HARC Meeting

March 4, 2010Arlington, Virginia

Aviation Issues

ICAO Resolution Dates from original ICAO resolution

reaffirmed at December 2009 meeting:– Lavatory, engine/APU, hand-held

extinguishers for which a new application for type certification has been submitted (i.e., newly designed aircraft) in the 2011 timeframe

– Lavatories in new production aircraft in the 2011 timeframe

– Hand-held extinguishers in new production aircraft in the 2014 timeframe, with it being a recommended practice by 2012

Aviation Issues

ICAO Resolution New date for hand-held extinguishers

in new production aircraft subsequently proposed by aviation industry - 2016

Accepted in principal along with change in resolution language from “consider a mandate in the 2014 timeframe” to “establish a mandate in the 2016 timeframe”

Aviation Issues HARC submitted comments on FAA draft

hand-held circular on January 8: FAA’s toxicity assessment for streaming agents

is too conservative, more conservative than EPA

Raises questions about the safety of existing Halon 121 extinguishers on aircraft

Raises questions about the safety of currently approved alternatives

Could hinder development of potential new alternatives with a toxicity profile similar to 1211

Not appropriate to use conservative approach for alternatives and not for Halon 1211

Aviation Issues HARC comments on FAA hand-held circular:

Recommend that FAA use the same approach for toxicity of streaming agents as EPA under SNAP

Needs to provide simple guidance (single table) and focus more on importance of using extinguisher

Corrected statement related to aviation “EPA critical use exemption” and “production” of blends

Remove requirements to mark extinguishers with statement related to minimum aircraft volumes and warning to “use only amount necessary to extinguish a fire” for fear of hesitation in using

Remove ventilation recommendation as it may conflict with established crew procedures

Aviation Issues Major halon contamination issue in Europe Large quantity of halon over last 7 years has

gone into aviation systems/extinguishers EASA determined that Halon 1301 is safe? EASA emergency airworthiness directive

issued in November requiring extinguishers from Fire Fighting Enterprises to be replaced

Subsequent EASA directives covering other types of extinguishers and aircraft

FAA emergency airworthiness directives issued in January and February

ASTM

D26.09 Subcommittee D6127 (HFC-23 HT&S), D6427 (HFC-236fa

HT&S), D7123 (HCFC Blend B HT&S) were balloted and received no negatives

D7327 (HFC Blend B Standard) is overdue for balloting - B. Colton to address

Negatives received for D6064 (HFC-227ea Standard), D6126 (HFC-23 Standard), and D6231 (HFC-125 Standard)

ASTM D26.09 Subcommittee

Negatives based on needed conductivity method for acidity withdrawn – ASTM conductivity method will be developed, then all ASTM standards can reference both colorimetric and conductometric methods

Other negatives based on lack of definition of non-absorbable gases (NAG) - ARI 700 refers to these as non-condensable gases

Additional definition will be added to reflect that ARI refers to NAG as non-condensable gases, and the standards will be re-balloted

ASTM D26.09 Subcommittee

Owing to severely contaminated Halon 1211 being found in the European aviation sector, and possible US as well, a new Halon 1211 standard is being developed under the Rapid Ballot process

Purity testing will use a GC/MS method The Halon 1301 standard will be revised

to replace GC testing with a GC/MS method

A draft Halon 1211 Standard is currently circulating for comment

Climate Change Climate Science

Recent revelations from emails about IPCC scientists hiding contradicting data

Errors in 2007 IPCC report related to Amazon rain forest endangerment, Netherlands/sea level, Himalayan glaciers

Raised questions about climate science and about the methods of the IPCC

Has contributed to recent polls in US and UK showing less concern for climate change

Climate Change

Copenhagen - What Happened? Current UNFCCC negotiation process is

unmanageable and almost collapsed UNFCCC Executive Secretary resigned Copenhagen Accord was negotiated by

small group of heads of state including President Obama and China’s Premier Wen Jiabo

China’s increased standing as an economic power was evident

Climate Change

Copenhagen - What Happened? UNFCCC consensus approach no longer

works, negotiations were consistently thwarted by a handful of countries such as Sudan, Venezuela, Bolivia, and Cuba

Developing countries refuse to allow Kyoto Protocol to go away until they have adequate commitments from developed countries for the post-2012 period

Climate Change Copenhagen - Results

Actions by all countries, both developed and developing, that would be listed in a table as part of the Accord

Guidelines that provide transparency for the monitoring, reporting, and verification (MRV) of the national actions listed in the table (key issue for the US)

Commitments for financial assistance to developing countries in $100 billion range, initially $10 billion/year for 3 years

Climate Change Copenhagen - Results

97 countries have kind of associated themselves with the Copenhagen Accord

57 countries, including 27 developing countries, have entered national actions or targets in the Accord’s table– US - 17% reduction from 2005 levels by 2020– EU - 20-30% reduction from 1990 levels by

2020– China - 40-45% reduction in carbon intensity

by 2020 (carbon emissions per unit GDP)

Climate Change

Copenhagen - What’s Next? Reexamination by IPCC of the methods

used to assemble and edit climate science assessments

Continued negotiations aimed at turning the Copenhagen Accord into a legally binding international treaty

Next Conference of Parties (COP 16) in Mexico City in November or December

Climate Change

Montreal Protocol Proposals by US and others were

considered at the 2009 Meeting of Parties in November that would have added HFCs to the Montreal Protocol and controlled their production

Controls would be similar to ODS (CFCs and halons), but production would be phased down slowly and not phased out completely

Climate Change Montreal Protocol

Mauritius and Micronesia:- freeze in 2012 - 60% in 2024- 15% reduction in 2015 - 75% in 2027- 30% in 2018 - 90% in 2030- 45% in 2021 (2004-2006 baseline)

United States, Canada and Mexico:- 10% reduction in 2013 - 70% in 2029

- 20% in 2017 - 85% in 2033- 30% in 2020 Developing Countries: 10% in 2016- 50% in 2025 85% in 2043

Climate Change Montreal Protocol

Proposals not expected to be approved, US and EU supported carrying them over

Instead they were killed due to opposition from China and India among others

Reasons HFC amendments not approved:– Not enough time to fully educate Parties on

proposal – Not enough information on HFC alternatives – Timing not right – Wait for Copenhagen outcome – Developing countries unsure of cost issues

associated with the accelerated HCFC phase out

– Scope: UNFCCC/Kyoto, not the Montreal Protocol

Climate Change

Montreal Protocol Expected that US, Canada and Mexico

will re-propose HFC amendment for consideration at 2010 Meeting of Parties (October in Uganda?)

US seems optimistic, but others think it may take 2 more years to get approved

Climate Change Congress

American Clean Energy and Security Act of 2009 (Waxman-Markey, H.R. 2454)

Clean Energy Jobs and American Power Act (Kerry-Boxer, S. 1733)

Both create an economy-wide cap-and-trade program covering 85% of US greenhouse gas (GHG) emissions

Reduce GHG emissions by 17-20% below 2005 levels in 2020, and 83% in 2050

Climate Change

Congress House bill (HR. 2454) passed in June by

219-212 vote Senate bill (S. 1733) reported out of

Environment and Public Works Committee in November and awaits further action

HFC provisions of both bills very similar HFC provisions were supported by

industry and environmental groups

Climate Change

Congress - HFC Provisions Hydrofluorocarbons (HFCs) would be

covered separately from other GHGs by amending Title VI of the CAA (ODS regulations)

Class II substances would be split into two groups, with group I containing the HCFCs and group II containing the HFCs

Overall production of HFCs would be phased down between 2012 and 2032

Climate Change

Proposed HFC Reduction Schedule2012 - 90% of baseline 2023 - 54%2013 - 87.5% 2024 - 50%2014 - 85% 2025 - 46%2015 - 82.5% 2026 - 42%2016 - 80% 2027 - 38%2017 - 77.5% 2028 - 34%2018 - 75% 2029 - 30%2019 - 71% 2030 - 25%2020 - 67% 2031 - 21%2021 - 63% 2032 - 17%2022 - 59% after 2032 - 15%

Climate Change

Congress - HFC Provisions (Allowances) Allowances required to produce or import

HFCs, or import products containing HFCs The minimum sales price would be set in

the early years of the program as follows:– $1.00 per MT in 2012, $1.20 in 2013, $1.40 in

2014, $1.60 in 2015, $1.80 in 2016, $2.00 in 2017, and then increases with inflation for rest of program

– After 2014 actual sales price determined by combination of auction and non-auction price

Climate Change

HFC Provisions - Allowance Cost At $1.00 per metric ton (2012):

- HFC-227ea = $1.46/lb - HFC-125 = $1.59/lb - HFC-236fa = $4.46/lb - HFC-23 = $6.73/lb

At $2.00 per metric ton (2017):- HFC-227ea = $2.93/lb - HFC-125 = $3.18/lb

- HFC-236fa = $8.92/lb - HFC-23 = $13.40/lb Why has industry supported this approach?

– Under main bill, minimum allowance cost would be $10 per ton = $11.46 per pound for HFC-227ea

Climate Change HFC Provisions - Labeling/Assistance

Essential use, labeling, nonessential product, safe alternatives, and other provisions of Title VI would be extended to HFCs

Products containing or made with HFCs would be required to be labeled with the phrase “contributing to global warming”

Provides possible funding to manufacturers of products containing HFCs, including fire protection systems, to facilitate the transition to low-carbon alternatives

Climate Change

HFC Provisions - Essential Use Essential use provisions would allow EPA

to withhold allowances from under the cap and allocate them specifically to produce HFCs for medical devices, aviation and space flight safety, fire suppression, and national security

Essential use provisions would also allow EPA to approve additional HFC production above the cap for developing countries, national security, and fire suppression

Climate Change HFC Provisions - Destruction

Offset credits are provided at a 20% discount for destruction of CFCs after 2011 in the US

EPA can add other class I or class II ODS EPA can add ODS destruction to list of offset

projects that receive credit in main program CFC destruction projects that occur between

2009 and 2012 and are recognized under a State or comparable program could receive credit under the early offset provisions

Climate Change

Congress - Path Forward Climate legislation may be taken up

again by the Senate in Spring 2010 Senators Kerry (D-MA), Graham (R-SC)

and Lieberman (I-CT) are currently working on a compromise (“tri-partisan approach”)

Key issues include nuclear power and oil exploration (Obama $8 billion in loan guarantees for two nuclear plants in GA)

Climate Change

Congress - Path Forward Senators Cantwell (D-WA) and Collins (R-

ME) recently introduced “cap-and-dividend” bill (S. 2877)

Cap on CO2 emissions from fossil fuel Carbon shares 100% auctioned 75% of proceeds returned to US residents

on a per capita basis, 25% for clean energy

HFCs not covered, but some clean energy funds could be used to finance reductions

Climate Change

Congress - Prospects for Passage Full blown cap-and-trade appears to be

dead Compromise based on “tri-partisan” or “cap-

and-dividend” approach could gain support Industry might support adding HFC

provisions to other climate or energy bills that have chance to pass or as stand alone bill

Right now prospects of Senate climate bill passing this year seem very small, would have to happen before mid-year

Climate Change

Alternatives to Federal Legislation EPA moving forward with regulation of

GHGs under existing Clean Air Act - attempts in Congress (Murkowski), petitions, and lawsuits to stop them

EPA has restricted use of high-GWP fire protection agents under SNAP– HFC-236fa is restricted for use in total

flooding fire suppression to applications where other alternatives are not technically feasible

Climate Change

European Union F-Gas Regulation Effective on July 4, 2007 Covers emissions of HFCs, PFCs, and SF6

Does not prohibit the use of HFCs for fire protection

Most applications requires reporting, recovery containment, leak inspection, labeling, training

Compliance with industry standards such as ISO should meet most requirements

Climate Change European Union F-Gas Regulation

2010 Review Contractor has begun a study to evaluate

compliance with the current regulations and to determine what else needs to be done

Industry position is that most EU member countries have not fully implemented existing regulation - too soon for changes

Could be superseded by addition of HFCs to Montreal Protocol

Climate Change States - Minnesota

Law passed in 2008 that requires reporting by producers and users of high-GWP greenhouse gases (HFCs, PFCs, and SF6)

Reporting threshold changed in 2009 from 500 MT to 10,000 MT

Minnesota Pollution Control Agency is implementing the reporting program

Reports for 2008 and 2009 include refrigerants, PFCs in semiconductors, SF6 in power generation - no fire suppression agents

Climate Change States - California

AB 32 - Alternative Suppressants- High-GWP mitigation fees- Use of lower GWP agents- Leak reduction- End of life agent recycling and destruction

Still under internal discussion and analysis

Not likely to be any action on mitigation fees or fire protection this year

HARC met with IRTA yesterday to discuss helping with CARB inventory

HEEP Update

Data collection is complete for 2008 Same 21 companies have reported for last

5 years Re-charge sales for 5 agents reported:

HFC-23 HFC-236fa HFC-125 PFC-3-1-10 HFC-227ea

2006 - 0.589 MMTCO2e = 0.161 MMTCE 2007 - 0.656 MMTCO2e = 0.179 MMTCE 2008 - 0.622 MMTCO2e = 0.170

MMTCE

HEEP Update

YearCompanies Reporting

MMTCO2 MMTCE

2002 22 0.530 0.145

2003 20 0.523 0.143

2004 21 0.625 0.170

2005 21 0.681 0.186

2006 21 0.589 0.161

2007 21 0.656 0.179

2008 21 0.622 0.170

Graphical Representation of Fire Protection Emissions of HFCs and PFCs

Reported Fire Protection Emissions of HFCs & PFCs

0.00

0.05

0.10

0.15

0.20

0.25

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Year

Emissions, MMTCE

Revised EU ODS Regulations Regulation (EC) No 1005/2009 effective 1/1/10 The draft new Annex VI on halon critical uses is

undergoing revisions following received comments from the Member States

A main area of contention is end dates for civil aviation - not all member states agree that end dates are required for all applications, although Commission may be flexible on final dates

Target is to have revised draft ready for vote of Regulations Committee on March 23, 2010

Revised EU ODS Regulations Most recent proposal (11/25/09) slips cut-off

dates for most applications by a year (2010) and end dates by 5 years (2025 or 2035)

Dates for aviation critical uses: Cargo compartment fixed systems - cannot be installed

on new aircraft after 2016, end of use exemption is 2035

Cabin/crew compartment portables - 2012, 2025 Engine nacelles and APU - 2012, 2035 Lavatory (potty bottles) - 2011, 2020 Dry bays - 2011, 2035 Inerting of fuel tanks - 2011, 2035

Due account should be taken of ICAO initiatives

HTOC HTOC meeting March 9-11, Montpellier

France 2010 Assessment Report:

Barriers to the free movement of recycled halons A5 Halon banking issues Impact of proposed HFC controls New installations using recycled halons Prolonged equipment use Unusable, contaminated stockpiles Delayed transition and impact on ozone recovery Aviation issues, ICAO leadership/cooperation Monitoring feedstock use

Will be looking for volunteer peer reviewers

HTOC Decision XXI/7: Halons

Support for mandatory dates by when halon alternatives will be used in newly designed aircraft; TEAP/HTOC to report ICAO progress to the 22nd Meeting of the Parties;

Parties that have implemented import and/or export restrictions of recycled halons should consider reassessing their situation;

Parties should refrain from destroying uncontaminated recycled halons before they have considered their domestic, as well as the global long-term future needs for halons;

HTOC Decision XXI/7: Halons

Parties should report their needs for halons to the Ozone Secretariat for use by the TEAP/HTOC in their assessment of halon banks;

Parties to inform, on a regular basis, their users of halons, including the maritime industries, the aviation sector and the military, of the need to prepare for reduced access to halons in the future and to take all actions necessary to reduce their reliance on halons.

HTOC Decision XXI/9: HCFCs and

Environmentally Sound Alternatives TEAP to provide the latest technical and

economic assessment of available and emerging alternatives to HCFCs, and to assess their impact on the environment, including on climate;

TEAP to list all sub-sectors using HCFCs, and provide costs, relative energy efficiency, market share etc., of technologies where low-GWP alternatives are used.

HTOC

Decision XXI/9: HCFCs and Environmentally Sound Alternatives TEAP to compare these alternatives

with other existing technologies, in particular, high-GWP technologies that are in use in the same sectors;

TEAP to identify and characterize barriers to the safe application of low-GWP alternatives;

HTOC

Decision XXI/9: HCFCs and Environmentally Sound Alternatives TEAP to update the information

provided in accordance with Decision XX/8 to inform the Parties of the uses for which low- or no-GWP technologies are or will soon be commercialized, and to predicted the amount of high-GWP alternatives to ozone-depleting substances uses that can potentially be replaced;

HTOC Decision XXI/9: HCFCs and

Environmentally Sound Alternatives Parties:

– To promote policies that avoid the selection of high-GWP alternatives, and which promote the development and availability of low-GWP alternatives to HCFCs and other ODS;

– To consider reviewing/amending policies which are barriers to the use of low- or zero-GWP alternatives to ODS, particularly HCFCs;

HTOC Decision XXI/9: HCFCs and Alternatives

The Executive Committee:– Is to expedite the finalization of its guidelines

on HCFCs;– For projects, particularly those phasing-out

HCFCs ,to consider providing additional funding for additional climate benefits;

– The cost of projects is to take into account climate benefits;

– To consider the effectiveness of low-GWP alternatives to HCFCs, including in the Air Conditioning and refrigeration sectors in high ambient temperature areas in Article 5 countries;

ODS Destruction Decision XXI/2 on management of ODS banks

Multilateral fund pilot projects on ODS destruction in developing countries

Seminar on how to identify and mobilize funds for ODS destruction prior to the OEWG meeting

Climate Action Reserve ODS destruction protocol does not include destruction of halons due to questions about the indirect GWP

Request at January 29 EPA/State Department stakeholder meeting that MP Science Panel clarify the issue of whether halon destruction would provide any climate benefits