Page 1 of 4

Memo: Montreal Protocol Compliance

This memo details how the amount of HCFCs allocated in each option discussed in the proposed rule, 

“Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC 

Production, Import, and Export,” (2011 Proposed Rule for 2012 through 2014) compares to the cap 

under the Montreal Protocol. All allocations are expressed as ODP-weighted metric tons (ODP-MT).

The total U.S. cap between 2010 and 2014 is 3,810 ODP-MT for consumption and 3,884.25 ODP-MT 

for production. In summary, the U.S. is in compliance with the Montreal Protocol under each of the 

scenarios discussed in the proposed rule by at least 36 percent for consumption and 33 percent for 

production.

HCFC-22

There are numerous options discussed as they relate to HCFC-22 allocations in 2012 through 2014. The 

proposed baselines for all options are identical to the baselines used in the 2011 Interim Final Rule. 

Consumption of HCFC-22

For consumption, these options include:

1. Allocate the same number of allowances as the 2009 Final Rule—

A. plus recoupment in 2013 (recoupment option 1)

B. plus recoupment in 2013 and 2014 (recoupment option 2)

C. including recoupment in 2013 and 2014 (recoupment option 3)

D. with no recoupment (recoupment option 4)

Consumption Allocation equivalent to the 2009 Final Rule (ODP-MT)

Allocation 

before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 2,239 - - - -

2013 1,974 325 162 - -

2014 1,709 - 162 - -

2. Allocate between 11 and 47 percent fewer allowances than in the 2009 Final Rule—

 plus recoupment in 2013 (recoupment option 1)

 plus recoupment in 2013 and 2014 (recoupment option 2)

 including recoupment in 2013 and 2014 (recoupment option 3)

 with no recoupment (recoupment option 4)

Consumption Allocation is 11 to 47 Percent Smaller than in the 2009 Final Rule (ODP-MT)

Larger 

Allocation

Scenario

Smaller 

Allocation 

Scenario

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 1,990 1,381 - - - -

2013 1,724 1,147 325 162 - -

2014 1,443 905 - 162 - -

N.B.: The specific reductions for each year are listed and explained in the “Adjustment Memo” included 

in the docket.
Page 2 of 4

Production of HCFC-22

For production, these options include: 

1. Allocate production at the same percentage as consumption, where the baseline percentage is 

such that total consumption allocation is the same as in the 2009 Final Rule—

a. plus recoupment in 2013 (recoupment option 1)

b. plus recoupment in 2013 and 2014 (recoupment option 2)

c. including recoupment in 2013 and 2014 (recoupment option 3)

d. with no recoupment (recoupment option 4)

Production Allocation Based on 2009 Final Rule Consumption Allocation (ODP-MT)

Allocation

before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 2,038 - - - -

2013 1,796 254 127 - -

2014 1,555 - 127 - -

2. Allocate production at the same percentage as consumption, where the consumption 

allocation is reduced by 11 to 47 percent—

a. plus recoupment in 2013 (recoupment option 1)

b. plus recoupment in 2013 and 2014 (recoupment option 2)

c. including recoupment in 2013 and 2014 (recoupment option 3)

d. with no recoupment (recoupment option 4)

Production Allocation Based on Lower Percentages of Baseline for Consumption (ODP-MT)

Range of 

Allocation

Before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 1,257 - 1,811 - - - -

2013 1,044 - 1,569 254 127 - -

2014 824 - 1,314 - 127 - -

3. Allocate production at the same percentage as 2009 Final Rule, such that there is an increase 

in the production allocation as compared to the 2009 Final Rule—

a. plus recoupment in 2013 (recoupment option 1)

b. plus recoupment in 2013 and 2014 (recoupment option 2)

c. including recoupment in 2013 and 2014 (recoupment option 3)

d. with no recoupment (recoupment option 4)
Page 3 of 4

Production Allocation Using Percentages of Baseline from the 2009 Final Rule (ODP-MT)

Allocation 

Before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 2,421 - - - -

2013 2,137 254 127 - -

2014 1,853 - 127 - -

HCFC-142b

There are numerous options discussed as they relate to HCFC-142b allocations in 2012 through 2014. 

The proposed baselines for all options are identical to the baselines used in the 2011 Interim Final Rule. 

Consumption of HCFC-142b

For consumption, these options include allocating the same number of allowances as the 2009 Final 

Rule—

 plus recoupment in 2013 (recoupment option 1)

 plus recoupment in 2013 and 2014 (recoupment option 2)

 including recoupment in 2013 and 2014 (recoupment option 3)

 no recoupment (recoupment option 4)

Proposed Consumption Allocation in ODP-MT

Allocation 

Before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 7 - - - -

2013 7 4 2 - -

2014 7 - 2 - -

Production of HCFC-142b

For production, these options include allocating the same number of allowances as the 2009 Final 

Rule—

 plus recoupment in 2013 (recoupment option 1)

 plus recoupment in 2013 and 2014 (recoupment option 2)

 including recoupment in 2013 and 2014 (recoupment option 3)

 no recoupment (recoupment option 4)

Proposed Production Allocation in ODP-MT

Allocation 

Before 

Recoupment

Additional 

Allowances 

[Recoupment 

Option 1]

Additional 

Allowances 

[Recoupment 

Option 2]

Additional 

Allowances 

[Recoupment 

Option 3]

Additional 

Allowances 

[Recoupment 

Option 4]

2012 30 - - - -

2013 30 26 13 - -

2014 30 - 13 - -
Page 4 of 4

Other HCFCs

This rulemaking does not affect the allocations for HCFC-123, HCFC-124, HCFC-225ca, and HCFC225cb. The resulting amount allocated in each year between 2012 and 2014 is:

Consumption Production

Chemical ODP- MT Allocated Chemical ODP- MT Allocated

HCFC-123 50 HCFC-123 0

HCFC-124 66 HCFC-124 111

HCFC-225ca 9 HCFC-225ca 8

HCFC-225cb 12 HCFC-225cb 15

Total 137 Total 135

All HCFCs Combined

HCFC Consumption Allocation using Highest Proposed Allocation for HCFC-22 (ODP-MT)

Montreal Protocol cap: 3,810 ODP- MT

Highest 

Allocation 

without 

Recoupment 

Total 

Allowances 

[Recoupment 

Option 1]

Total 

Allowances 

[Recoupment 

Option 2]

Total 

Allowances 

[Recoupment 

Option 3]

Total 

Allowances 

[Recoupment 

Option 4]

2012 2,383 2,383 2,383 2,383 2,383

2013 2,118 2,446 2,282 2,118 2,118

2014 1,852 1,852 2,017 1,852 1,852

Each option is at least 36 percent below the Montreal Protocol Cap

HCFC Production Allocation using Highest Proposed Allocation for HCFC-22 (ODP-MT)

Montreal Protocol cap: 3,884.25 ODP- MT

Highest 

Allocation 

without 

Recoupment

Total 

Allowances 

[Recoupment 

Option 1]

Total 

Allowances 

[Recoupment 

Option 2]

Total 

Allowances 

[Recoupment 

Option 3]

Total 

Allowances 

[Recoupment 

Option 4]

2012 2,586 2,586 2,586 2,586 2,586

2013 2,302 2,582 2,442 2,302 2,302

2014 2,018 2,018 2,158 2,018 2,018

Each option is at least 33 percent below the Montreal Protocol Cap