The Facts

The Analysis
     Discreet Early Action

     Environmentally Sensitive,      Cooperative Industry

     Significantly Lower
     Emissions Than Initially
     Projected

The Data
     Frost & Sullivan

     US EPA Experiment

     End the Leak-Refill
     Continuum

     Partial Can Education

     New Refrigerant

Based on refrigerant sales data and a study by Frost and Sullivan, a retail sale ban on R134a will:

• Have a negligible impact on emissions of global warming gasses.
  
• Create a $170 million windfall for professional service facilities.
  
• Place the brunt of the economic burden of the reductions on low and fixed income Californians who work on their own air conditioners because the cost of professional service is so high.

With the wide-ranging number of potential global warming reduction alternatives available to them, the Air Resources Board should not be spending extensive agency resources on a proposal that will generate little to nothing in real environmental benefits, but will heavily burden California citizens least able to afford it.

The Facts:
A ban on the commercial availability of automobile air conditioning refrigerant is not warranted at this time, as a discreet “early action item” required by Health and Safety Code §38560.5. The Global Warming Potential (GWP) savings from banning retail sales of R134a will only provide a .04 Million Metric Ton (MMT) of carbon dioxide (CO2) equivalent reduction potential, less than 2% of the 2.4 MMT of CO2 equivalent potential that had originally been projected by California Air Resources Board staff.

Insofar as the nearly $170 million economic burden of this extremely small potential reduction will be born by the California residents who are the least able to afford this economic impact, ie, low and fixed income individuals who are forced to work on their own vehicles due to the high cost of professional service, the potential ban is unfair, discriminatory, environmentally unjust and does not meet, on its face, the statutory requirement of cost-effectiveness.

The Assembly Bill 32 target of a 25 percent reduction (1990 level equivalent) in global warming gasses by 2020 will be met and far exceeded by the automotive refrigerant industry with the introduction of new refrigerants that are currently under development that will yield a GWP reduction by a magnitude of 100. But the safety and operational aspects of these new refrigerants must be resolved before they can be rolled out and use of the current refrigerant restricted, casting doubt on the technical feasibility of an early action ban.

In addition to the promise of emerging new refrigerants and the low comparative GWP reduction and high relative cost of restricting the availability of current automotive refrigerant, especially on those Californians who can least afford it, the automotive air conditioning industry has embarked on self directed efforts to reduce emissions such as by raising the awareness of safe handling through product education as well as container seal improvements, and advocating for the inclusion of a/c system inspection through the state’s Smog Check program to address concerns over a leak-refill cycle.

Thus, a prospective ban on the commercial retail availability of current automotive refrigerant as an AB 32 early action item fails the statutory requirement at §38560 and §38560.5(c) that the state board adopt rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions. A prospective ban should coincide with a cost-effective, technologically feasible alternative refrigerant.

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The Analysis:
Discreet Early Action
The California State Legislature recently enacted legislation, Assembly Bill 32 (Chapter 488, Statutes of 2006), that requires the California Air Resources Board (CARB) to implement measures aimed at capping global warming gasses at 1990 levels by 2020. As part of this legislation, the board is mandated to develop a list of “discreet early action greenhouse gas emission reduction measures” by June 2007, with regulations for these actions being promulgated on or before January 1, 2010 (Health and Safety Code §38560 et seq.).

CARB has pointed to a ban on the retail sale of R134a, used in vehicle air conditioners, as a possible target for early regulatory action under the new law. CARB has expressed three concerns about the do-it-yourself use of R-134a in automotive air conditioners, the can heel, or residue left in the can after completing a recharge, the possible continuous cycle of leak-refill-leak-refill, and the discarding of partially filled cans.

Environmentally Sensitive, Cooperative Industry
The automotive refrigeration products industry has a proven track record of working to retool and reformulate its products to comply with government regulations and other environmental milestones to reduce environmental impact in an effort to contribute positively to California’s air quality.

For example, in older cars, the refrigerant used for the air conditioning system, known as R12 (GWP 2400), was made up of chlorofluorocarbons (CFCs), which have been shown to "eat into" the protective layer of ozone in the earth's upper atmosphere, and also play a part in global climate change.

In response to the ozone threat, the refrigerant industry converted from R12 to a new formulation. All cars built since 1995 have a refrigerant known as HFC-134a (a hydroflourocarbon, also known as R-134a) in their systems and many older cars had their systems converted. The conversion from R12 to R134a (GWP 1300) is an example of how government and industry worked together to find an alternative to a necessary health and comfort part of a vehicle that was found to have an environmental impact.

But while R134a is not an ozone-depleting chemical, it is a greenhouse gas that can increase global climate change. R134a is an improvement over CFCs, and research is continuing to find a replacement for R134a – one that is not a greenhouse gas. There are several new refrigerants (GWP < 50) being tested to determine their safety and viability, but every indication is that new refrigerants will be commercially operational and available by the time Europe’s ban on R134 takes effect at the end of 2011. The new gasses are important not just because they will have an extremely low GWP, but also because, unlike flammables and CO2 refrigerants, these new refrigerants can be safely used in current A/C systems with very little mechanical modification and little need for expensive changes in aftermarket service procedures. With new low GWP gases just around the corner, any potential ban on R134a by California should be coordinated with the introduction of its low GWP replacement, just as R12 was banned upon the availability of R134a. To do otherwise could be to jeopardize the health and safety of the most vulnerable in our society.

Significantly Lower Emissions Than Initially Projected
The Global Warming Potential (GWP) savings from banning retail sales of R134a will only provide a .04 Million Metric Ton of CO2 equivalent reduction potential and not the 2.4 MMT of CO2 potential that had originally been projected by the Air Resources Board staff, less than 2% of staff’s estimate. The staff’s only previous source of information was the automotive air conditioning service industry- an economic segment and conflicted stakeholder group that would realize a financial windfall from the banning of consumer products. Further, the nearly $170 million burden of this extremely small potential reduction will fall squarely on the backs of the California residents who are the least able to afford this burden, low and fixed income individuals who are forced to work on their own vehicles due to the high cost of professional service.

The latest information on the size of the market and the calculable emission potential of consumer handling of R134a is based on a September 2006 economic impact study done by the nationally recognized research firm of Frost & Sullivan, and a can heel study done by the United States Environmental Protection Agency (US EPA) in the summer of 2006. This new information has recently been presented to CARB staff.

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The Data:
Frost & Sullivan
Following are a number of verifiable findings. There are 1,160,000 pounds of R134a sold each year to automotive do-it-yourselfers in California. According to the Frost & Sullivan study, a do-it-yourselfer can buy a can of R134a for less than ten dollars. To have the same amount of refrigerant put into his or her car by a professional mechanic would cost $147.

If all the do-it-yourself business goes to the professional service shops each year there will be an additional cost to low income motorists and a windfall profit to the professional shops of approximately $170 million.

However, not all business would go to the professional mechanic. Less than 50 percent of those surveyed said they would go to a professional technician or mechanic; however, the average price they said they would pay is $32, which means that they might see a mechanic, but are not likely to pay to have the service performed at a price which is almost four times what they want to spend.

Some would go without an air conditioner; however, this scenario results in the release of additional greenhouse gasses due to the increased aerodynamic drag caused by rolling down the windows, which, in turn will burn more gasoline leading to greater CO2 emissions from the car’s tailpipe. A number of users would buy outside the state, some would buy a 30 pound cylinder and share with others, and some would buy an office duster or a boat horn, both of which are filled with the same R134a that is sold for automotive air conditioners. Last, but not least, some would use propane, which is legal to sell in California, as a refrigerant. This not a safe alternative because the use of propane as a refrigerant is likely to cause an explosion- a risk some might take if they are unaware of the danger or cannot afford the service, but live in extremely hot regions of the state like the Central Valley and the Inland Empire.

US EPA Experiment
A US EPA sponsored study, carried out in the summer of 2006, determined that if the do-it-yourselfer uses proper installation procedures, the amount of refrigerant remaining in the can will be vapor only and the same percentage as the amount of refrigerant that remains in the 30 pound cylinder used by the professional mechanic.

The Frost & Sullivan survey shows that 88 percent of do-it-yourselfers use and follow the proper instructions for servicing their automotive air conditioning system. Based on this information, the annual aggregated amount of R134a left in the can after installation, or can heel, would be just 22,000 pounds more than the amount left in the cylinder by the professional mechanic. The packagers of small cans of R134a have all agreed to improve installation instructions to minimize this 22,000 pound can heel loss.

End the Leak-Refill Continuum
The Climate Action Team Report process called for all affected state agencies to submit work plans for greenhouse gas reduction measures. Among the CARB work plan recommendations includes adding a refrigerant leak-tightness test to the “pass” criteria for state’s vehicular inspection and maintenance program (Smog Check). Doing so will prevent both do-it-yourselfers and professional mechanics from the continuous cycle of leak, refill, leak, refill.

Partial Can Education
The Frost & Sullivan study determined that 62 percent of all do-it-yourselfers generally use a full can of R134a. They would not be storing a partially filled can. A quarter of those surveyed said they do store a partially filled can and 88 percent of those who store a can said that they later used the remaining refrigerant. Fourteen percent said they do not store the can but discard the contents of a partially filled can. Using this data and assuming that no refrigerant used by a professional facilities is discarded, it was then calculated that there would be an additional 40,000 pounds of refrigerant discarded by the do-it-yourselfer. Industry is addressing this area of concern on packaging and other point of sale material.

New Refrigerants
There is another compelling reason to not add a retail ban on R134a. Three major chemical manufacturers have replacements for R134a refrigerant that have very low GWP. They will, in all probability, be used in all cars manufactured starting in 2011. A Society of Automotive Engineers (SAE) Alternative Refrigerant System Symposium will be held in June to discuss the alternatives and the timelines for their introduction into the market.

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