EPA Bans Hydrofluorocarbons

Last week the U.S. Environmental Protection Agency (EPA) issued a final rule establishing a comprehensive program to cap and phase down the production and consumption of hydrofluorocarbons (HFCs) in the United States. HFCs are potent greenhouse gases commonly used in refrigeration and air conditioning equipment, as well as foams and many other applications.

This final rule will phase down the U.S. production and consumption of HFCs by 85% over the next 15 years, as mandated by the American Innovation and Manufacturing (AIM) Act that was enacted  by the U.S. Congress in December 2020. The AIM Act not only phases down HFCs, but  also ushers in the use of more climate friendly and energy efficient alternatives. American companies are at the forefront of developing HFC alternatives and the technologies that use them. If there were a  global phasedown of HFCs, it could  avoid up to 0.5 °C of global warming by 2100. 

The total emission reductions under this rule from 2022 to 2050 are projected to amount to the equivalent of 4.6 billion metric tons of CO2. EPA used the social costs of HFCs to monetize the benefits of this rule. EPA estimates that in 2022, the annual net benefits of this action are $1.7 billion, rising to $16.4 billion in 2036 when the final phasedown step is reached. The present value of the cumulative net benefits of this action is $272.7 billion from 2022 through 2050. The benefits are calculated over the 29-year period from 2022–2050 to account for the years that emissions will be reduced following the consumption reductions from 2022–2036.

The press release says that the Biden-Harris Administration is marshalling a whole-of-government approach to prevent the illegal trade, production, use or sale of HFCs; support the transition to HFC alternatives and encourage the reclamation and recycling of HFCs from retired equipment.  “To help ensure the integrity of the program and a rigorous and timely phasedown, EPA will work with the Department of Homeland Security to prevent the illegal import and trade of HFCs through an interagency task force. The task force will be led by experts from U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement, Homeland Security Investigations and EPA to detect, deter, and disrupt any attempt to illegally import HFCs into the United States.”

They believe that it will be necessary to make the U.S. Boarder somehow impervious to illegal trade of these substance.  Despite the economic benefit to society due to the reduction of 4.6 metric tons of CO2 equivalents, there is a significant cost to homeowners and businesses to replace refrigeration and cooling equipment. I look forward to seeing how effective these plans are because boarder control has not been the administration's strong suit. This element was deemed important enough in the Administration’s planning to be called out in the press release. So there must be considerable profit to be made by smuggling HFCs into the U.S.

The plans to phase down the use of HFC's began in July 2016 when then Secretary Kerry attended the “Extraordinary Meeting of the Parties to the Montreal Protocol,” which took  place in Vienna, Austria to discuss the utilizing the Montreal Protocol for reducing greenhouse gas emissions.  At the time the parties created the Kigali Amendment to the Montreal Protocol. According to a report at the time from the Lawrence Berkeley National Laboratory, HFCs had become one of the fastest growing greenhouse gases, with atmospheric concentrations growing every year. HFC had replaced chloroflurocarboncs (CFCs) under the Montreal Protocol.

In the 1980’s when Scientists identified and documented the growing hole in the ozone layer above Antarctica, the nations were alarmed. Then the NOAA Earth Systems Research Laboratory postulated the mechanism that created the Antarctic ozone hole. According to their work, the hole in the ozone was created by a reaction of ozone and chlorofluorocarbons free radicals on the surface of ice particles in the high altitude clouds that form over Antarctica.

The nations met and finally were able to negotiate the Montreal Protocol on Substances that Deplete the Ozone Layer to protect the stratospheric ozone layer by phasing out the manufacture and use of ozone-depleting substances in 1987. The Montreal Protocol was ratified by all nations and is always cited as the most successful multilateral environmental treaty to-date. The Montreal Protocol forced the phase-out of ozone-depleting gases chlorofluorocarbons (CFCs) and later hydrochlorofluorocarbons (HCFCs). In 2016 at the Extraordinary Meeting of the Parties the signatories met to negotiate the phase out of hydrofluorocarbons (HFCs) that had replaced CFCs and HCFCs. While HFCs do not deplete the ozone layer they are a potent greenhouse gas and using the framework of the Montreal Protocol seem expedient. 

According to climate scientists, HFC currently used in the air conditioning and refrigeration industry have global warming potentials thousands of times greater than CO2, though their current impact is limited. Air conditioner sales in many emerging high population economies such as Brazil, India, and Indonesia are growing at 10-15% per year. Scientists now believe that it is essential to phase out HFCs (and natural gas) to mitigate climate change.