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Finding the Promise in Compromise: EIA Proposal to Jumpstart California HFC Reclaim

Last week EIA participated in California’s Air Resources Board (ARB) 6th workshop on proposed regulations to reduce emissions of super pollutant hydrofluorocarbons (HFCs) used in cooling. The state’s rigorous process for proposing new regulations on HFC refrigerants has been ongoing for several years now and is in the final stretch. Opportunities for stakeholder engagement have been abundant and ARB has invited input from industry along the way. They even aligned with an industry proposed 2023 deadline for transitioning new air conditioning equipment to refrigerants with a global warming potential (GWP) less than 750.

The same industry stakeholders that proposed 2023 as the deadline now claim that the date is unmeetable due to slower than expected updates to state building codes as well as economic hardships brought on by the COVID-19 pandemic. EIA, along with other environmental stakeholders, has stridently opposed any delay in proposed deadlines for these new regulations, which are already insufficient to meet the state’s 2030 emission reduction goals.

But, just maybe, this unforeseen situation presents an opportunity to actually increase emission reductions under the proposed regulation. ARB asked stakeholders to formulate alternate proposals that would allow companies requesting a delay to reduce an equal or greater amount of HFC emissions by 2030.

This is EIA’s proposal: What if there’s a way to provide manufacturers who need a short-term extension (2 years maximum) for relief, while in exchange requiring them to help jumpstart a market for increased use of recycled, or “reclaimed” HFC refrigerants? It’s a fairly simple idea, and it just might work. Instead of buying new synthetically produced HFCs, equipment manufacturers can purchase “reclaimed” refrigerant” – that is, used refrigerant that’s undergone a cleaning process to remove impurities so it can be safely re-used without damaging equipment – to pre-fill new air conditioners or other equipment they sell onto the market in California.

Manufacturers will have to use enough reclaimed refrigerant to offset not just the initial refrigerant used to fill the equipment, but enough to also offset any additional refrigerant that gets added to replace leaked refrigerant over the equipment’s full lifetime. It’s not hard math; for most types of equipment we know estimated lifetime expectancy and how much refrigerant it leaks on average. This is information California already uses to estimate total HFC emissions for its greenhouse gas inventory.

EIA has long argued that we need policies both to transition new cooling equipment away from using HFCs, and also to manage existing HFCs by increasing collection, recycling, and sustainable disposal through destruction. Our report Search, Reuse, & Destroy: How states can lead on a 100 billion ton climate problem, provided recommendations for states to do just that. The biggest challenge to making this happen is that most refrigerant isn’t properly recovered from equipment at its end of life; it costs money and time to do so and there is no demand or value for its reuse. Instead most refrigerant gets vented into the atmosphere, a practice that’s illegal if done intentionally, but nonetheless commonly happens and contributes the vast majority of overall HFC emissions.

If equipment manufacturers were required, however, to begin bulk purchasing large quantities of reclaimed HFCs, it would create a market value for recovering and collecting used HFC refrigerants. This would ‘jumpstart’ a greater market for used refrigerant, one that could grow over time, particularly with other complimentary policies and incentives. This effect could actually increase the emission reductions achieved by the regulation before 2030.

We look forward to finding promise in compromise by continuing discussion on this idea for California, already a leader in HFC reduction policies, to blaze a new trail.