned out of HFC

‐ based foam blowing agents and when the remainder will do so.

Our calculations show that the total emissions that actually could be avoided by banning HFCs in refrigerator foam are

far less than EPA projected. The difference in projections is a result of EPA overestimating the number of refrigerators

and freezers manufactured with HFC foam blowing agent between 2017 and 2020. Based on interviews with

manufacturers, AHAM’s analysis includes an up to date snapshot of the current refrigerator foam landscape and reflects

the plans already underway for a complete industry

‐ led transition away from HFCs in foam.

On slide 5, the first bullet cites EPA’s projection of total emissions avoided in 2020 alone that could be attributed to

adoption of the SNAP rule as proposed (I realize now that this was not clear on our slide, so I edited it to clarify that the

figures are only for emissions avoided in 2020). In this case, the figure now represents total emissions avoided in all

applications affected by the SNAP rule, not just refrigerator foam. The second bullet characterizes the portion of total

avoided emissions attributable to changes in refrigerator foam according to EPA’s estimate and our actual data,

respectively. Our point here is that in that situation, the fraction of total emissions avoided that would be attributable

to AHAM members’ products is miniscule, both overall and in comparison to the EPA figure. These avoided emissions

are a very small percentage of HFC usage even by EPA estimates, and they are actually much smaller because the EPA

analysis vastly overstates the amount of HFCs that will still be in use as of 2020.2 This confirms that our request for a minor adjustment of the phase

‐ out date to (1) reflect the voluntary phase

‐ out

already committed to by industry and (2) to align with DOE’s appliance efficiency standards rulemaking and allow our

members to execute a single redesign process will not have any appreciable negative impact on the environment or on

EPA’s overall goals with this rulemaking.

I hope this addresses the questions you and your colleagues had yesterday, but feel free to ask for more detail or

clarification, if needed.

Thanks,

Rob

Robert D. McArver

Vice President, Policy & Government Relations

1111 19th Street NW, Suite 402, Washington, DC 20036

t 202.872.5955 ext316 c 703.582.1324 e rmcarver@aham.org

Visit >www.aham.org< or AHAM's Blog aham.typepad.com