# Staff Analysis of Proposed Early Action for

Climate Change Mitigation in California

1. Early Actions Strategy Name and Proponent

SUMMARY # B02

ID NUMBER: N/A

TITLE: REDUCTION OF HFC-134a EMISSIONS FROM

NONPROFESSIONAL SERVICING OF MOTOR VEHICLE AIR CONDITIONING SYSTEMS (MVACs)

PROPONENT: 2007 EARLY ACTIONS FINAL REPORT AND 2006 CAT

REPORT



### 2. Staff Recommendation

Staff recommends that this strategy be retained as a discrete early action as approved by the Board during its June 21, 2007 hearing. The form of the regulation has not been developed and CARB staff is considering an industry proposal as well as a restriction on the sale of small cans of refrigerant. Staff recog nizes that the latter strategy will place some economic hardship on the low-income sector of the public. The Environmental Justice Advisory Committee and certain Board member s have expressed some concerns about this regulatory proposal. Whichever approach is taken, the reductions in emissions that can be achieved is significant consi dering the amount of effort.



### 3. Early Action Description

This regulatory measure would reduce the emissions of high-GWP refrigerants by nonprofessionals who recharge their leaking automotive air conditioning systems. This strategy would apply predominantly to the individua l who recharges their personal vehicles’ air conditioner(s). These individuals ty pically do not have the know-how to either repair their leaking MVACS, or the proper eq uipment to correctly re-charge the system. HFCs are potent GHGs. Specifically, HFC-1 34a, used nearly universally in motor vehicle air conditioning systems, has a GWP o f 1300 as compared to CO2 (with a GWP of 1). The focus of this strategy is to elimina te the unnecessary releases of HFC134a when cans are used to recharge leaky MVACS. T he source of these emissions include the leaking A/C unit that is never repaired , the breaching of the system in recharging the MVACS, and the discarding of the refri gerant can containing the unused portion of the refrigerant. As mentioned previousl y, the exact nature of this proposed

measure has not been determined. CARB staff is con sidering a concept restricting the sales of small cans of refrigerant as well as an in dustry proposal that would reduce emissions from the unused refrigerant remaining in the used can. CARB staff intends to work with industry in an evaluation process to char acterize the emission reductions, technical feasibility, and cost effectiveness of ea ch option. The most viable alternative will be brought to the Board for their consideratio n.

### 4. Potential Emission Reductions

Potential emission reductions for the sale restrict ion option have been estimated to be in the range of from 1 to 2 MMTCO2E in 2012 that would give an emission reduction potential rating of large. The industry proposal w ould result in estimated reductions ranging from less than 0.1 MMTCO2E to approximately 1 MMTCO2E which would give an emission reduction potential of medium.



### 5. Estimated Costs / Economic Impacts and the Impa cted Sectors / Entities

The cost of a small can of refrigerant is approxima tely $10 per can. There are anywhere

from 2 million to 4 million small cans sold in Cali fornia per year. Thus, a complete ban on

the sale of small cans would result in the eliminat ion of about $23 million to $40 million dollars per year of small can sales. Dividing this cost by the estimated emission reductions gives a preliminary cost effectiveness r ange of from about $ 12 to $ 40 per

MTCO 2 E. The true cost and cost effectiveness numbers ma y be much less if one considers only the actual profit margin per can, ra ther than the total cost of the can at

retail.

The professional auto A/C servicing industry would benefit significantly from the increase in demand of its services and at the expense of the DIY, who would see her A/C service costs climb from a cost per can of HFC-134a of appr oximately $10 to the cost of professional A/C servicing of more than $100. Indu stry has recently determined a windfall profit to the professional mechanic, who i n 2006 on average charges $147 for recharge service, on the order of more than $166 mi llion. It appears that lower-income individuals may be more affected by this measure th an others since they would do their own MVACS servicing rather than paying someone. On the other hand, the use of professionals in servicing automobile A/C systems w ould probably result in reduced emissions and A/C systems operating in a more effic ient manner. Professional technicians have the experience, training and prope r equipment to service and repair these complex systems. So there would be a benefit to the sales restriction approach

Industry has proposed the implementation of a refri gerant can return program along with refrigerant recovery of the unused contents. Costs and cost effectiveness of this proposal are yet to be determined. This proposal w ould target one specific component of the emissions from the DIY practitioners, the ca n heel. Industry has said that they would support the inclusion of a leak check require ment in the Smog Check Program. This alternative would certainly lessen the cost im pacts on the low-income population although the price of the refrigerant would probabl y increase due to the use of selfsealing valves and the set-up and operation of a ca n return and refrigerant recovery

program.



### 6. Technical Feasibility

The form of this discrete early action has not been determined. One proposal calls for a restriction on the sales of small cans of refrigera nt. This regulatory proposal would not be considered a technology-based regulation, becaus e it would basically prohibit the sale of small cans of refrigerant. The alternate p roposal from industry would reduce emissions from the unused refrigerant remaining in the used can by the installation of self-sealing valves on the refrigerant containers a nd the recovery of the refrigerant remaining in the used can. Self-sealing valves are used on some containers of theproduct so it is an accepted technology. There is still some uncertainty how refrigerant

recovery from the used containers would work althou gh it would seem to be technically

feasible.



### 7. Additional Considerations

The state of Wisconsin has passed regulations restr icting the sale and use of HFC-134a. In addition, several local air districts in Califor nia have regulations prohibiting the release of refrigerants into the atmosphere and, in some di stricts, restricting the sale of small

cans.

This proposed regulation is a CAT strategy and woul d fall under the jurisdiction of ARB since it involves emissions of the refrigerant into the atmosphere. Under the Global Warming Solutions Act, AB 32, the ARB has the regul atory authority to restrict the sale and use of HFC-134a, a high-GWP refrigerant, in thi s particular sector. As an Early Action Item this proposed regulation will be taken to the Board by early 2009.



### 8. Division: Research Division

Staff Lead: Winston Potts Section Manager: Tao Huai

Branch Chief: Alberto Ayala

9. References:
Sciance, F., “Society of Automotive Engineers Impro ved Mobile Air Conditioning Cooperative Research Program,” SAE 7 th Alternate Refrigerant Systems Symposium, Scottsdal e, AZ, June,

2006.

U.S. Consumer Buying Behaviors of R-134a Refrigeran t for Light Vehicle Applications, Draft Report by Frost & Sullivan for the Automotive Refri geration Products Institute, September 2006.

Personal communication. Rick Raborn, Sexton Can Com pany.

Atkinson, W., “Emissions from Refrigerant Container s, EPA Study,” SAE 7 th Alternate Refrigerant Systems Symposium, Scottsdale, AZ, June, 2006.

“Reducing Global Warming Emissions...while still ena bling motorists to work on their car’s air conditioner.” Working presentation to CARB and EPA by ARPI, Dec. 13, 2006, Sacramento, CA.