In our third article, we take a closer look at some provocative questions raised in recent press coverage. We thought a good jumping-off point was a recent New York Times article on residential air conditioning; below we address a few of the nearly 100 reader comments (in italics below) submitted in response to the article.
By Jill Abelson and Jeff Cohen
R-22: Going, going, gone
Chlorodifluoromethane, better known as HCFC-22 or R-22 is a common refrigerant that is currently being phased out in the U.S. due to its very high potential to exacerbate ozone-depletion (R-22 is also a global warming gas). U.S. EPA has tried to reduce use of this material by imposing strict quotas on its production. Since 2010, the agency has also banned sale of new air-conditioning units containing the compound, and has promoted recycling of the gas from old machines so it will not be released. Despite these efforts, the agency has drawn criticism for not doing enough. Can a bounty or buy-back program help? What about a cap-and-trade program?
Let’s first look at some of the things related to R-22 that are legal and are not legal:
- Production for servicing existing equipment installed prior to January 1, 2010
- Production and import by businesses that have prescribed allowances from U.S. EPA through 2020
- Intentional venting
- Leaks from large systems above specified leak rates that go unreported and unrepaired
- Imports or production by businesses that are not authorized by EPA
- Sale to non EPA-certified technicians
Without a doubt, there are challenges in enforcing these and other regulations for R-22 and other refrigerants. High visibility enforcement actions have been effective. Ultimately, the best way to guarantee proper management and minimize/eliminate emissions is to offer economic incentives for equipment owners, technicians, distributors, reclaimers, metals recyclers, and other participants in the “value chain.”
A cash value on recovered and reclaimed R-22 could help reduce unnecessary releases. Since 2010, R-22 production and import allowances have been significantly cut back. Despite these cuts, and associated increases in gas prices, EPA has not yet measured accompanying improvements in the rate of reclaimed R-22. Without an increase in reclamation rates, system owners and other R-22 end-users will face volatile prices and uncertain access to supplies.
EPA is expecting that allowance cuts for R-22 production will encourage greater recovery, and that refrigerant reclaimers will, in fact, be offering higher “bounties” for the gas.
A cap-and-trade program already worked to rid us of acid rain, but most of the R-22 is sitting in old HVAC equipment, as opposed to being emitted. Is this a possible solution?
— NYTimes reader “Dave Kliman”
Over a 20-year period, the U.S. cap-and-trade system for acid rain created incentives that turned pollution reductions into marketable assets. Midwestern and Eastern power plants covered under the program achieved full compliance, even exceeding targets for sulfur dioxide, at a cost that was 70-80 percent below original government estimates.
California’s cap and trade program can be equally successful at reducing greenhouse gas emissions cost-effectively. The California GHG program allows for offsets generated by projects using standardized protocols. These offsets will be driving innovations among “non-compliant” entities so that the state’s targets can be met at the lowest cost. One of the approved offset project types is the destruction of CFC refrigerant gases that would otherwise be used in leaky equipment and eventually released into the atmosphere.
It is possible that this protocol would extend to R-22 and other fluorochemical refrigerants with high GWPs (global warming potential), so long as the offsets meet additionality and other key criteria.
Compliance and containment: Accountability is key
10 years ago, I worked as an inspector the EPA’s CFC program. It’s nearly impossible to catch someone actually releasing refrigerant into the air. Instead we’d go after people for record-keeping violations. It was very unsatisfying and I didn’t really feel I was accomplishing much. We did get complaints of releases called in occasionally, but again, I never had a case where we proved it. As far as I know, my former regional office doesn’t have anyone working the CFC program at this time.
— From NYtimes reader “Ann”
U.S. EPA regulations related to fluorochemical refrigerants have resulted in a safe and smooth transition from CFCs to alternatives that are far better for the environment. However, it is challenging to ensure compliance with regulations that involve tens of thousands of certified technicians servicing millions of air conditioning and refrigeration units and systems across the U.S.
By law, owners of large equipment (e.g., supermarket systems, commercial air conditioning units) have to ensure that the equipment is maintained and leaks are repaired by certified technicians. Homeowners of smaller central A/C units are not legally responsible for refrigerant leaks, but anyone servicing the smaller equipment is still prohibited from knowingly venting R-22. While the choice to recharge leaky equipment may come down to economics (recharge vs. new unit) this choice may be short-sighted. The unit would likely continue to require routine servicing, with increasingly more expensive recharges.
We think the most cost-effective solution to promote best practices and prevent unnecessary emissions is to emphasize accountability, and to leverage market incentives.
I wish the New York Times article went more into the greener coolants that are being developed. Shouldn’t we put our minds together and push for near 100% sustainable A/C development?
— From NYtimes reader “DavidLibraryFan”
Refrigerants with zero or very low global warming potential (GWP) are gaining more market acceptance, in lots of applications. This year, EPA added three hydrocarbons as acceptable alternatives in household and small commercial refrigerators and freezers through the Significant New Alternatives Policy (SNAP) program. The newly-listed hydrocarbon refrigerants – already widely in use in Europe — can be used to replace CFC-12 and HCFC-22 in household refrigerators, freezers, combination refrigerator-freezers, and commercial stand-alone units. EPA also published final use conditions for CO2 and HFO-1234yf as a refrigerant in new cars and trucks. Two resources on ammonia, hydrocarbons, and CO2 refrigerants are Refrigerants, Naturally and Shecco.
What really happens to my old refrigerator?
My small town has an annual white goods collection. The town invites residents to bring down old appliances … but refrigerators and freezers cannot contain Freon. When he asked officials how to get rid of the Freon, they said “we can’t tell you what to do, but if the line happened to be cut then we could accept your old refrigerator.”
— From NYtimes reader “Fosco”
Of the 9.4 million fridges reaching end of life in the U.S., about 25 percent are resold into the after market, resulting in increased energy demand from continued use of the older, less-efficient models. That leaves 7.1 million fridges to be de-manufactured. Of these fridges, the vast majority end up in landfills or metal scrapyards, where their coolant refrigerants and other hazardous materials may not be dealt with properly. EPA’s RAD program encourages voluntary, responsible recycling but less than 10 percent of the discarded fridges in the U.S. are managed under RAD programs.
While Federal law requires recovery of refrigerants and other hazardous waste prior to disposal or recycling (the law does not require recovery of appliance foam, also an ODS/GHG emissions source), properly recovering refrigerants adds time and labor to an already labor-intensive process. “Cutting the line,” i.e. venting the refrigerant before the refrigerator arrives at the recycling facility, unfortunately, may be a common practice before your beloved old fridge is crushed for scrap metal.
Refrigerator buy-back and recycling programs are active in many parts of the country, with sponsorship from local utilities, retailers, and some manufacturers. Equipment owners often get a rebate towards a new fridge, with utility programs paying for older units as long as they are operational. Appliance recyclers like JACO Environmental will pick up your old unit at your house or at a collection facility, and completely de-manufacture the fridge into its component materials. Refrigerants and even the fluorochemicals in the insulation foam are extracted under vacuum, and safely disposed or recycled.
Is more innovation in store for refrigerants? Stay tuned for our next articles.
The Refrigerant Revolution, our multi-part article series, explores the environmental and economic dynamics around refrigerants and the market-based solutions aimed at their full life-cycle management. We introduced the series by describing how some refrigerants, when released to the atmosphere from leaky equipment, or from equipment improperly discarded, are threatening the Earth’s climate system.