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## Mem**o: 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 S ystem 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 O DP
- 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 2,23 9
- - - - 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 P**  **ercent Smaller than in the**  **2009 Final Rule (ODP -** **MT)**

Larger Allocation Scenario Smaller

Allocati on Scenario Additional

Allowances [Recoupment Option 1] Additional

Allowances [Recoupment Option 2] Additional

Allowances [Recoupment Option 3] Additional

Allowances [Recoupment Option 4] 2012 1,99 0 1,38 1
- - - - 2013 1,72 4 1,14 7 325 162
- - 2014 1,44 3 90 5
- 162
- - N.B.: The specific reductions for each ye ar 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 b y 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

Al lowances [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) **Propose d 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 HCFC
225cb. 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 2,1 18 2,446 2,282 2,118 2,118 2014 1,85 2 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 2,58 2 2,44 2 2,3 02 2,302 2014 2,018 2,018 2,15 8 2,0 18 2,018 **Each option is at least 33 percent below the Montreal Protocol Cap**