MEMORANDUM 

To: Debbie Ottinger, EPA

CC: Don Wuebbles, University of Illinois

From: Mollie Averyt, Becky Ferenchiak, Mark Flugge, and Kasey Knoell, ICF

Date: November 24, 2014

Re: Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

(Revised November, 2014) 

This revised memorandum presents an updated summary of an ICF analysis to develop default Global 

Warming Potentials (GWPs) for fluorinated compounds without peer-reviewed GWPs. These default 

GWPs have been evaluated for inclusion in the final rule, “Greenhouse Gas Reporting Program: Addition 

of Global Warming Potentials to the General Provisions and Amendments and Confidentiality 

Determinations for Fluorinated Gas Production” (EPA Docket No. EPA-HQ-OAR-2009-0927, hereinafter 

referred to as “Final Rule to Add GWPs and Amend Subpart L”). The purpose of the analysis is to: 

1. Consider which sets of compounds should be used as the basis for default GWPs for the 

different groups of fluorinated GHGs whose GWPs do not appear on Table A-1, 

2. Calculate the average and the standard deviation of the GWPs for these groups, and 

3. Suggest possible default GWPs by rounding the average for each group to one or two significant 

figures. 

This analysis builds on two previous analyses prepared for the proposed rules, “Greenhouse Gas 

Reporting Program: Amendments and Confidentiality Determinations for Fluorinated Gas Production” 

(hereinafter referred to as “Proposed Amendments to Subpart L”), published on November 19, 2013 (78 

FR 69337), and “Greenhouse Gas Reporting Program: Addition of Global Warming Potentials” 

(hereinafter referred to as “Proposed Rule to Add GWPs”), published on July 31, 2014 (79 FR 44332). 

Those analyses were respectively entitled Analysis of Potential Default GWPs for Fluorinated GHGs 

Reported Under the GHGRP, and Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under 

the GHGRP (Revised July, 2014). They are available in EPA Docket No. EPA-HQ-OAR-2009-0927. The 

second analysis included consideration of the comments received on the GWP-related provisions of the 

Proposed Amendments to Subpart L; this analysis adds consideration of the comments received on the 

Proposed Rule to Add GWPs. 

The remainder of this memorandum is organized into the following sections: 

I. Summary 

II. Analysis Method for Determining Default GWP Groups 

III. Comparison between Defaults and Estimated GWPs for Several F-GHGs 

IV. Evaluation of Analysis Method by Dr. Wuebbles and Recommendations 

V. Revisions to the Proposed Chemical-Specific and Default GWPs 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 2

VI. References 

Appendix A: F-GHGs by Fluorinated GHG Group

The complete results of the analysis are contained in the spreadsheet “Default GWP Chemical 

Groups_11-24-2014.xlsx.” 

Please contact Mollie Averyt at 202-862-1569 (mollie.averyt@icfi.com) with any questions or comments. 

I. Summary 

Through the Greenhouse Gas Reporting Program (GHGRP), the U.S. Environmental Protection Agency 

(EPA) receives reports of emissions of numerous fluorinated greenhouse gases (GHGs) and heat transfer 

fluids (HTFs) that do not have GWPs listed on Table A-1, the GHGRP’s compendium of GWPs. EPA is 

adding chemical-specific and default GWPs to Table A-1 to address this situation. Specifically, EPA is

adding approximately 100 chemical-specific GWPs published by the Intergovernmental Panel on Climate 

Change (IPCC) in their Fifth Assessment Report (AR5) (Myhre et al. 2013) in the fall of 2013. For the 

fluorinated GHGs and HTFs reported under the GHGRP that do not have chemical-specific GWPs in 

either Table A-1 or AR5, EPA is adding default GWPs. These default GWPs will be assigned based on the 

fluorinated GHG group to which the fluorinated GHG and HTF belongs, based on chemical structure. 

Default GWPs will ensure that the atmospheric impacts of all fluorinated GHGs and HTFs are reflected in 

facility calculations and carbon dioxide equivalent (CO2e) emissions totals. 

In developing the fluorinated GHG groups and associated default GWPs, the goal is to model the GWPs 

of compounds that belong to each group (but whose GWPs are not on Table A-1) with as much accuracy 

and precision as possible. EPA is applying the following criteria to assess potential compound groups:

(1) Collectively, the compound groups should span the full range of atmospheric behavior (atmospheric 

lifetimes and GWPs) observed among fluorinated GHGs, (2) within each compound group, the 

compounds should be chemically similar and exhibit similar atmospheric behavior, and (3) compounds 

whose atmospheric behavior is likely to be different from that of any of the compounds whose GWPs 

are being modeled should be excluded from the calculation. However, numerical outliers should be 

included in the calculation when the possibility exists that such outliers may also occur among the 

fluorinated GHGs whose GWPs are being modeled. 

As noted above, ICF previously performed two analyses based on these criteria to develop default 

GWPs. As shown in Table 1, the first set of default GWPs based on five fluorinated GHG groups was 

proposed in the Proposed Amendments to Subpart L for purposes of reporting emissions under subpart 

L. 

Table 1. Fluorinated GHG Groups and Associated Default GWPs in Proposed Amendments to Subpart L 

Fluorinated GHG Group 

GWP in Proposed 

Amendments to 

Subpart L (100-yr) 

Average 

GWP 

Standard 

Deviation 

of GWP 

Fully fluorinated GHGs 10,000 9,857 3,450 

Saturated hydrofluorocarbons (HFCs) 2,200 2,187 3,346 

Saturated hydrofluoroethers (HFEs) and saturated 

hydrochlorofluoroethers (HCFEs)a

1,600 1,536 2,536 

Unsaturated perfluorocarbons (PFCs), unsaturated HFCs, 

unsaturated hydrochlorofluorocarbons (HCFCs), unsaturated 

HFEs, and fluorinated ketones 

1 0.42 0.62 

Other fluorinated GHGsb 100 112 177 

a

 The average GWP and standard deviation for this group were revised from 1,559 and 2,551, respectively, after including 2-

Chloro-1,1,2-trifluoro-1-methoxyethane, which was previously miscategorized in “Other fluorinated GHGs.” 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 3

b

 The average GWP and standard deviation for this group were revised from 103 and 183, respectively, after removing 

fluorotelomer alcohols and fluorinated aldehydes, which were previously categorized in “Other fluorinated GHGs,” which at the 

time was the most appropriate category. 

For this set of default GWPs as well as subsequent sets, EPA based the proposed default GWPs on the 

average of the chemical-specific GWPs of chemicals that belonged to that group and that were either on

Table A-1 or are proposed to be added to Table A-1 under the Proposed Rule to Add GWPs. The 

fluorinated GHG groups have consistently been based primarily on chemical structure, which is 

correlated with atmospheric lifetime and GWP. 

As discussed in the Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP 

(Revised July, 2014), three commenters, DuPont, 3M, and the American Chemistry Council (ACC) 

provided comments regarding the chemical groups and associated GWPs of fluorinated gases in the 

Proposed Amendments to Subpart L. The commenters requested that EPA split the third group 

(saturated HFEs and saturated HCFEs) into two, expand the fourth group (unsaturated PFCs, unsaturated 

HFCs, unsaturated HCFCs, unsaturated HFEs, and fluorinated ketones), and add two additional groups, 

fluorotelomer alcohols and fluorinated GHGs with carbon-iodine bonds, to increase the precision and 

accuracy of the default GWPs applied to the chemicals in these groups. Two commenters also 

suggested separating compounds with GWPs near 10 (e.g., fluorinated alcohols other than 

fluorotelomer alcohols) from the remainder of the “other” category. 

These comments were reviewed and the fluorinated GHG groups and associated default GWPs were 

reevaluated for the Proposed Rule to Add GWPs. A brief summary and analysis of the GWP-related 

comments on the Proposed Amendments to Subpart L can be found in the Revised Analysis of Default 

GWPs for Fluorinated GHGs Reported Under the GHGRP (Revised July, 2014). A detailed summary and 

response to all the comments on the Proposed Amendments to Subpart L is included in docket number 

EPA-HQ-OAR-2009-0927. 

In the Proposed Rule to Add GWPs, EPA proposed eight default GWP values based on fluorinated GHG 

groups. These default GWPs were proposed to be added to Table A-1 and to apply to fluorinated GHGs 

and HTFs not otherwise listed on Table A-1. The proposed fluorinated GHG groups are listed in Table 2,

below. 

Table 2. Fluorinated GHG Groups and Associated Default GWPs for Proposed Rule to Add GWPs 

Fluorinated GHG Group 

GWP in Proposed Rule to 

Add GWPs 

(100-year) 

Fully fluorinated GHGs 10,000 

Saturated hydrofluorocarbons (HFCs) 2,200 

Non-segregated saturated hydrofluoroethers (HFEs) 

Non-segregated saturated hydrochlorofluoroethers (HCFEs) 2,400 

Partially segregated saturated hydrofluoroethers (HFEs) 

Partially segregated saturated hydrochlorofluoroethers (HCFEs) 200 

Unsaturated perfluorocarbons (PFCs) 

Unsaturated HFCs and HCFCs 

Unsaturated halogenated ethers 

Unsaturated halogenated esters 

Fluorinated ketones 

Fluorinated aldehydes 

1 

Fluorotelomer alcohols 1 

Fluorinated GHGs with one or more carbon-iodine bond 1 

Other fluorinated GHGs 110 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 4

In response to comments received on the Proposed Rule to Add GWPs, EPA is making additional changes 

to the default GWPs for the Final Rule to Add GWPs. First, the group of saturated HFCs is being divided 

into two groups based on the number of carbon-hydrogen bonds in the compound (i.e., two or fewer 

carbon-hydrogen bonds and three or more carbon-hydrogen bonds). Second, the group of saturated 

HFEs and HCFEs is being divided into three groups based on the number of carbon-hydrogen bonds in 

the compound (i.e., one carbon-hydrogen bond, two carbon-hydrogen bonds, and three or more 

carbon-hydrogen bonds) rather than two groups based on the position of the fluorine atoms in the 

compound (segregated vs. partially segregated). Third, the proposed “other” category is being divided 

into three groups: (1) Fluorinated acetates, carbonofluoridates, and fluorinated alcohols other than 

fluorotelomer alcohols, (2) fluorinated formates, and (3) other fluorinated GHGs and HTFs. The details of 

this revised analysis are summarized in Section V.

II. Analysis Method for Determining Default GWP Groups 

In order to establish different compound groups and evaluate potential default GWPs for each group, 

ICF analyzed the chemical structure, GWPs, and atmospheric lifetimes of the fluorinated GHGs with 

peer-reviewed GWPs. The F-GHGs with peer-reviewed GWPs include the compounds on Table A-1 and 

the compounds in AR5. As noted above, ICF also considered the comments on the Proposed 

Amendments to Subpart L and on the Proposed Rule to Add GWPs. 

Ninety seven F-GHGs from AR5 and one F-GHG from the IPCC Fourth Assessment Report (AR4) (Forster 

et al. 2007) (i.e., 98 F-GHGs in total) that are not included in the current Table A-1 are included in the 

current analysis. For compounds that are included in the current Table A-1, ICF used the GWPs from 

Table A-1 as they were updated in the “2013 Revisions to the Greenhouse Gas Reporting Rule and 

Proposed Confidentiality Determinations for New or Substantially Revised Data Elements; Final Rule” (78 

FR 71904; November 3, 2013), with the exception of sevoflurane, for which the AR5 GWP was used. For 

compounds that are included only in AR5, ICF used the GWP from AR5 in the analysis, with the 

exception of several very short-lived compounds whose GWPs were listed in AR5 as “<1.” In order to 

increase the accuracy of the default GWP analysis, precise GWPs were calculated and used in this 

analysis for these compounds using the atmospheric lifetime and the corrected radiative efficiency 

provided in the AR5. 

The current analysis focuses on 12 main model groups (Table 3). The details of this revised analysis are 

summarized in Section V. As was the case for the fluorinated GHG groups included in the Proposed 

Amendments to Subpart L and in the Proposed Rule to Add GWPs, these groups exclude compounds 

that are chemically different (i.e., that are not fluorocarbons and are therefore chemical outliers) from 

the compounds whose GWPs are being modeled, but they include compounds whose GWPs are 

unusually high or low (i.e., numerical outliers). Also like the fluorinated GHG groups included in the

Proposed Amendments to Subpart L and the Proposed Rule to Add GWPs, the groups include chemically 

similar chlorine-containing compounds that are defined as fluorinated GHGs (i.e., are not regulated as

ozone-depleting compounds under 40 CFR part 82). 

The average and standard deviation of the GWPs of the compounds within each model group were 

calculated. The suggested GWP for each model group is equal to the average GWP of the F-GHGs within 

that model group, rounded to either one or two significant figures. 

Table 3 presents the fluorinated GHG groups with the corresponding average, standard deviation, and 

relative standard deviation of the GWPs for each group. As can be seen by comparing Table 3 to Table 1, 

the additions and changes to the fluorinated GHG groups that were included in the Proposed 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 5

Amendments to Subpart L are likely to improve the accuracy and precision of the default GWPs. This 

improvement is driven by the relationship between the structural criteria used to break out the new 

groups (and subgroups) and atmospheric lifetime. As discussed further in the Revised Analysis of Default 

GWPs for Fluorinated GHGs Reported Under the GHGRP (Revised July, 2014) and in the Analysis of 

Atmospheric Lifetimes, Radiative Efficiencies, and Global Warming Potentials of Saturated 

Hydrofluoroethers by Number of Carbon-Hydrogen and Carbon-Fluorine Bonds (both available in Docket 

EPA-HQ-OAR-2009-0927), atmospheric lifetime is the key factor in determining the 100-year GWPs of 

most fluorinated GHGs.1

Table 3. Average, Standard Deviation, and Relative Standard Deviation of GWPs of Fluorinated GHG 

Groups 

Fluorinated GHG Group Default 

GWP 

Average 

GWP 

Standard 

Deviation 

Relative 

Standard 

Deviation 

Number 

of 

Chemicals 

in Group 

Fully fluorinated GHGs and HTFs 10,000 9,857 3,450 35% 15 

Saturated hydrofluorocarbons (HFCs) with two or 

fewer carbon-hydrogen bonds 3,700 3,657 4,264 117% 12 

Saturated hydrofluorocarbons (HFCs) with three 

or more carbon-hydrogen bonds 930 928 1,563 169% 14 

Saturated HFEs and HCFEs with one carbonhydrogen bond 5,700 5,680 5,629 99% 5 

Saturated HFEs and HCFEs with two carbonhydrogen bonds 2,600 2,616 2,155 82% 19 

Saturated HFEs and HCFEs with three or more 

carbon-hydrogen bonds 270 267 255 96% 36 

Fluorinated formates 350 349 178 51% 8 

Fluorinated acetates, carbonofluoridates, and 

fluorinated alcohols other than fluorotelomer 

alcohols 

30 29 45 154% 22 

Unsaturated PFCs 1 0.66 0.96 146% 6 

Unsaturated HFCs and unsaturated HCFCs 1 0.38 0.51 134% 14 

Unsaturated halogenated ethers 1 0.11 - - 2 

Unsaturated halogenated esters 1 N/A N/A N/A 0 

Fluorinated ketones 1 0.11 - - 1 

Fluorinated aldehydes 1 0.01 - - 1 

Fluorotelomer alcohols 1 0.32 0.10 31% 4 

Fluorinated GHGs with one or more carbon-iodine 

bonds 1 0.4 - - 1 

Other fluorinated GHGs and HTFs 2,000 2,050 4,042 197% 164a

N/A = Not available 

a

 The default GWP for the “other fluorinated GHGs and HTFs” group is based on the average GWP of all the compound on Table 

A-1 and those proposed to be added to Table A-1. 

 

1

 The partial exception to this rule is the group of fully fluorinated GHGs. While the long atmospheric lifetimes of fully 

fluorinated GHGs give this group the highest average GWP of any group, those lifetimes are so long that differences between 

the lifetimes have relatively little impact on the differences between the 100-year GWPs of the fully fluorinated GHGs. Whether 

a fully fluorinated GHG has an atmospheric lifetime of 1,000 years or 2,000 years, most emissions of that gas will still remain in 

the atmosphere after 100 years. 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 6

In addition, potential default GWPs for the fluorinated GHG groups were developed by also evaluating 

GWPs of the F-GHGs from AR5 only. This analysis can be found in the Revised Analysis of Default GWPs 

for Fluorinated GHGs Reported Under the GHGRP (Revised July, 2014). 

Figure 1 below is a semi-log histogram that illustrates the number of chemicals in each F-GHG group or

subgroup whose GWPs fall within different orders of magnitude. The left-most bar represents the 

number of compounds with GWPs between 0.001 and 0.01; the second bar represents compounds with 

GWPs between 0.01 and 0.1; etc.
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 7

Figure 1. Histogram of F-GHG Group and Subgroup GWPs 

05

101520253035404550

0.001 to

0.01

0.01 to 0.1 0.1 to 1 1 to 10 10 to 100 100 to

1,000

1,000 to

10,000

10,000

and above

GWP

Fully Fluorinated GHGsSaturated HFCs with 2 or fewer Saturated HFCs with 3 or more Saturated HFEs and HCFEs with bondSaturated HFEs and HCFEs with bondsSaturated HFEs and HCFEs with hydrogen bondsFluorinated formatesFluorinated acetates, carbonoffluorinated alcohols other than Unsaturated PFCsUnsaturated HFCs and HCFCsUnsaturated Halogenated EtheUnsaturated Halogenated EsterFluorinated KetonesFluorinated AldehydesFluorotelomer AlcoholsCompounds including one or m
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 8

III. Comparison between Defaults and Estimated GWPs for Several 

F-GHGs 

ICF tested the accuracy of the default GWPs based on chemical groups by comparing the default GWPs 

to: (1) The GWPs of F-GHGs with documented (but not peer-reviewed) GWPs provided by 3M and made 

available for comment through the April 5, 2013 Notice of Data Availability (NODA) (78 FR 20632) (Table 

4) and (2) the GWPs of F-GHGs with documented (but not peer-reviewed) GWPs in the Proposed 2013 

Revisions rule (Table 5). Chemical-specific GWPs for these fluorinated GHGs are not included in the Final 

Rule to Add GWPs. 

In Table 4, eight compounds with documented GWPs provided by 3M were categorized into the 

fluorinated GHG groups and assigned a default GWP: 

• The first six compounds would be assigned to the “fully fluorinated GHGs and HTFs” group and 

have an average GWP of 9,452. This average GWP is similar to the suggested default GWP for 

“fully fluorinated GHGs and HTFs”, which is equal to 10,000. 

• The remaining two compounds provided by 3M, HFE-7300 and HFE-7500, have an average GWP 

of 205. Both HFE-7300 and HFE-7500 are saturated HFEs with three or more carbon-hydrogen 

bonds and have atmospheric lifetimes of 3.8 and 2.2 years, respectively. Therefore, these two 

compounds could be assigned to the saturated HFEs and HCFEs with three or more carbonhydrogen bonds, which has a suggested default GWP of 270. 

Table 4. 3M Company Fluorinated GHGs GWPs and Default GWP Comparison 

Potential Fluorinated GHG 

Group 

Chemical Designation or Common 

Name 

Chemical 

Formula 

3M 

Submitted 

GWP 

Default 

GWP 

Fully fluorinated GHGs and HTFs Perfluorotripropyl amine (PTPA) C9F21N 8,690 10,000 

Fully fluorinated GHGs and HTFs Perfluorotributyl amine (PTBA) C12F27N 9,020 10,000 

Fully fluorinated GHGs and HTFs Perfluorotriamyl amine (PTAA) C15F33N 8,900 10,000 

Fully fluorinated GHGs and HTFs Perfluoromethyl morpholine (PMM) C5F11NO 9,500 10,000 

Fully fluorinated GHGs and HTFs Perfluoroisopropyl morpholine (PIPM) C7F15NO 11,000 10,000 

Fully fluorinated GHGs and HTFs 2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9-

hexadecafluorooxonane 

C8F16O 9,600 10,000 

Saturated HFEs and HCFEs with 

three or more carbon-hydrogen 

bonds 

1,1,1,2,2,3,4,5,5,5-decafluoro-3-

methoxy-4-trifluoromethyl-pentane 

(HFE-7300) 

C7H3F13O 310 270 

Saturated HFEs and HCFEs with 

three or more carbon-hydrogen 

bonds 

3-ethoxy-1,1,1,2,3,4,4,5,5,6,6,6-

dodecafluoro-2-trifluoromethyl-hexane 

(HFE-7500) 

C9H5F15O 100 270 

As shown in Table 5, eleven compounds with documented (but not peer-reviewed) GWPs in the 

Proposed 2013 Revisions Rule that are not included in the Final Rule to Add GWPs were also categorized

into the fluorinated GHG groups and assigned a default GWP: 

• Two of the compounds that would be categorized as “unsaturated halogenated ethers”, which 

both had estimated GWPs of 3, would be assigned a default GWP of 1. 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 9

• Six of the compounds that would be categorized as “fluorinated GHGs with one or more carboniodine bonds”, whose average estimated GWP was 2.3, would be assigned a default GWP of 1. 

• The GWP for 1H,1H,2H,2H-perfluorohexan-1-ol (42–AL) was listed as 2 in the Proposed 2013 

Revisions Rule; this compound would be categorized as a “fluorotelomer alcohol” and assigned a 

default GWP of 1. 

• The GWP for FK–6–1–12 was listed as 1 in the Proposed 2013 Revisions Rule and this compound 

would be categorized as a “fluorinated ketone” and assigned a default GWP of 1. 

• The GWP for carbonyl fluoride was listed as 2 in the 2013 Revisions Rule; this compound would 

be categorized as an “other fluorinated GHGs and HTFs” and assigned a default GWP of 2,000. 

With the exception of the default GWP for carbonyl fluoride, the default GWPs assigned to these 

compounds are quite close to their previously estimated GWPs. The defaults for the unsaturated 

compounds, fluorotelomer alcohols, and compounds with carbon-iodine bonds are lower than the 

previously estimated GWPs for these compounds because the defaults reflect corrections made to the 

radiative efficiencies of these compounds in AR5. These corrections lower the radiative efficiencies to 

account for the fact that the compounds are very short-lived and are therefore not well-mixed in the 

atmosphere. 

Table 5. Fluorinated GHG GWPs in Proposed 2013 Revisions Rule Not Included in Final Rule 

Potential Fluorinated GHG 

Group 

Chemical Designation or 

Common Name Chemical Formula Proposed GWP 

Default 

GWP 

Unsaturated halogenated ethers Perfluoropropyl vinyl ether C5F10O 3 1 

Unsaturated halogenated ethers Perfluoroethyl vinyl ether C4F8O 3 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds Perfluorethyl iodide (2–I) C2F5I 3 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds 

Perfluorbutyl iodide (PFBI, 

42–I) C4F9I 3 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds Perfluorhexyl iodide (6–I) CF3CF2CF2CF2CF2CF2IC

6F13I 2 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds Perfluoroctyl iodide (8–I) C8F17I 2 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds 

1,1,1,2,2-pentafluoro-4-

iodo butane (22–I) C4H4F5I 2 1 

Fluorinated GHGs with one or 

more carbon-iodine bonds 

1,1,1,2,2,3,3,4,4-

nonafluoro-6-iodo hexane 

(42– I) 

C6H4F9I 2 1 

Fluorotelomer alcohols 

1H,1H, 2H,2Hperfluorohexan-1-ol (42–

AL) 

C6H5F9O 5 1 

Fluorinated ketones FK–6–1–12/NovecTM 774, 

C7 Fluoroketone 

C7F14O Chemical 

Blend 1 1 

Other fluorinated GHGs and 

HTFs Carbonyl fluoride COF2 2 2,000 

IV. Evaluation of Analysis Method by Dr. Wuebbles and 

Recommendations 

Dr. Donald J. Wuebbles evaluated the overall approach of assigning a default GWP to target compounds 

from certain compound groups based on the average GWP of similar “model” groups of compounds, 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 10

and noted that although there are significant uncertainties associated with this approach due to the 

range of GWPs observed within each group of model compounds, this may be the most viable option for 

EPA based on the available information and time constraints. Dr. Wuebbles recommended developing a 

technique for assigning default GWPs based on modeling, or by developing a default estimate based on 

the relative amounts of fluorine, chlorine, and hydrogen in each compound. Both techniques would 

require additional research, and the technique based on modeling would be a major research effort. 

Dr. Wuebbles also suggested considering compounds with double carbon-carbon bonds (which are 

expected to all have short lifetimes) as a potential model group. Based on this suggestion, a model 

group consisting of separate sub-groups for unsaturated PFCs, HFCs and HCFCs, halogenated ethers, and 

halogenated esters was developed.2 Dr. Wuebbles also noted that the IPCC process for developing 

Assessment Reports (e.g., AR4) is not designed to be the sole arbiter of “official” GWP values, and other 

sources of published (i.e., peer-reviewed) literature (e.g., WMO 2010) should be considered when 

establishing default GWP estimates. In addition, as a result of this discussion, numerical outliers are not 

excluded when calculating the suggested (i.e., average) model group GWP, since the GWPs for unknown 

target compounds might equally be outliers themselves. 

Dr. Wuebbles also reviewed the comments that were received on the Proposed Amendments to 

Subpart L. Dr. Wuebbles agreed with the analyses conducted by DuPont because their suggestions are 

well-defined from a physical chemistry standpoint and also because Hodnebrog et al. 2013 is the proper

source to use for such analyses as is it the basis for the GWPs presented in AR5. Dr. Wuebbles also noted 

that 3M’s suggestion to use the median GWP of a group of compounds (i.e., saturated HFEs) to assign a 

default GWP for that particular group is inappropriate, as the compounds with very high GWPs would be 

assigned a much smaller GWP value. 

 

2

 During a conference call on May 9, 2013 between ICF, EPA, and Dr. Wuebbles to have an intermediary discussion regarding 

the default GWP analysis, Dr. Wuebbles communicated that compounds with a lifetime greater than 1 year should be 

considered long-lived regardless of their corresponding GWP.
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 11

V. Revisions to the Proposed Chemical-Specific and Default GWPs 

EPA is finalizing the addition of both chemical-specific and default GWPs following consideration of 

comments submitted on the Proposed Rule to Add GWPs, which were received during the comment 

period that ended on September 2, 2014. This section summarizes those comments and revisions that 

were made to the rule in response to the comments received. 

a. Duplicate Compounds on Table A-1 

One commenter observed that the proposed chemical-specific GWPs in Table A-1 included some 

duplicate compounds with different GWPs. In the final Table A-1, five duplicate compounds were 

removed. Two sets of duplicates resulted from the inadvertent proposed addition to Table A-1 of a GWP 

for a compound that already had a GWP listed. These included two fluorinated alcohols with the CAS 

numbers 422–05–9 and 920–66–1. In these cases, the previously listed GWPs, based on AR4, are 

retained. Three sets of duplicates came from AR5. These included two HFEs and one fluorinated alcohol 

with the CAS numbers 173350–37–3, 205367–61–9, and 375–01–9, respectively. In these cases, the 

average of the two GWPs was used, because the superiority of one GWP source over the other could not 

be determined. 

b. Default GWP Groups 

Three changes to the proposed fluorinated GHG groups and default GWPs were made. These changes 

result in the creation of four additional fluorinated GHG groups and default GWPs, increasing the total 

number of default GWPs from eight to twelve. All of the changes are expected to increase the accuracy 

and precision of the default GWPs. 

First, the group of saturated HFCs is being divided into two groups based on the number of carbonhydrogen bonds in the compound. Second, the group of saturated HFEs and HCFEs is being divided into 

three groups based on the number of carbon-hydrogen bonds in the compound rather than two groups 

based on the position of the fluorine atoms in the compound (segregated vs. partially segregated). The

number of carbon-hydrogen bonds in each saturated HFC and HFE (and HCFE) is significantly correlated 

(negatively) with the atmospheric lifetime and GWP of that compound. For the saturated HFEs, the 

number of carbon-hydrogen bonds predicts the GWP more precisely than does the position of the 

fluorine atoms in the compound. Moreover, the number of carbon-hydrogen bonds in each compound is 

likely to be known, facilitating the correct categorization and default GWP selection for each saturated 

HFC or HFE that does not have a chemical-specific GWP on Table A-1. This structure clearly establishes

groups of saturated HFCs and HFEs that have similar GWPs and sets considerably more precise default 

GWPs for these groups. 

Finally, the proposed “other” category is being divided into three groups: 

(1) Fluorinated acetates, carbonofluoridates, and fluorinated alcohols other than fluorotelomer 

alcohols, 

(2) Fluorinated formates, and 

(3) Other fluorinated GHGs and HTFs. 

A previous analysis, described in more detail in Appendix D, Part i, of Revised Analysis of Default GWPs 

for Fluorinated GHGs Reported Under the GHGRP (Revised July, 2014), indicated that the fluorinated 

formates had significantly higher GWPs than most of the other specific compound types in the “other” 

group. The average GWP for the formates is about 350 while the average GWP for the other compounds 

comprising the “other” group is 30. Based on suggestions received from commenters to separate the 

“other” group into different categories because of the relatively large range of GWPs included in the 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 12

group, the Final Rule to Add GWPs is separating the specific compound types that were formerly in the 

“other” category into two groups. A default GWP of 350 is established for fluorinated formates, while a 

default of 30 is established for fluorinated acetates, carbonofluoridates, and fluorinated alcohols other 

than fluorotelomer alcohols. This approach establishes default GWPs that better reflect the average 

GWPs of both of the new, smaller groups. The new default GWPs differ by more than an order of 

magnitude, considerably increasing their precision for their respective groups. 

Finally, a separate group for fluorinated GHGs that do not fall into any of the specific fluorinated GHG 

groups is being established and assigned a default GWP of 2,000, which is based on the average for all

fluorinated GHGs. This “catch-all” group, which retains the title “Other fluorinated GHGs and HTFs,” 

includes types of fluorinated GHGs and HTFs whose GWPs have not been studied. A default GWP of 

2,000 more appropriately represents such fluorinated GHGs than the previously proposed GWP of 110, 

which was based on the GWP values for a small, potentially unrepresentative subset of fluorinated 

GHGs (i.e., fluorinated acetates, fluoridates, fluorinated alcohols other than fluorotelomer alcohols, and 

fluorinated formates). Where the GWPs of particular fluorinated GHG groups have not been published 

in the peer-reviewed literature, it is likely they may fall anywhere on the continuum of GWPs measured

for the fluorinated GHGs in this analysis. Therefore, a default GWP of 2,000 will be used for any 

fluorinated GHG that cannot be categorized in any of the default GWP groups and/or whose GWP is not 

on Table A-1. 

VI. References 

Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, 

G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007. Changes in Atmospheric 

Constituents and in Radiative Forcing. In: 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. 

Hodnebrog, O. et al. 2013. Global Warming Potentials and Radiative Efficiencies of Halocarbons and 

Related Compounds: A Comprehensive Review. Reviews of Geophysics, 51. 

Myhre, G., D. Shindell, F.A. Breon, W. Collins, J. Fuglestvedt, J. Huang, D. Koch, J.-F. Lamarque, D. Lee, B. 

Mendoza, T. Nakajima, A. Robock, G. Stephens, T. Takemura and H. Zhang, 2013: Anthropogenic and 

Natural Radiative Forcing. In: Climate Change 2013: The Physical Basis. Contribution of Working Group I

to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, 

G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. 

Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 

Wuebbles, Don. 2014. Transcribed Correspondence with Don Weubbles on March 14, 2014. 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 13

Appendix A: F-GHGs by Fluorinated GHG Group 

Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

Fully fluorinated GHGs 

PFPMIE perfluoropolymethylisopropyl ether 69991-67-9 CF3OCF(CF3)CF2OCF2OCF3 10,300 

PFC–14 Perfluoromethane 75–73–0 CF4 7,390 

PFC–9–1–18 Perfluorodecalin (mixed) 306–94–5 C10F18 7,500 

PFC–218 Perfluoropropane 76–19–7 C3F8 8,830 

PFC–3–1–10 Perfluorobutane 355–25–9 C4F10 8,860 PFC–4–1–12 Perfluoropentane 678–26–2 C5F12 9,160 PFC–5–1–14 Tetradecafluorohexane 355–42–0 C6F14 9,300 

PFC-6-1-12 Hexadecafluoroheptane 335-57-9 C7F16, CF3(CF2)5CF3 7,820 PFC-7-1-18 Octadecafluorooctane 307-34-6 C8F18, CF3(CF2)6CF3 7,620 

PFC-318 Perfluorocyclobutane 115–25–3 c-C4F8 10,300 

PFC–116 Perfluoroethane 76–16–4 C2F6 12,200 

PFC–c216 Perfluorocyclopropane 931–91–9 c-C3F6 17,340 

 Perfluorodecalin (cis) 60433-11-6 cis-C10F18 7,240  Perfluorodecalin (trans) 60433-12-7 trans-C10F18 6,290  Trifluoromethyl sulphur pentafluoride 373–80–8 SF5CF3 17,700 

Saturated HFCs with two or fewer carbon-hydrogen bonds 

HFC-227ca 1,1,1,2,2,3,3-Heptafluoropropane 2252-84-8 CF3CF2CHF2 2,640 

HFC–125 354–33–6 CHF2CF3 3,500 

HFC-329p 1,1,1,2,2,3,3,4,4-Nonafluorobutane 375-17-7 CHF2CF2CF2CF3 2,360 

HFC–227ea 431–89–0 C3HF7 3,220 

HFC–23 75–46–7 CHF3 14,800 

HFC–43–10mee 138495–42–8 CF3CFHCFHCF2CF3 1,640 

HFC–134 359–35–3 CHF2CHF2 1,100 

HFC–236ea 431–63–0 CHF2CHFCF3 1,370 

HFC–236cb 677–56–5 CH2FCF2CF3 1,340 

HFC–236fa 690–39–1 C3H2F6 9,810 

HFC–32 75–10–5 CH2F2 675 

HFC–134a 811–97–2 CH2FCF3 1,430 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

Saturated HFCs with three or more carbon-hydrogen bonds 

HFC-245cb 1,1,1,2,2-Pentafluoropropane 1814-88-6 CF3CF2CH3 4,620 

HFC-245ea 1,1,2,3,3-Pentafluoropropane 24270-66-4 CHF2CHFCHF2 235 

HFC–143a 420–46–2 C2H3F3 4,470 

HFC–143 430–66–0 C2H3F3 353 

HFC-245eb 1,1,1,2,3-Pentafluoropropane 431-31-2 CH2FCHFCF3 290 

HFC–245fa 460–73–1 CHF2CH2CF3 1,030 

HFC–41 593–53–3 CH3F 92 

HFC–245ca 679–86–7 C3H3F5 693 

HFC–152 624–72–6 CH2FCH2F 53 

HFC–152a 75–37–6 CH3CHF2 124 

HFC–161 353–36–6 CH3CH2F 12 

HFC–365mfc 406–58–6 CH3CF2CH2CF3 794 

HFC-263fb 1,1,1-Trifluoropropane 421-07-8 CH3CH2CF3 76 

HFC-272ca 2,2-Difluoropropane 420-45-1 CH3CF2CH3 144 

Saturated HFEs and HCFEs with one carbon-hydrogen bond 

HFE–329mcc2 1,1,1,2,2-Pentafluoro-2-(1,1,2,2-tetrafluoroethoxy)ethane 134769-21-4 CHF2CF2OCF2CF3 919 

HFE–227ea 2356–62–9 CF3CHFOCF3 1,540 

1,1,1,2,2,3,3-Heptafluoro-3-(1,2,2,2-tetrafluoroethoxy)-

propane 3330-15-2 CF3CF2CF2OCHFCF3 6,490 

HFE–125 (difluoromethoxy)(trifluoro)methane 3822–68–2 CHF2OCF3 14,900 

HFE-329me3 1,1,1,2,3,3-Hexafluoro-3-(trifluoromethoxy)propane 428454-68-6 CF3CFHCF2OCF3 4,550 

Saturated HFEs and HCFEs with two carbon-hydrogen bonds 

HCFE-235ca2 

(enflurane) 2-Chloro-1-(difluoromethoxy)-1,1,2-trifluoroethane 13838-16-9 CHF2OCF2CHFCl 583 

HFE–338mcf2 1,1,1,2,2-Pentafluoro-2-(2,2,2-trifluoroethoxy)ethane 156053-88-2 CF3CH2OCF2CF3 552 

HFE–134 1691–17–4 CHF2OCHF2 6,320 

HG-03 1,1,3,3,4,4,6,6,7,7,9,9,10,10,12,12-Hexadecafluoro- 2,5,8,11-tetraoxadodecane 173350-37-3 HF2C-(OCF2CF2)3-OCF2H 3,670 

1,1,3,3,4,4,6,6,7,7,9,9,10,10,12,12,13,13,15,15-

eicosafluoro-2,5,8,11,14-Pentaoxapentadecane 173350-38-4 HCF2O(CF2CF2O)4CF2H 3,630 

HG-30 1,1,3,3,5,5,7,7,9,9-Decafluoro-2,4,6,8-tetraoxanonane 188690-77-9 HF2C-(OCF2)3-OCF2H 7,330 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

HFE–338pcc13 

(HG–01) 1,2-Bis(difluoromethoxy)-1,1,2,2-tetrafluoroethane 188690–78–0 CHF2OCF2CF2OCHF2 1,500 

HFE–236fa 1,1,1-Trifluoro-2-(trifluoromethoxy)ethane 20193–67–3 CF3CH2OCF3 487 

HG-02 1-(Difluoromethoxy)-2-(2-(difluoromethoxy)-1,1,2,2- tetrafluoroethoxy)-1,1,2,2-tetrafluoroethane 205367-61-9 HF2C-(OCF2CF2)2-OCF2H 3,825 

 Trifluoro(fluoromethoxy)methane 2261-01-0 CH2FOCF3 751 

HG-20 (Difluoromethoxy)((difluoromethoxy)difluoromethoxy)diflu oromethane 249932-25-0 HF2C-(OCF2)2-OCF2H 5,300 HG-21 1,1,3,3,5,5,7,7,8,8,10,10-Dodecafluoro-2,4,6,9- tetraoxadecane 249932-26-1 HF2C- OCF2CF2OCF2OCF2O- CF2H 3,890 

HFE–338mmz1 2-(Difluoromethoxy)-1,1,1,3,3,3-hexafluoropropane 26103-08-2 (CF3)2CHOCHF2 380 

Isoflurane 

(HCFE–235da2) 2-chloro-2-(difluoromethoxy)-1,1,1-trifluoro-ethane 26675-46-7 C3H2ClF5O 350 

HFE-236ca 1-(Difluoromethoxy)-1,1,2,2-tetrafluoroethane 32778-11-3 CHF2OCF2CHF2 4,240 

Desflurane 

(HFE–236ea2) 2-(Difluoromethoxy)-1,1,1,2-tetrafluoroethane 57041-67-5 CHF2OCHFCF3 989 

HFE–236ca12 

(HG–10) Bis(difluoromethoxy)difluoromethane 78522-47-1 CHF2OCF2OCHF2 2,800 

 1,1,2-Trifluoro-2-(trifluoromethoxy)-ethane 84011-06-3 CHF2CHFOCF3 1,240 

HFE–43–10pccc 

(H–Galden 

1040x) 

1-(Difluoromethoxy)-2-

[(difluoromethoxy)(difluoro)methoxy]-1,1,2,2-

tetrafluoroethane 

E1730133 CHF2OCF2OC2F4OCHF2 1,870 

Saturated HFEs and HCFEs with three or more carbon-hydrogen bonds 

HFE-449sl, 

(HFE-7100) 

Isomer blend 

 163702–07–6 C4F9OCH3 297 

HFE–347pcf2 1,1,2,2-Tetrafluoro-1-(2,2,2-trifluoroethoxy)ethane 406-78-0 CHF2CF2OCH2CF3 580 

Sevoflurane 

(HFE-347mmz1) 2-(Difluoromethoxy)-1,1,1,3,3,3-hexafluoropropane 28523-86-6 (CF3)2CHOCH2F 216 

HFE–347mcf2 1-(2,2-Difluoroethoxy)-1,1,2,2,2-pentafluoroethane 171182-95-9 CHF2CH2OCF2CF3 374 

HFE–245fa2 2-(Difluoromethoxy)-1,1,1-trifluoroethane 1885-48-9 CHF2OCH2CF3 659 

HFE–347mmy1 1,1,1,2,3,3,3-Heptafluoro-2-methoxypropane 22052–84–2 CH3OCF(CF3)2 343 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

HFE–245cb2 1,1,1,2,2-Pentafluoro-2-methoxy-ethane 22410-44-2 CF3CF2OCH3 708 

HFE–347mcc3 Heptafluoropropyl methyl ether 375–03–1 CH3OCF2CF2CF3 575 

 1,1,2,2-Tetrafluoro-1-(fluoromethoxy)ethane 37031-31-5 CH2FOCF2CF2H 871 

HFE–143a trifluoromethoxymethane 421–14–7 CH3OCF3 756 

 Difluoro(fluoromethoxy)methane 461-63-2 CH2FOCHF2 617 

HFE–245fa1 1,1-Difluoro-2-(trifluoromethoxy)ethane 84011-15-4 CHF2CH2OCF3 286 

HFE–356mmz1 1,1,1,3,3,3-Hexafluoro-2-methoxypropane 13171-18-1 C4H4F6O 27 

HFE–356pcc3 1,1,2,2,3,3-Hexafluoro-1-methoxypropane 160620-20-2 CH3OCF2CF2CHF2 110 

HFE-356mff2 BIS(2,2,2-TRIFLUOROETHYL) ETHER 333-36-8 CF3CH2OCH2CF3 17 

HFE–356pcf3 3-(difluoromethoxy)-1,1,2,2-tetrafluoropropane 35042–99–0 CHF2OCH2CF2CHF2 502 

 Difluoro(methoxy)methane 359-15-9 CH3OCHF2 144 

HFE–356mec3 1,1,1,2,3,3-Hexafluoro-3-methoxypropane 382-34-3 CH3OCF2CHFCF3 101 

 2-Chloro-1,1,2-trifluoro-1-methoxyethane 425-87-6 CH3OCF2CHFCl 122 

HFE–254cb1 1,1,2,2-Tetrafluoro-1-methoxyethane 425-88-7 CH3OCF2CHF2 359 

 Fluoro(fluoromethoxy)methane 462-51-1 CH2FOCH2F 130 

HFE–356pcf2 1-(2,2-Difluoroethoxy)-1,1,2,2-tetrafluoroethane 50807-77-7 CHF2CH2OCF2CHF2 265 

HFE-569sf2, 

(HFE-7200) 

Isomer blend 

1-Ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane 163702-05-4 C4F9OC2H5 59 

HFE-365mcf2 1-Ethoxy-1,1,2,2,2-pentafluoroethane 22052-81-9 CF3CF2OCH2CH3 58 

 1-Ethoxy-1,1,2,2,3,3,3-heptafluoropropane 22052-86-4 CF3CF2CF2OCH2CH3 61 

HFE–365mcf3 1,1,1,2,2-Pentafluoro-3-methoxypropane 378-16-5 CF3CF2CH2OCH3 11 

 Fluoro(methoxy)methane 460-22-0 CH3OCH2F 13 

HFE–263fb2 1,1,1-Trifluoro-2-methoxyethane 460-43-5 CF3CH2OCH3 11 

R-E-143a; HFE263m1 1,1,2,2-Tetrafluoro-1-(trifluoromethoxy)ethane 690-22-2 CF3OCH2CH3 29 

2-Ethoxy-3,3,4,4,5-pentafluorotetrahydro-2,5-bis[1,2,2,2-

tetrafluoro-1-(trifluoromethyl)ethyl]-furan 920979-28-8 C12H5F19O2 56 

 1-Ethoxy-1,1,2,3,3,3-hexafluoropropane 380-34-7 CF3CHFCF2OCH2CH3 23 

HG'-02 1,1,2,2-Tetrafluoro-1-methoxy-2-(1,1,2,2-tetrafluoro-2- methoxyethoxy)ethane 485399-46-0 CH3O(CF2CF2O)2CH3 236 HG'-03 3,3,4,4,6,6,7,7,9,9,10,10-Dodecafluoro-2,5,8,11- tetraoxadodecane 485399-48-2 CH3O(CF2CF2O)3CH3 221 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

Page 17

Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

HFE–374pc2 1-ethoxy-1,1,2,2-tetrafluoroethane 512–51–6 CH3CH2OCF2CHF2 557 

1,1,2,2-Tetrafluoro-3-methoxy-propane; Methyl 2,2,3,3-

tetrafluoropropyl ether 60598-17-6 CHF2CF2CH2OCH3 0.5 

HG'-01 1,1,2,2-Tetrafluoro-1,2-dimethoxyethane 73287-23-7 CH3OCF2CF2OCH3 222 

Fluorinated formates 

Trifluoromethyl formate 85358-65-2 HCOOCF3 588 

Perfluoroethyl formate 313064-40-3 HCOOCF2CF3 580 

Perfluoropropyl formate 271257-42-2 HCOOCF2CF2CF3 376 

Perfluorobutyl formate 197218-56-7 HCOOCF2CF2CF2CF3 392 

2,2,2-Trifluoroethyl formate 32042-38-9 HCOOCH2CF3 33 

3,3,3-Trifluoropropyl formate 1344118-09-7 HCOOCH2CH2CF3 17 

1,2,2,2-Tetrafluoroethyl formate 481631-19-0 HCOOCHFCF3 470 

1,1,1,3,3,3-Hexafluoropropan-2-yl formate 856766-70-6 HCOOCH(CF3)2 333 

Fluorinated acetates 

 Perfluorobutyl acetate 209597-28-4 CH3COOCF2CF2CF2CF3 1.6  Perfluoropropyl acetate 1344118-10-0 CH3COOCF2CF2CF3 1.8  Perfluoroethyl acetate 343269-97-6 CH3COOCF2CF3 2.1  Trifluoromethyl acetate 74123-20-9 CH3COOCF3 2.0  1,1-Difluoroethyl 2,2,2-trifluoroacetate 1344118-13-3 CF3COOCF2CH3 31  Ethyl 2,2,2-trifluoroacetate 383-63-1 CF3COOCH2CH3 1.30  2,2,2-Trifluoroethyl 2,2,2-trifluoroacetate 407-38-5 CF3COOCH2CF3 7  Methyl 2,2-difluoroacetate 433-53-4 HCF2COOCH3 3  Difluoromethyl 2,2,2-trifluoroacetate 2024-86-4 CF3COOCHF2 27  Methyl 2,2,2-trifluoroacetate 431-47-0 CF3COOCH3 52 

Carbonofluoridates 

 Methyl carbonofluoridate 1538-06-3 FCOOCH3 95 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

 1,1-Difluoroethyl carbonofluoridate 1344118-11-1 FCOOCF2CH3 27 

Fluorinated alcohols other than fluorotelomer alcohols 

 2,2,3,3,4,4,5,5-Octafluorocyclopentanol 16621-87-7 -(CF2)4CH(OH)- 73  Bis(trifluoromethyl)–methanol 920-66-1 (CF3)2CHOH 195  2,2,3,3,3–pentafluoropropanol 422-05-9 CF3CF2CH2OH 42  4,4,4-Trifluorobutan-1-ol 461-18-7 CF3(CH2)2CH2OH 0.05  2,2,3,3,4,4,4-Heptafluorobutan-1-ol 375-01-9 C3F7CH2OH 25  2,2,3,3-Tetrafluoro-1-propanol 76-37-9 CHF2CF2CH2OH 13  2,2,3,4,4,4-Hexafluoro-1-butanol 382-31-0 CF3CHFCF2CH2OH 17  2-Fluoroethanol 371-62-0 CH2FCH2OH 1.07  2,2-Difluoroethanol 359-13-7 CHF2CH2OH 3  2,2,2-Trifluoroethanol 75-89-8 CF3CH2OH 20 

Unsaturated PFCs 

PFC C-1418 Perfluorocyclopentene; Octafluorocyclopentene 559-40-0 c-C5F8 1.97 

Dyneon HFP 

(3M) hexafluoropropylene (HFP); PFC-1216; Perfluoropropene 116-15-4 C3F6 , CF3CF=CF2 0.05 

TFE tetrafluoroethylene (TFE); PFC-1114; Perfluoroethene 116-14-3 CF2=CF2, C2F4; 0.004 

 Perfluorobuta-1,3-diene 685-63-2 CF2=CFCF=CF2 0.003  Perfluorobut-1-ene 357-26-6 CF3CF2CF=CF2 0.10  Perfluorobut-2-ene 360-89-4 CF3CF=CFCF3 1.82 

Unsaturated HFCs 

HFC-1234ze(Z) (Z)-1,3,3,3-Tetrafluoroprop-1-ene 29118-25-0 

C3H2F4 

trans-CF3CH=CHF, 

CF3CH=CHF(Z) 

0.29 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

HFC-1234ze(E) (E)-1,3,3,3-Tetrafluoroprop-1-ene 1645-83-6 C3H2F4 cis-CF3CH=CHF 0.97 

TFP trifluoro propene (TFP); HFC-1243zf; 3,3,3-Trifluoroprop-1-

ene 

677-21-4 C3H3F3 , CF3CH=CH2 0.12 

VF vinyl fluoride (VF); HFC-1141 75-02-5 C2H3F, CH2=CHF 0.02 

VF2 vinylidiene fluoride (VF2); HFC-1132a 75-38-7 C2H2F2 , CF2=CH2 0.04 

HFC-1234yf; 

HFO-1234yf 2,3,3,3-Tetrafluoroprop-1-ene 754-12-1 C3H2F4 CF3CF=CH2 0.31 

Capstone 42-U perfluorobutyl ethene (42-U); 3,3,4,4,5,5,6,6,6- Nonafluorohex-1-ene 19430-93-4 C6H3F9, CF3(CF2)3CH=CH2 0.16 Capstone 62-U perfluorohexyl ethene (62-U); 3,3,4,4,5,5,6,6,7,7,8,8,8- Tridecafluorooct-1-ene 25291-17-2 C8H3F13, CF3(CF2)5CH=CH2 0.11 Capstone 82-U 

perfluorooctyl ethene (82-U); 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-Heptadecafluorodec-1-

ene 

21652-58-4 C10H3F17, CF3(CF2)7CH=CH2 0.09 

Solstice 1233 

zd(E) trans-1-chloro-3,3,3-trifluoroprop-1-ene 102687-65-0 C3H2ClF3, CHCl=CHCF3 1.34 

(E)-HFC-1225ye (E)-1,2,3,3,3-Pentafluoroprop-1-ene 5595-10-8 CF3CF=CHF(E) 0.06 

(Z)-HFC-1225ye (Z)-1,2,3,3,3-Pentafluoroprop-1-ene 5528-43-8 CF3CF=CHF(Z) 0.22 

HFO-1345zfc 3,3,4,4,4-Pentafluorobut-1-ene 374-27-6 C2F5CH=CH2 0.09 

(Z)-HFC-1336 (Z)-1,1,1,4,4,4-Hexafluorobut-2-ene 692-49-9 CF3CH=CHCF3(Z) 1.58 

PMVE, HFE-216 perfluoromethyl vinyl ether (PMVE) 1187-93-5 CF3OCF=CF2 0.17 

Fluoroxene (2,2,2-Trifluoroethoxy)ethene 406-90-6 CF3CH2OCH=CH2 0.05 

Fluorinated aldehydes 

 3,3,3-Trifluoro-propanal 460-40-2 CF3CH2CHO 0.01 
Revised Analysis of Default GWPs for Fluorinated GHGs Reported Under the GHGRP

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Trade Name Chemical Designation or Common Name CAS No. Chemical Formula Proposed GWP 

Fluorinated ketones 

Novec 1230 FK-5-1-12 Perfluoroketone; FK-5-1-12myy2; PERFLUORO(2- METHYL-3-PENTANONE) 756-13-8 CF3CF2C(O)CF(CF3)2 0.1 

Fluorotelomer alcohols 

 3,3,3-Trifluoropropan-1-ol 2240-88-2 CF3CH2CH2OH 0.35  3,3,4,4,5,5,6,6,7,7,7-Undecafluoroheptan-1-ol 185689-57-0 CF3(CF2)4CH2CH2OH 0.43  3,3,4,4,5,5,6,6,7,7,8,8,9,9,9-Pentadecafluorononan-1-ol 755-02-2 CF3(CF2)6CH2CH2OH 0.33 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,11-

Nonadecafluoroundecan-1-ol 87017-97-8 CF3(CF2)8CH2CH2OH 0.19 

Fluorinated GHGs with one or more carbon-iodine bonds 

 Trifluoroiodomethane 2314-97-8 CF3I 0.4 

Other fluorinated GHGs and HTFs 

Halon-1202 Dibromodifluoromethane 75-61-6 CBR2F2 231 

Halon-2311 / 

Halothane 2-Bromo-2-chloro-1,1,1-trifluoroethane 151-67-7 CHBrClCF3 41