With the Environmental Protection Agency seeking to implement a further rule to its Significant New Alternatives Policy (SNAP), which regulates refrigerant usage, the environmental groups, along with other stakeholders, have been putting forward their own views.
Following the listing of a number of lower GWP refrigerants in April, the EPA issued its rulemaking in July delisting a number of higher GWP refrigerants including R404A and R134a in certain applications.
Tackling HFCs is seen as a key element of the Obama administration’s Climate Action Plan and the EPA is working towards an additional rulemaking before the end of his term.
The petitions, one from the Environmental Investigation Agency (EIA) and a joint petition from the Natural Resources Defense Council (NRDC) and the Institute for Governance and Sustainable Development (IGSD), call on the EPA to build on and extend recent SNAP delistings of higher GWP HFC refrigerants in a number of applications.
While both petitions seek to strengthen the bans, their contents are very different.
The NRDC/IGSD petition calls for a strengthening of the current rule, the delisting of more refrigerants and its extension to other areas of application including unitary air-conditioning. It lists a wide range of what the two groups see as acceptable alternatives including HFCs, HFOs and their respective blends as well as “natural” refrigerants.
The EIA proposal sticks to refrigeration applications and calls for additional bans on a number of higher GWP HFCs, including delisting R134a and a ban on the the use of R507A and R404A by 2019.
Ban medium GWP blends
Significantly, the EIA has questioned the need for new transitional HFC blends with GWPs from 600 to 1,400 or higher in new equipment and retrofits. The EIA argues that these new substitutes, which were recently approved on the SNAP list of alternatives, have the potential to cause a major and sustained impact on the climate when compared to other available alternatives with GWPs of 10 or less.
“Allowing these HFC blends in new and retrofit equipment risks locking in high emissions from these chemicals for decades and undermines the market growth of suitable low-GWP alternatives,” it says. It goes further to suggest that the EPA should ban HFC blends from new equipment and strictly limit their use in retrofits of existing equipment in only those end-uses where they replace old substitutes with substantially higher climate impacts.
R410A a target
The NRDC/IGSD seeks an end to using R410A in both residential and commercial air conditioning applications, suggesting a range of refrigerants including R32, R454B, R446A, R447A and the Chemours development refrigerant DR-55.
Although not neglecting R410A, the EIA petition states that certain other air conditioning end-uses such as split and unitary air conditioning will require additional time and should be considered under a subsequent rulemaking.
Mark W Roberts, the EIA’a senior counsel in the US, told the Cooling Post that it believes the EPA is currently looking at the refrigeration sector. “We put in a petition that is directly linked to refrigeration because in the last rulemaking the EPA asked specific questions about refrigeration and we have had communications with them that this is what they are working on,” he said.
“We are also very concerned about the proliferation of mid-range HFC/HFO blends. We think that is a huge mistake,” he added.
Natural v man-made
Apart from listing the HFOs R1234ze and R1233zd for certain chiller applications, all the EIA’s alternatives are “natural” refrigerants. “The EIA has a general philosophy that we want the lowest possible commercially available alternatives in any sector. In refrigeration, in particular, that’s naturals that have been proven or are leading hands down,” said the EIA’s Mark W Roberts.
The NRDC claims to have no fixed position concerning fluorinated and non-fluorinated alternatives. “Our objective is to make substantial and rapid improvement in GWP while maintaining or improving energy efficiency,” said David Doniger, NRDC’s director, climate & clean air program. “This is a process of continuous improvement. Industry has mastered several transitions since CFCs, and they should expect periodic transitions to be the norm going forward, moving always to better, safer products.”
“The Obama administration is taking the lead to cut HFCs both at home and abroad,” added IGSD president, Durwood Zaelke. “Stopping use of HFCs that are no longer needed is part of the effort, and it demonstrates to the rest of the world that the US is serious about a global phase down of HFCs.”