Benefits of Addressing HFCs under
         the Montreal Protocol
              October 2015
        Stratospheric Protection Division
        Office of Atmospheric Programs
          Office of Air and Radiation
&EPA
United States
Environmental Protection
Agency                  EPA 430-S-15-001

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    Benefits of Addressing HFCs under the Montreal Protocol
                                  October 2015
                            EXECUTIVE SUMMARY

The United States, Canada, and Mexico have proposed an amendment to the Montreal Protocol
to phase down production and consumption of hydrofluorocarbons (HFCs) and control
byproduct emissions. The proposal includes binding reduction targets for all countries, and
provides access to financial support and extended phasedown time to developing countries. The
proposal builds on the success of the Montreal Protocol, relies on the strength of its institutions,
and realizes climate benefits in both the near and long-term.

HFC use and emissions are rapidly increasing as a result of the phaseout of ozone-depleting
substances (ODS) and growing global demand for air conditioning and refrigeration. Although
safe for the ozone layer, the continued emissions of HFCs - primarily as alternatives to ODS and
also from the byproduct emissions of HFC-23 will have an immediate and significant effect on
the Earth's climate system. Without further controls, it is predicted that HFC emissions could
partially negate the climate benefits achieved under the Montreal Protocol. The proposal calls for
a gradual phasedown of HFCs which will allow for  early transition in sectors where alternatives
are widely available while providing more time and incentive for innovation in deploying
alternatives in other areas.

This analysis estimates projected climates benefits based on adoption of a freeze in HFC
consumption and production (in 2021) for Article 5  parties and on initial reduction steps (in 2019
and 2024) in for non-Article 5 parties. Adopting these provisions would achieve approximately
57-79 gigatons of carbon dioxide equivalent (GtCCheq) (or 57,000-79,000 million metric tons
of carbon dioxide equivalent (MMTCCheq)) cumulatively by 2050, which is about 68% of the
consumption reductions from the full North American proposal.  In 2016, Parties could return to
negotiate the rest of the schedule as well as other provisions. Adoption of the full North
American proposal would produce environmental benefits of 90-111 GtCCheq cumulatively by
2050. Table ES-1 displays the projected cumulative benefits that could be adopted through 2015
and 2016 negotiations.

TABLE ES-1: ESTIMATED BENEFITS OF THE AMENDMENT PROPOSAL
Cumulative HFC Reductions (GtCCheq) through 2050

HFC Phasedown -
Consumption Reductions
Byproduct Controls -
Emissions Reductions
Total*
A5 Freeze & Non-A5
First Steps
57-79

57-79
Remaining Provisions
20
12
32
Total
78-99
12
90-111
 May not sum due to rounding

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            Benefits of Addressing HFCs under the Montreal Protocol - October 2015
1. INTRODUCTION

This paper presents an updated analysis of potential benefits from globally reducing consumption
of hydrofluorocarbons (HFCs) and reducing byproduct emissions of HFC-23 to reflect the 2015
proposed amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer as
submitted by United States, Canada, and Mexico using the same methodology as previous
amendment analysis from the U.S. Environmental Protection Agency (U.S. EPA)1.

2. PROPOSED AMENDMENT TO PHASE DOWN HFC  CONSUMPTION
   AND REDUCE HFC-23 BYPRODUCT EMISSIONS

The governments of the United States of America, Canada, and Mexico proposed an amendment
to the Montreal Protocol to phase down the consumption and production of HFCs and reduce
HFC-23 byproduct emissions. Key elements of this Amendment proposal:
•  Lists 19 HFCs as controlled substances under the Montreal Protocol.
•  Recognizes that there may not be alternatives for all HFC applications today and therefore
   relies on a gradual phase down mechanism with a plateau as opposed to a complete phaseout.
•  Establishes commitments for the developed country (non-Article 5) and developing country
   (Article 5) phasedown of HFC production and consumption while providing additional time
   for Article 5 countries.
•  The amendment uses GWP weighting for HFCs and HCFCs.
•  Includes provisions to limit HFC-23 byproduct emissions resulting  from the production of
   HCFCs and HFCs.
•  Requires reporting on HFC production, consumption, and byproduct emissions.
•  Makes reductions in HFC production and consumption and byproduct emissions eligible for
   funding under the Multilateral Fund for the Implementation of the Montreal Protocol (MLF).
•  Requires licensing of HFC imports  and exports, and import and export controls for non-
   Parties.

After considerable deliberation, these countries have proposed a staged approach that sets a
critical goal of adopting a meaningful but less ambitious amendment this year, along with an
agreement to take up the remaining elements next year. This approach is intended to address a
number of the concerns that have been raised. This revised approach would allow for an
achievable first step of an HFC amendment consisting of initial control and other measures to be
adopted in 2015; and a complete phasedown schedule and additional aspects  to be further
negotiated in 2016.
1 EPA, 2014. Benefits of Addressing HFCs under the Montreal Protocol, My 2014. Accessible at http://confmontreal-
protocol.org/meeting/mop/copl 0-
mop26/presession/Information%20Documents%20are%20available%20in%20English%20onl/MOP-26-INF5.pdf

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            Benefits of Addressing HFCs under the Montreal Protocol - October 2015
3. PROPOSED PHASEDOWN OF HFC CONSUMPTION

3.1.   ASSUMPTIONS FOR ESTABLISHING THE BASELINE AND PROJECTED
   CONSUMPTION
Because FIFCs have replaced HCFCs in many applications in some countries, the baseline used
in the North American proposal is set using historical information while accounting for this
transition. The consumption baseline is depicted in the table below.

TABLE 1: BASELINE EQUATIONS	
   Party
                           Method
 Equation 1 :
 Non-Article
  5 Parties
100%
     / / 2011 HFC Consumption \\
     ' I +2012 HFC Consumption 1
      \+ 2013 HFC Consumption/
                                            + 75%
                                                  / / 2011 HCFC Consumption \\
                                                 ' j +2012 HCFC Consumption I
                                                   \+ 2013 HCFC Consumption/
                                               3

 Equation 2:
  Article 5
   Parties
100%
     // 2011 HFC Consumption \\
      1 +2012 HFC Consumption )
      \+ 2013 HFC Consumption/
                                            + 50%
                                                  it 2011 HCFC Consumption \\
                                                   1 +2012 HCFC Consumption J
                                                   V+2013 HCFC Consumption/
Projected consumption estimates for Article 5 and non-Article 5 from 2015 through 2050 are
shown in Graph 1.
GRAPH 1. PROJECTED HFC CONSUMPTION 2012 THROUGH 2050

               Projected HFC Consumption 2O15 through 2O5O

    «.soo

    4.000

    3,900

    3.OOO

£
3   2-so°

S   iooo

    1,500

    1.000

     SOO
                      Projected Article 5
                      Consumption Range
          uaJO31-1^
                 Projected Non-Article 5
                  Consumption Range
        20 jo
                                       2010
                                       Year
                                                      2040

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             Benefits of Addressing HFCs under the Montreal Protocol - October 2015
3.2.   REDUCTION SCENARIO AND RESULTS
The reduction schedule used for this analysis appears in Graph 2 and Table 2 below. Targets
were set by considering the need to  achieve significant reductions, the likely availability of
alternatives, and other obligations under the Montreal Protocol (e.g., HCFC phaseout).

GRAPH 2. PROPOSED HFC REDUCTION SCHEDULES
HI
0»
Cap (% of Base
:C Fre
100". -I
WW -
8054 •
70* •
<•
50% -
40* •
H
20* -
10X. •
eze and Reduction Steps for Non-Article 5 & Article 5 Countries
fas a per cent of baseline)
— 1 :___.
1
i i
i i
i i
i-—,
i i

MIS 202O 202S 2030 203S 2O4O 2O4S 2OSO
^^ 4lf>101t - «Ml *» i«»p» «» hi i«niK.r •< m Krl4

TABLE 2: PROPOSED HFC REDUCTION SCHEDULES
HFC Consumption and Production Reduction Schedule
Non-Article 5 Parties
Year
2019
2024
2030
2036
Cap (% of Baseline)
90%
65%
30%
15%
Article 5 Parties
Year
2021
2026
2032
2046
Cap (% of Baseline)
100%
80%
40%
15%
The table above shows freeze and Non-A5 steps through 2025 in bold that represent the first step
in our proposed two-step approach for an amendment. The non-bold items are the other steps
that were proposed in our original 2015 submission that we now propose be considered in 2016.

Applying the reduction schedule and baselines to the projected consumption developed as
described above yields HFC consumption reductions as shown in Table 3. Table 3 estimates the
range of cumulative reductions through 2050 of FIFC consumption for the A5  freeze and Non-A5
first steps, the remaining reduction schedule, and the total.
TABLE 3: ESTIMATED BENEFITS OF THE HFC PHASEDOWN

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             Benefits of Addressing HFCs under the Montreal Protocol - October 2015
Cumulative HFC Phasedown Consumption Reductions (MMTCCheq) through 2050

World
A5 Freeze & Non-A5
First Steps
57,000 - 79,000
Remaining Reduction
Schedule
20,000
Total'
78,000-99,000
* May not sum due to rounding

A study by Velders et al.2 indicates that if HFC production were phased out in 2020 instead of
2050, for example, up to 146 GtCCheq (or 146,000 MMTCCheq) of cumulative emissions could
be avoided from 2020 - 2050, and an additional bank of up to 64 GtCCheq (or 64,000
MMTCCheq) could also be avoided in 2050.
3.3.   NATIONAL, REGIONAL, AND GLOBAL EFFORTS
Over the past several years, we have seen a number of countries take action to address HFCs and
these actions are already resulting in benefits. We can expect additional actions in the absence of
an amendment. Graph 3 depicts:
    •   Business as usual in a world absent HFC reduction measures;
    •   Reduced consumption from domestic and regional measures
          o  Includes measures from the European Union, United States, Japan and assumed
             measures from Canada
    •   Reduced consumption from additional measures under the Montreal Protocol (i.e.
       adopting an HFC phase down).

GRAPH 3. NON-ARTICLE 5 CONSUMPTION BENEFITS FOR FULL REDUCTION SCHEDULE
                          Potential for HFC Reductions:
                                   Non-A5 Parties
      2.000 -|

      1.8OO

      1.600
      1.200


      l-OOO -


       BOO


       600 -


       400


       200 -
 Business as Usual absent HFC
    Reduction Measures

                                      Reduced Consumption from
                                    Domestic and Regional Measures
Reduced Consumption from
  Additional Measures:
 Adopting the Amendment
                    2020
                              202i
                                        2O3O      2OJS
                                            Y**rs
                                                           2040
                                                                     2044
                                                                               2050
United States of America

2 Velders, G. J. M, S. Solomon, and J. S. Daniel. Growth of climate change commitments from HFC banks and
emissions. Atmos. Chem. Phys. 14, 4563-4572, 2014.

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             Benefits of Addressing HFCs under the Montreal Protocol - October 2015
The President directed the United States to lead through both international diplomacy and
domestic action. In particular, he directed the U.S. EPA to use its authority through the
Significant New Alternatives Policy (SNAP) Program to encourage private sector investment in
low-emissions technology by identifying and approving climate-friendly chemicals while
prohibiting certain uses of the most harmful chemical alternatives. In addition, the President
directed his Administration to purchase cleaner alternatives to HFCs whenever feasible and to
transition over time to equipment that uses safer and more sustainable alternatives.

In the past year, the U.S. EPA issued two new rules and two notices significantly updating the
lists of acceptable and unacceptable alternative chemicals under the SNAP Program.  In February
2015, several alternatives were added to the acceptability list (subject to use conditions) for use
in the refrigeration and air conditioning sectors, including several hydrocarbons. Hydrocarbons
are already in use in refrigeration and air conditioning applications in Europe and Asia. In July
2015, the U.S. EPA released a final rule that changed the status of certain high-GWP HFCs used
in motor vehicle air conditioning, retail food refrigeration and vending machines, aerosols, and
foam blowing to make them unacceptable because safer, more climate-friendly alternatives are
available. The expected cumulative emission savings are 1.1 gigatons of CCh-equivalent by 2030
and 4.5 gigatons by 2050. In October 2014 and July 2015, the U.S. EPA also issued two
acceptability notices, adding to the list of alternatives acceptable for use in the refrigeration and
air conditioning; aerosols; solvents, coatings and inks; fire suppression and explosion protection;
and foam blowing sectors.

European Fluorinated Gas Regulation
The European Commission recently revised and strengthened their requirements on fluorinated
gases as part of their policy to combat climate change. The previous F-gas regulation was
adopted in 2006 and was aimed at stabilizing European Union (EU) F-gas emissions  at 2010
levels. The new regulation went into effect January 1, 2015.  The intent is  to cut the EU's F-gas
emissions by two-thirds compared with 2014 levels.  Requirements include a European
phasedown and quota system for the supply of HFCs beginning in 2015, along with bans on
certain HFC-containing equipment, and a requirement to destroy or recycle HFC-23 (a
production byproduct). Existing regulation on labeling, refrigerant management and reporting
requirements, and training programs have also been expanded to cover HFCs. The expected
cumulative emission savings are 0.9 gigatons of CCh-equivalent by 2030 and 2.6 gigatons by
2050.

Canada
In March 2015, Environment Canada proposed a permitting  and reporting regime for bulk HFCs.
The proposal is consistent with the provision for a permitting and reporting regime outlined in
the North American Proposal to phase down HFCs under the Montreal Protocol. Additionally,
Environment Canada is in the process of developing a proposal for regulatory measures for
HFCs, following the publication of a Notice of Intent to Regulate Hydrofluorocarbons on
December 6, 2014. Following consultations with industry, Canada is considering an approach
that combines two components: 1. a phase-down of HFC consumption (manufacture, imports and
exports); and 2. prohibitions on specific HFC-containing products,  such as air-conditioning and
refrigeration equipment, foam insulation products and aerosol products. This approach is similar
to the one used to successfully phase out ozone-depleting substances in Canada. Work on

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             Benefits of Addressing HFCs under the Montreal Protocol - October 2015
defining the proposed controls and moving through the regulatory development process is
ongoing. Proposed measures for HFCs in line with the above approach could be published in
2016.

Japanese Fluorinated Gas Regulation
In 2013, Japan enacted a law updating and expanding their existing fluorocarbon regulations.
The objective of the new legislation, which came into force in April 2015, is to reduce HFC
emissions through measures that cover the total life cycle, from manufacture through disposal, of
fluorocarbons and equipment using these gases.  Under the new law, manufacturers and
importers are required to develop HFC phase-down plans that promote non-fluorinated gases or
low-GWP fluorocarbons, and meet national GWP targets and timelines for specific end-uses.
The government has also created mandatory registration/ permission systems for fluorocarbon
process operators (i.e. entities that recover, refill, recycle or destroy fluorocarbons). In addition,
end-users of fluorocarbon-containing equipment are responsible for the proper monitoring and
management of equipment and leaks.

The Climate and Clean Air Coalition to Reduce Short-Lived Climate Pollutants
The Climate and Clean Air Coalition (CCAC) to Reduce Short-Lived Climate Pollutants is a
voluntary initiative launched in 2012 aimed at achieving progress in addressing near-term
contributions to global warming. The CCAC is focusing on HFCs as well as black carbon and
methane, and has sponsored several capacity building activities such as workshops and
conferences focusing on enabling the use of climate-friendly alternatives to high-GWP HFCs and
removing barriers to their adoption. The CCAC is also helping countries inventory their HFC
sectors, and has produced case studies to share information about successful transitions to
climate-friendly alternatives in commercial refrigeration. In addition,  it is sponsoring several
technology demonstration projects, HFC inventories in developing countries, and additional
capacity building efforts.

Intended Nationally Determined Contributions
Countries committed to develop a new international climate agreement by the conclusion of the
U.N. Framework Convention on Climate Change (UNFCCC) twenty first Conference of the
Parties (COP21) in Paris in December 2015. Different countries start from  different initial
situations, development stages, degrees of urbanization, industrial development stages, degrees
of technological maturity, degrees of market development, domestic financing capacities etc.
Countries thus need to transform their economies under very different conditions and at different
phases of growth cycles. Ahead of COP21, countries agreed to publicly outline what post-2020
climate actions they intend to take under a new international agreement, known as their Intended
Nationally Determined Contributions (INDCs). The INDCs will include mitigation goals that
represent a progress beyond current efforts in the country. INDCs can include a range of efforts
including efforts to reduce HFC emissions.

Figure 1 presents a geographic distribution of HFC  policies along with countries participating in
the Climate and Clean Air Coalition.

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FIGURE 1. GEOGRAPHIC DISTRIBUTION OF HFC POLICIES AND CCAC PARTNERS
                                                                 CCAC partners and countries with HFC policies are shaded in a darter color
NORTH AMERICA
Canada an
Mexico H
Undsd States of America
mm

AFRICA

Benin BD
Burkina feso O
Central African Republic D
Chad D
Cote d'hrore D
Egypt H
LATIN AMERICA AND CARIBBEAN
BeizeO
Chile HI
Colombia 31 B
Dominican Republic a



Ethiopia tQ
Ghana D
KenyaD
Kingdom of Morocco D
Libenan
MaJiffl
Paraguay EBD
Peru 31
Uruguay B




Mozambique a
Nigeria D
Republic of Guinea O
Togo B a

EUROPE AND CENTRAL ASIA
Austria a
Denmark BID
Finland Bl
France H
Germany BD
Ireland •
uyBa
Macedonia Q
Moldova 0
Montenegro Q
Netherlands O a
Norway BB

Poland an
Russian Federation H
SerfaiaQ
StoveniaQ
SpainB
c,.,gAaj, m n
owvoenHici
SwrtzeriandHla
United KmgdomDEa

European Commission

WEST ASIA SOUTH ASIA
Iraq !D
Israel H
Jordan B
Yemen 0


Bangladesh B
JapanBD
Mongolian
Republic of Korea 9
Republic of Maldives B


PACIFIC ISLAND SOUTHEAST ASIA
COUNTRIES
Cambodia fl)
Australia HI (3 Laos n
New Zealand BBO FhilippnesBO


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4. BYPRODUCT EMISSIONS OF HFC-23

PROPOSED AMENDMENT AND CURRENT MITIGATION ACTIVITIES
The North American Amendment proposal includes provisions that limit HFC-23 byproduct
emissions (and under our approach these would be taken up in 2016) resulting from the
production of HCFCs and FIFCs. HFC-23 is a potent greenhouse gas that is 14,800 times more
damaging to the Earth's climate system than carbon dioxide. HFC-23 is a known byproduct from
fluorochemical production. HCFC-22 is used primarily as a refrigerant and as a feedstock for
manufacturing synthetic polymers. HCFC-22 is an ODS; non-feedstock production of it is
scheduled for phaseout by 2040 under the Montreal Protocol. However, given the extensive use
of HCFC-22 as a feedstock, its production is projected to continue indefinitely. While a small
amount of HFC-23 is used predominantly in plasma-etching processes in semiconductor
manufacturing, as a fire suppressant, and either neat or as a blend component in cryogenic
refrigeration, the vast majority of HFC-23 produced is not used and is either emitted, captured or
destroyed. The capture and destruction technologies for HFC-23 byproduct emissions is proven
and readily available. Recent studies3 indicate that HFC-23 emissions continue to increase in
developing countries, despite global efforts to curb emissions.

BENEFITS FROM BYPRODUCT CONTROLS
Table 4 estimates the benefits of HFC-23 byproduct emission controls.

TABLE 4: ESTIMATED BENEFITS OF HFC-23 BYPRODUCT EMISSION CONTROLS
Cumulative HFC-23 Byproduct Emission Reductions (MMTCCheq)

World Byproduct Controls
though 2050
12,000
In April 2013, the Executive Committee of the MLF reached an agreement with China to phase
out all HCFC production for consumption by 2030. China is by far the largest Article 5 producer
of HCFC-22 and has 34 out of the 43 identified production lines. While the agreement will phase
out the HCFC-22 production for consumption, this analysis already accounted for the HCFC-22
phaseout as well as the growth in HCFC-22 for feedstock use; thus, no adjustment is necessary.
On September 25, 2015, the United States and China made a joint presidential statement on
climate change which  states that for China, "Actions on HFCs continue to be supported and
accelerated, including  effectively controlling HFC-23 emissions by 2020."
3 Montzka, S. A., L. Kuijpers, M. O. Battle, M. Aydin, K. R. Verhulst, E. S. Saltzman, and D. W. Fahey. et al: Recent increases
in global HFC-23 emissions, Geophysical Research Letters, 37, L02808, doi:10.1029/2009GL041195, 2010.

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             Benefits of Addressing HFCs under the Montreal Protocol - October 2015
5. SUMMARY

This analysis estimates projected climates benefits based on adoption of a freeze in HFC
consumption and production (in 2021) for Article 5 parties and on initial reduction steps (in 2019
and 2024) in for non-Article 5 parties. Adopting these provisions would achieve approximately
57,000-79,000 MMTCCheq cumulatively by 2050, which is about 68% of the consumption
reductions from the full North American proposal. In 2016, Parties could return to negotiate the
rest of the schedule as well as other provisions. Adoption of the remaining provisions would add
an additional 32,000 MMTCCheq of environmental benefits for a total of 90,000-111,000
MMTCCheq cumulatively by 2050. Table 5 displays the projected cumulative benefits that could
be adopted through 2015 and 2016 negotiations.

TABLE 5: ESTIMATED BENEFITS OF THE AMENDMENT PROPOSAL
Cumulative HFC Reductions (MMTCCheq) through 2050

HFC Phasedown -
Consumption Reductions
Byproduct Controls -
Emissions Reductions
Total*
A5 Freeze & Non-A5
First Steps
57,000 - 79,000

57,000 - 79,000
Remaining Provisions
20,000
12,000
32,000
Total
78,000-99,000
12,000
90,000-111,000
* May not sum due to rounding

The analysis assumes the HFC reduction obligations in the proposal by the United States,
Canada, and Mexico are met, and that all Parties (developed and developing countries) continue
to comply with current HCFC phaseout obligations. Although both the HFC proposal and the
HCFC controls would be effective simultaneously, individual countries would still have the
ability to examine their specific conditions and obligations, and determine how to meet the
obligations. Transitions from HCFCs could include interim steps using a range of HFCs in
various end uses, transitioning to low-GWP HFCs and non-fluorinated alternatives (e.g.,
ammonia, hydrocarbons) and continuing to use some amount of HFCs for the foreseeable future
for certain end-uses (e.g., metered dose inhalers for asthmatics).
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