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 recognizes 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 members have expressed some 

concerns about this regulatory proposal. Whichever approach is taken, the reductions in 

emissions that can be achieved is significant considering 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 individual who recharges their personal 

vehicles’ air conditioner(s). These individuals typically do not have the know-how to 

either repair their leaking MVACS, or the proper equipment to correctly re-charge the 

system. HFCs are potent GHGs. Specifically, HFC-134a, used nearly universally in 

motor vehicle air conditioning systems, has a GWP of 1300 as compared to CO2 (with a 

GWP of 1). The focus of this strategy is to eliminate the unnecessary releases of HFC134a when cans are used to recharge leaky MVACS. The 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 refrigerant can containing the unused 

portion of the refrigerant. As mentioned previously, the exact nature of this proposed 

measure has not been determined. CARB staff is considering a concept restricting the 

sales of small cans of refrigerant as well as an industry 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 characterize the emission reductions, 

technical feasibility, and cost effectiveness of each option. The most viable alternative 

will be brought to the Board for their consideration. 
4. Potential Emission Reductions

Potential emission reductions for the sale restriction 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 would 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 Impacted Sectors / Entities 

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

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

the sale of small cans would result in the elimination 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 range of from about $ 12 to $ 40 per 

MTCO2E. The true cost and cost effectiveness numbers may be much less if one 

considers only the actual profit margin per can, rather 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 approximately $10 to the cost of 

professional A/C servicing of more than $100. Industry has recently determined a 

windfall profit to the professional mechanic, who in 2006 on average charges $147 for 

recharge service, on the order of more than $166 million. It appears that lower-income 

individuals may be more affected by this measure than 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 would probably result in reduced 

emissions and A/C systems operating in a more efficient manner. Professional 

technicians have the experience, training and proper 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 refrigerant 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 would target one specific component 

of the emissions from the DIY practitioners, the can heel. Industry has said that they 

would support the inclusion of a leak check requirement in the Smog Check Program. 

This alternative would certainly lessen the cost impacts on the low-income population 

although the price of the refrigerant would probably increase due to the use of selfsealing valves and the set-up and operation of a can 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 refrigerant. This regulatory proposal would not 

be considered a technology-based regulation, because it would basically prohibit the 

sale of small cans of refrigerant. The alternate proposal 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 and the recovery of the refrigerant 

remaining in the used can. Self-sealing valves are used on some containers of the 
product so it is an accepted technology. There is still some uncertainty how refrigerant 

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

feasible. 

7. Additional Considerations 

The state of Wisconsin has passed regulations restricting the sale and use of HFC-134a. 

In addition, several local air districts in California have regulations prohibiting the release 

of refrigerants into the atmosphere and, in some districts, restricting the sale of small 

cans. 

This proposed regulation is a CAT strategy and would 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 regulatory authority to restrict the sale 

and use of HFC-134a, a high-GWP refrigerant, in this 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 Improved Mobile Air Conditioning Cooperative 

Research Program,” SAE 7th Alternate Refrigerant Systems Symposium, Scottsdale, AZ, June, 

2006. 

U.S. Consumer Buying Behaviors of R-134a Refrigerant for Light Vehicle Applications, Draft 

Report by Frost & Sullivan for the Automotive Refrigeration Products Institute, September 2006. 

Personal communication. Rick Raborn, Sexton Can Company. 

Atkinson, W., “Emissions from Refrigerant Containers, EPA Study,” SAE 7th Alternate Refrigerant 

Systems Symposium, Scottsdale, AZ, June, 2006. 

 “Reducing Global Warming Emissions...while still enabling motorists to work on their car’s air 

conditioner.” Working presentation to CARB and EPA by ARPI, Dec. 13, 2006, Sacramento, CA.