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Forum LIVE
Forum LIVE
The Changing World of Refrigerant Regulations
August 14, 2019
This webinar and related materials are for informational purposes only and not for the purpose of providing legal advice. If you need legal guidance in a particular matter, you should contact your attorney.
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Helen Walter-Terrinoni• VP Regulatory Affairs for Air Conditioning, Heating,
and Refrigeration Institute (AHRI)
• Co-chair of the UN Montreal Protocol Foams Technical Operations Committee
• Science Advisor for the Alliance for Responsible Atmospheric Policy
• Formerly with Chemours Fluorochemicals and the Center for Polyurethane Institute
• Masters, Chemical Engineering, Syracuse University
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What are the World’s goals? The Kigali AgreementEstimated to reduce temperature rise by up to 0.5C
• 1.5C 2C temperature rise
• 250 million more people exposed to drought and its consequences
• 1.7 billion more people exposed to extreme temperatures
• > 1/5 of the current global population
GWP weighted phasedown of the consumption and production of controlled HFCs by country
• Each country determines their own regulatory structure (e.g. quota and allocation, bans, bright lines)
• Regulatory structures are emerging
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The World Is Regulating HFCs
European Union: 2006 F-Gas 1
Regulated aerosols, mobile AC and some foams
Australia: 2012 HFC Tax
~$20 (USD)/lb R-404A & $10/lb R-410A
Repealed in 2014
California: SB 1383 40% emissions
reduction by 2030
EU F-Gas II2014:
HFC Phasedown implemented, 79% reduction by 2030
Japan: 2015 Top Runner
Program
2016 & 2017 EPA Issues SNAP Rules 20 & 21
Some Climate Alliance States
adopting SNAP Rules 20 & 21
Bottom Line: Local to global, governments are regulating HFCs
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2016 Montreal Protocol Kigali HFC Amendment Phase Down Schedules
Kigali Amendment to the Montreal Protocol HFC Phasedown Schedule as % of Baseline
120%
100%
80%
60%
40%
20%
0%
2010 2020 2035 20552015 2030 20502025 20452040
nA5 ex Belarus, Russian Federation, Kazakhstan, Tajikistan, UzbekistanBelarus, Russian Federation, Kazakhstan, Tajikstan, UzbekistanA5 ex GCC, India, Pakistan, Iraq, IranGCC, India, Pakistan, Iraq, Iran
• Industry and E-NGOs agree that a universal system under the Montreal Protocol was best
• 79 countries, as of August 2019, have ratified Kigali, including EU, Canada, Japan, Australia, Mexico.
• A number of countries have also established programs to implement the Kigali phasedown
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Kigali Amendment: What about the United States?
Process
• State Department (directed by the White House) transmits the amendment for “advice and consent” to the Senate
• 2/3 of Senators present must vote in favor of ratification
• EPA promulgates regulations to implement the amendment
How will it be implemented?
• Sector-based controls?
• Quota and allocation system?
• Sector-based GWP Limits?• Combination?
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Montreal Protocol HFC Phasedown in US
Kigali Amendment to the Montreal Protocol HFC Phasedown Schedule as % of Baseline
120%
100%
80%
60%
40%
20%
0%
2010 2020 2035 20552015 2030 20502025 20452040
nA5 ex Belarus, Russian Federation, Kazakhstan, Tajikistan, Uzbekistan
BASELINE
10% ( SNAP RULE 20)
40% ( SNAP RULE 21)
70%
80%
85%
• SNAP Rules 20 & 21 and Section 608 Refrigerant Management HFC Rule were designed to meet the first 2 steps of the HFC phasedown
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EPA SNAP Status
• Both SNAP Rules 20 and 21 have now been vacated by the Court to the extent that they required HFCs to be replaced in existing applications. EPA is in the process of determining how they will regulate HFCs going forward.
• EPA is writing applicable regulations through a new rulemaking process; proposed rule may be published in 2019.
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EPA SNAP Sectors in the original Rules 20 & 21
Note: Although there is much uncertainty as to how EPA might regulate HFCs going forward, designated sectors remain important as some states are adopting transition dates based on SNAP.
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US Climate Alliance-State Action on HFCs
• August 4, 2017: U.S. submits formal notice of withdrawal from Paris Climate Agreement withdrawing, at the earliest, Nov. 4, 2020
• United States Climate Alliance States commit to reduce emissions commensurate with U.S. commitment. 392 mayors also committed to the Paris agreement reductions.
• Some states have included HFCs in this effort• California, Washington and Vermont have adopted HFC transition
dates based on SNAP, with some delays and exceptions• Connecticut, Delaware, Maryland, New York have made
commitments and/or taken steps toward adopting regulatory programs. Final regs expected in 2020/2021
• New Jersey has introduced legislation based on SNAP
Bottom Line: 24 States and Puerto Rico are moving forward with climate regulation due to federal inaction
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California
SB 1383 statutory requirement to reduce emissions by 40% by 2030 compared to 2013
• The rest of the world regulates based on refrigerant production and consumption rather than emissions
Bottom Line: California’s goals are 5-10 years ahead of the Kigali Amendment
HFC Projected Emissions (MMTCO2E) in CA 2010 - 2050with Kigali Amendment Global HFC Phasedown
MM
TCO
2E (1
00-y
ear G
WP)
30
25
20
15
10
5
0
2010 2020 20352015 2030 20502025 20452040
HFC Emissions BAU, No Phasedown. No New MeasuresH1: Historical CFC Reductions ScenarioH2: Historical HCFC-22 Reductions ScenarioBC: Best Case Scenario New Equipmwnt Low-GWP + RetrofitsWC: Worst Case ScenarioEmissions Goal: 40% Reductions below CA 2013 Baseline by 2030
HFC Projected Emissions (MMTCO2E) in CA 2010 - 2050with Kigali Amendment Global HFC Phasedown
MM
TCO
2E (1
00-y
ear G
WP)
30
25
20
15
10
5
0
2010 2020 20352015 2030 20502025 20452040
HFC Emissions BAU, No Phasedown. No New MeasuresH1: Historical CFC Reductions ScenarioH2: Historical HCFC-22 Reductions ScenarioBC: Best Case Scenario New Equipmwnt Low-GWP + RetrofitsWC: Worst Case ScenarioEmissions Goal: 40% Reductions below CA 2013 Baseline by 2030
California Emissions Goal 2030
0.71% Compound Growth Rate
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California Air Resources Board: Additional Measures
40% Reduction = 10% SNAP Rules + 10% Kigali Phase Down + 20% Additional MeasuresProposal presented October 2018
*Potential exemptions: Reclaimed refrigerant and R-410A for stationary AC
Bottom Line:• California emissions goals are driving regulations beyond SNAP & refrigerant
management rules• Additional commercial refrigeration measures• AC measures
Service Ban* GWP Limit Date1500 2022
Additional measures: Stationary refrigerant limits in new systems GWP Limit DateAir conditioning systems (excluding chillers) 750 2023
New commercial refrigeration systems (>50 lbs) 150 2022
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Implementation Varies by Country
• European Union (EU) combined an allocation system with GWP limits by sector.
• Canada combined an allocation system with GWP limits by sector.
• Australia has a step down every two years with no sector bans at this time. They do charge a deposit for HFCs to encourage recovery.
• Japan has GWP limits by sector, reclaim requirements, and a quota and allocation phasedown.
• Regardless of country, leaking equipment must be addressed.
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United Nations Environment Program Fact Sheet
• Most significant global issue is leaky stationary refrigeration & air conditioning equipment
Global: ~52% of GWP services leaking equipment
HFC use for topping up leaks in RACHP
Filling new equipment: 40%
Toppping up leaks: 60%
60% of the 86% = topping up leaks = 52%
Markets using HFCs, % of tonnes CO₂ 2012
RACHP: 86%
Fire Protection: 3%Foams: 7%
Aerosols: 4%
Solvents: 0%
86% GWP = RACHP
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European Union Fluorinated Gas Regulations
• The EU F-gas and the Kigali amendment phasedowns are similar but have different baselines, scope and phasedown steps
• EU F-Gas Rules address most of the needed phasedown under Montreal Protocol Kigali HFC Amendment
Montreal Protocol Amendment Europe Impact C02eq
120%
100%
80%
60%
40%
20%
0%
20152017
20192021
20232025
20272029
20312033
20342036
20382040
20422044
20462048
2050
nA5 ex Belarus, Russian Feseration, Kazakhstan, Tajikstan, Uzbekistan EU F-Gas
Bottom Line: Although Kigali has no sector specific controls, EU phasedown includes sector controls largely after the first major step down
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Europe (EU-28) F-Gas II
-79%-76%
-69%
-55%
-7%
100%
Cap basis: CO2 Eg MTC02e sales 2009-2012
200
150
100
50
0
20152016
20172018
20192020
20212022
20232024
20252026
20272028
20292030
-37%
Pre-Charge
Equipment Ban:• 2015: HFC ≥ 150; Refrigerators/ Freezers -Foam &
Refrigerant
• 2015: HFC ≥ 2500; Commercial Refrigerators/ Freezers
• 2020: HFC ≥ 2500; Stationary Refrigeration HFC ≥ 150; Movable Room Air Conditioners
• 2020: HFC ≥ 150; XPS FOAM
• 2022: HFC ≥ 150; Commercial Refrigerators/ Freezers
• 2023: HFC ≥ 150; PU FOAM
• 2025: HFC ≥ 750; single split air conditioners
Service Ban:• 2020: Prohibit Service and maintenance of refrigeration
equipment with a min charg size of 40 tonnes C0₂ equivalent with refrigerants ≥ 2500 GWP
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Canada – In Effect April 2018 Consumption and production baselines modeled after the Montreal Protocol HFC Amendment
Consumption Baseline / Production Baseline Baseline = 100% HFC + 75% of HCFC baseline
HFC Consumption AllowancesHFC consumption allowances pro-rata based on a company’s average consumption in the years 2014 and 2015. Allowances distributed based on percentage of overall consumption multiplied by the Canadian baseline
There will be a review for interim changes before 2035 to consider A2L limits and other technical advancements
Kigali Amendment Ratified 2017• Import/Export permits needed for HFCs
• Consumption reporting needed for HFCs
Stationary• Stand-alone medium temperature commercial refrigeration
systems: 2020, GWP limit of 1400
• Stand-alone low temperature commercial refrigeration systems: 2020, GWP limit of 1500
• Centralized refrigeration systems: 2020, GWP limit of 2200
• Chiller, GWP Limit 700
• Transport refrigeration systems: 2025, GWP limit of 2200
• MAC: 2021 150 GWP
• Aerosol: 2018 GWP 150
• Foams: 2021 GWP 150https://www.ec.gc.ca/lcpe-cepa/eng/regulations/DetailReg.cfm?intReg=240http://www.gazette.gc.ca/rp-pr/p2/2017/2017-10-18/html/sor-dors216-eng.html
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Kigali Amendment to the Montreal Protocol HFC Phasedown Schedule as % of Baseline
12.0
10.0
8.0
6.0
4.0
2.0
0.0
2016 2018 2021 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 20362017 2020 20242019 20232022
Montreal Protocol phase-down requirementsPrevious phase-down schedule for AustraliaNew phase-down for Australia
Australia Ozone Protection and Synthetic Greenhouse Gas Management Act.
• The scheme commenced on 1 January 2018 and at 75% of Australia’s allowed baseline under the Kigali amendment.
• The steps down will be every two years and are designed to avoid shocks to industry typically observed by having fewer, sharper reductions
• The legislation also allows for GWP limits to be set for particular equipment types by regulation.
• No bans or GWP limits are planned at this time.
• Debating allowance for very small percentage of allocation to new market entrants (<5%)
• Consumption Baseline• Baseline = 100% HFC from 2011-2013 + 75% of HCFC from
original baseline
HFC Phasedown FAQs: Australian Government – Department of Environment and Energy http://www.environment.gov.au/protection/ozone/legislation/opsggm-review/hfc-phase-out-faqs
Training Modules for Handling Flammable Refrigerantshttps://training.gov.au/Training/Details/22329VIC
Kigali Amendment to the Montreal Protocol HFC Phasedown Schedule as % of Baseline
9
8
7
6
5
4
3
2
1
0
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Uni
ts =
1 m
illio
n
Usage Quota
Refrigerant Usage Projections
Aligning Australia’s HFC phase-down with the Montreal Protocol
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Japan – Act on Rational Use and Proper Management of Fluorocarbons
*The average of GWP in each manufacturer.**To be added in 2019• Japanese Movement
ratified Kigali amendment in 2018.
• METI will step down quota and allocation every year for every producer.
• Adding of chilling units, VRV is under discussion. (The estimated target will be GWP 750 around 2027)
JULY 2019
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Consumo de los principales HFC
60
50
40
30
20
10
0
20072008
20092010
20112012
20132014
20152016
20172018
20192020
20212022
20232024
20252026
20272028
20292030
HFC-410
HFC-134a
HFC-245fa
HFC-236fa
HFC-404A
HFC-407C
HFC-507A
HFC-413A
HFC-152a
Consumo de HFC y Calendario de Reduccion ( En Megatoneladas de CO₂eq)
70
60
50
40
30
20
10
0
20072008
20092010
20112012
20132014
20152016
20172018
20192020
20212022
20232024
20252026
20272028
20292030
20312032
20332034
20352036
20372038
20392040
20412042
20432044
20452046
20472048
2049
Total (Megaton) Kigali Amendment
Mexico: Considering Options
Mexico is the only developing country to date that published an HFC phasedown.
Freeze - 2024Emisiones Potenciales estimadas al 2030
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Safe Refrigerant Transition
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Australia: Safe Use of Low GWP Refrigerants
2012: End to end supply chain safety analysis
• 2012-14 Carbon Tax
• 2018: AC - 60% R32 (A2L)
• 460 models / 35 ducted system models
Refrigerant License required to purchase ANY HFC, but not HCs (A3)
• NO reports of safety issues related to the use of R-32 in Australia
• Since 2014, 3 serious injuries and 2 deaths associated with use of HCs in systems not designed for them
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Problem Statement
• Differences in properties of low GWP refrigerants (e.g., flammability and toxicity) may require changes made to current commercial practices to minimize risk while meeting climate regulations.
• In many cases, these are historic products that have not been used in these equipment types in some time, if at all.
AHRI Safe Refrigerant Transition Task Force• Invitation to interested stakeholders to participate in an evaluation of the end-to-end supply chain to
determine any gaps in transition planning to safely use low GWP refrigerants.• Initial North America focus with a commitment to socialize learnings internationally
Contact: [email protected] if interested in participating
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For More InformationAHRIHelen Walter-Terrinoni VP Regulatory Affairs [email protected]
globalFACTJordan SmithExecutive Director [email protected]
