Benefits of Addressing HFCs under
the Montreal Protocol
July 2016
Stratospheric Protection Division
Office of Atmospheric Programs
Office of Air and Radiation
United States
Environmental Protection
Agency EPA 430-R-16-006
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Benefits of Addressing HFCs under the Montreal Protocol
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.l Our goal is to adopt an ambitious HFC phasedown amendment in 2016 that
includes HFC control commitments from both Article 5 (developing) and non-Article 5 (developed)
countries. The agreement should produce significant climate mitigation benefits, and also include
increased financial support that the United States and other countries can provide for the Protocol's
Multilateral Fund (MLF) to enable compliance. 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. The
continued emissions of HFCs - primarily as alternatives to ODS and as byproduct emissions of
HFC-23 - are having an immediate and significant effect on the Earth's climate system. Without
further controls, HFC emissions could largely negate the climate benefits achieved under the
Montreal Protocol. The proposed amendment calls for a gradual phasedown of HFCs, which will
allow for an early transition in sectors where alternatives are widely available while providing
more time and incentive for innovation in deploying alternatives in other areas.
Phasing down HFCs through the Montreal Protocol has a large potential for slowing climate
change by avoiding up to one-half degree Celsius of warming by the end of the century.2 At the
November 2015 27th Meeting of the Parties (MOP-27) in Dubai, the Parties adopted the Dubai
Pathway. The Dubai Pathway commits Parties to "work within the Montreal Protocol to an HFC
amendment in 2016." Adoption of the North American proposal would produce cumulative HFC
consumption reductions of 90-111 GtCO2eq (or 90,000-111,000 million metric tons of carbon
dioxide equivalent (MMTC02eq)) by 2050. Table ES-1 displays the projected cumulative
benefits of adoption of the North American proposal as submitted in 2015 and forwarded by the
Parties for continued consideration in 2016.
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 & Non-A5 Parties
78-99
13
90-111
* Totals may not sum due to independent rounding.
1 This paper only analyzes the amendment proposed by Canada, Mexico and the United States (the "North American
proposal"). Three other proposed amendments have been submitted to the Ozone Secretariat, with different proposed
control measures and dates. They are summarized in section three of this paper.
2 Y. Xu, D. Zaelke, G. J. M. Velders and V. Ramanathan. "The role of HFCs in mitigating 21st century climate
change" Atmospheric Chemistry and Physics 13 (2013): 6083-6089. Accessible from http://www.atmos-chem-
phvs.net/13/6083/2013/acp-13-6083-2013.pdf.
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
1. INTRODUCTION
A phasedown of HFCs under the Montreal Protocol is the best way to reduce the rapidly
growing climate effect of these gases. This paper presents an analysis of potential benefits from
globally reducing consumption of hydrofluorocarbons (HFCs) and reducing byproduct emissions
of HFC-23 in accordance with the North American proposed amendment to the Montreal Protocol
on Substances that Deplete the Ozone Layer as submitted by the United States, Canada, and
Mexico using the same methodology as previous amendment analyses from the U. S.
Environmental Protection Agency (U.S. EPA).3
2. PROPOSED AMENDMENT TO PHASE DOWN HFC CONSUMPTION
AND PRODUCTION AND REDUCE HFC-23 BYPRODUCT
EMISSIONS
The governments of the United States of America, Canada, and Mexico are proposing 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 phasedown mechanism with a plateau as opposed to a complete phaseout;
• Establishes commitments for the phasedown of HFC production and consumption by
developed countries (non-Article 5) and by developing countries (Article 5) with additional time
for Article 5 countries;
• Uses GWP weighting for HFC s and HCFC s;
• Includes provisions to limit HFC-23 byproduct emissions resulting from the production of
HCFCs and HFCs;
• Requires reporting on HFC production, import, export, and byproduct emissions of HFC-23;
• 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);
and
• Requires licensing of HFC imports and exports, and import and export controls from/to
non-Parties.
3. PROPOSED PHASEDOWN OF HFC CONSUMPTION
3.1. ASSUMPTIONS FOR ESTABLISHING THE BASELINE AND PROJECTED
CONSUMPTION
Because HFCs have replaced HCFCs in many applications already, particularly in non-Article 5
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.
3 EPA, 2015 Benefits of Addressing HFC under the Montreal Protocol, October 2015. Accessible at
https://www.epa.sov/sites/production/files/2016-03/documents/2015 benefits of addressing hfcs under the montreal protocol
final clean.pdf.
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
TABLE 1: BASELINE EQUATION
Party
Equation 1:
Non-Article 5
parties
Equation 2:
Article 5
parties
Method
100%
100%
/ / 2011 HFC consumption \ \
I +2012 HFC consumption \
\+ 2013 HFC consumption/
3
\ 1
// 2011 HFC consumption \\
1 +2012 HFC consumption \
\+ 2013 HFC consumption/
3
\ )
+ 75%
+ 50%
// 2011 HCFC consumption \\
1 +2012 HCFC consumption ] \
V+2013 HCFC consumption/
3
^ /
// 2011 HCFC consumption \\
1 +2012 HCFC consumption \ \
V+2013 HCFC consumption/
3
^ /
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
Projected Article 5
Consumption Range
^Tff
1.000
Projected Non-Article 5
Consumption Rang*
2010 2Oli 2020 2O2S 20JO 2OJS
Year
2O4O 2O*S 2O3O
3.2. REDUCTION SCENARIO AND RESULTS
While the Parties to the Montreal Protocol are considering four different amendment
proposals, as noted above, this paper only analyzes the North American proposal.
Therefore, the reduction schedule used for this analysis appears in Graph 2 and Table 2
below. Phasedown steps were set by considering the need to achieve significant reductions to
protect the global climate, the known and likely availability of alternatives, and other
obligations under the Montreal Protocol (e.g., HCFC phaseout).
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
GRAPH 2. PROPOSED HFC REDUCTION SCHEDULES
HFC Freeze and Reduction Steps for Non-Article 5 & Article 5 Countries
(as a percent of baseline)
100% -i
90% -
0) 70% -
"3 60% -
IB
CD
•4- 50% -
o
30% -
20% -
10% -
2015
2020 2025 2030
AS Steps to be considered in 2016
2035 2040 2045 2050
— Non-A5 Steps to be considered in 2016
2055
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%
Applying the reduction schedule and baselines to the proj ected consumption for Article 5 and
non-Article 5 parties yields HFC consumption reductions as shown in Table 3. Table 3 estimates
the range of cumulative reductions through 2050.
TABLE 3: ESTIMATED BENEFITS OF THE HFC PHASEDOWN
Cumulative HFC Phasedown Consumption Reductions (MMTCCheq) through 2050
Non-Article 5 Parties
Article 5 Parties
World*
25,000-37,000
¥0,000-73,000
7S,000-PP,000
* Totals may not sum due to independent rounding.
* Totals do not include benefits from controlling HFC-23 byproduct emissions.
A study by Velders et al.4 indicates that phasing outHFC production in 2020, for example,
prevents up to 146 GtCO2eq (or 146,000 MMTCO2eq) of cumulative emissions from 2020
2050, and an additional bank of up to 64 GtCO2eq (or 64,000 MMTCO2eq) could also be
avoided in 2050.
3.3. OTHER AMENDMENT PROPOSALS
The European Union (EU), India, and a coalition of Pacific Island States submitted proposals in
4 G. J. M. Velders, S. Solomon and J. S. Daniel. "Growth of climate change commitments from HFC banks an
emissions" Atmospheric Chemistry and Physics 14 (2014): 4563-4572. Accessible from http://www.atmos-chem-
phys.net/14/4563/2014/acp-14-4563-2014.html.
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
2015 along with the North American proposal. Each proposal recognizes the differing transition
capabilities of Non-Article 5 and Article 5 countries, as evidenced in Tables 4 and 5 below. The
four proposals suggest a first step or freeze by 2019, with at least two additional steps occurring by
2030 for Non-Article 5 countries. For Article 5 countries, the four proposals call for a freeze date
ranging from 2019 to 2031, with varying numbers of steps.
TABLE 4: COMPARISON OF HFC AMENDMENTPROPOSALS'KEYELEMENTSFORNON-ARTICLESPARTIES
KEY ELEMENTS
Party's Baseline
(GWP -weighted)
Control Measures
for HFC
Production and
Consumption
(percent of
baseline)
NORTH
AMERICAN
PROPOSAL
Average of HFC
production and
consumption in
20 11-20 13 +75% of
average HCFC
production and
consumption in
2011-2013
2019-90%
2024 - 65%
2030 - 30%
2036 - 15%
INDIA
PROPOSAL
Average of HFC
production and
consumption in
20 13-20 15 +25% of
HCFC baseline
(excludes HFC-23)
2016-100%
2018-90%
2023 - 65%
2029 - 30%
2035 - 15%
EUROPEAN
UNION
PROPOSAL
Average of HFC
production and
consumption in
2009-20 12 + 45% of
average HCFC
production and
consumption in
2009-2012.
2019-85%
2023 - 60%
2028 - 30%
2034 - 15%
ISLAND STATES
PROPOSAL*
Average of HFC
production and
consumption in
2009-20 12 + 45% of
average HCFC
production and
consumption in
2009-2012
2017-85%
2021-65%
2025 - 45%
2029 - 25%
2033 - 10%
* Kiribati, Marshall Islands, Mauritius, Federated States of Micronesia, Palau, Philippines, Samoa and Solomon Islands.
TABLE 5: COMPARISON OF HFC AMENDMENT PROPOSALS' KEY ELEMENTS FOR ARTICLE 5 PARTIES
KEY ELEMENTS
Party's Baseline
(GWP -weighted)
Control Measures
for HFC
Production and
Consumption
(percent of
baseline)
NORTH
AMERICAN
PROPOSAL
Average of HFC
production and
consumption in
2011-2013+50%
HCFC production
and consumption in
2011-2013
2021 - 100%
2026 - 80%
2032 - 40%
2046 - 15%
INDIAN
PROPOSAL
Average of HFC
production and
consumption in
2028-2030 + 32.5%
of HCFC baseline
(excludes HFC-23)
2031-100%
2050 - 15%
Phasedown steps are
to be nationally
determined 5 years
in advance for the
next 5 -year period
EUROPEAN
UNION
PROPOSAL
Consumption:
average of HFC and
HCFC consumption
in 2015-2016
Production:
average of HFC
production in 2009-
20 12 + 70% of
HCFC production in
2009-2012
Consumption: 2019
- 100% combined
HCFC/HFC
consumption;
further reduction
steps and timing to
be agreed by 2020
Production
2019 -100% HFC
production
2040 -15% HFC
production
ISLAND STATES
PROPOSAL
Average of HFC
consumption in
2015-2017 + 65% of
HCFC baseline
2020 - 85%
2025 - 65%
2030 - 45%
2035-25%
2040 - 10%
A key takeaway from comparing these proposals is that, with the exception of the Indian
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
amendment proposal, they all call for an early freeze on HFC consumption and production for
Article 5 countries. This early action is vital, as the majority of the benefits will be realized by 2030,
and a freeze well before that year is an essential first step to realizing these benefits.
3.4. NATIONAL, REGIONAL, AND GLOBAL EFFORTS
Over the past several years, we have seen a number of countries take actions to address HFCs.
Even in the absence of an amendment, we can expect additional actions at the national and regional
levels. While these actions have already changed the trajectory of global HFC emissions, these actions
alone are not enough. 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 EU, United States, Japan, and assumed measures
from Canada;
• Reduced consumption from additional measures under the Montreal Protocol (i.e.
adopting an HFC phasedown).
GRAPH 3. NON-ARTICLE 5 CONSUMPTION BENEFITS
Potential for HFC Reductions:
Non-A5 Parties
1.700
Business as Usual absent HFC
Reduction Measures
Reduced Consumption from
Domestic and Regional Measures
Reduced Consumption from
Additional Measures:
Adopting the Amendment
2015
2020
2030 20»
V.-.1--.
204S
204O
United States of America
In June 2013, 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 also
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.
Since the President's direction, the U.S. EPA issued two rules, three notices, and one proposed rule
significantly updating the lists of acceptable and unacceptable alternative chemicals under the
SNAP Program. In February 2015, several alternatives were added to the acceptable list (subject to
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
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 and are now entering the U.S. market. 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 alternatives that are more climate-friendly and pose less overall risk are
available. The expected cumulative emission savings are 1.1 gigatons of CCh-equivalentby 2030
and 4.5 gigatons by 2050. In October 2014, July 2015, and May 2016, the U.S. EPA also issued
three acceptability notices, adding to the list of alternatives acceptable for use in the refrigeration
and air conditioning; solvents, coatings and inks; fire suppression and explosion protection; and
foam blowing sectors. In April 2016, the U.S. EPA issued a proposed rulemaking to change the
status of certain high-GWP HFCs used in chillers, household refrigerator-freezers, foam blowing,
cold storage warehouses, and additional uses in retail food refrigeration.
The U.S. also recognizes that refrigerant management is an important way to reduce climate-
damaging emissions from equipment used for air-conditioning and refrigeration. In November
2015, the U.S. EPA proposed a regulation that would strengthen the existing refrigerant
management requirements and then extend those requirements to HFCs. This rule would further
reduce HFC emissions by an estimated 7 million metric tons of CO2 equivalent in 2025. The U.S.
EPA intends to finalize this rule in 2016.
The U.S. government is a large purchaser of goods and services. To meet the President's goals for
federal leadership to reduce HFC emissions, new executive actions were announced in September
2014 to begin the process to update procurement regulations for federal agencies in order to
promote the use of safer chemical alternatives to HFCs by service and vendor contractors. The
Department of Defense (DoD), General Services Administration, and the National Aeronautics
and Space Administration (NASA) jointly issue the Federal Acquisition Regulation (FAR) for use
by executive agencies in acquiring goods and services. In May 2016, DoD, GSA, and NASA
sponsored a final rule to amend the FAR to address HFCs. The final rule directs government
agencies to procure other alternatives in lieu of high-GWP HFCs, where feasible, and refers to
EPA's SNAP Program for the current list of acceptable alternatives; refers to EPA's pending
regulation to extend refrigerant management requirements to reduce HFC emissions; requires
vendor reporting on use of HFCs (i.e., refrigerants); and supports using reclaimed HFCs where
feasible.
European Fluorinated Gas Regulation
The European Commission revised and strengthened its requirements on fluorinated gases as part
of its policy to combat climate change. The previous F-gas regulation (including the mobile air
conditioning (MAC) Directive) was adopted in 2006 and was aimed at stabilizing EU F-gas
emissions at 2010 levels. The regulation went into effect January 1, 2015, and aims to cuttheEU's
F-gas emissions by two-thirds compared with 2014 levels. Requirements include a European
phasedown and quota system for the supply of HFCs that began in 2015, 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
Canada is in the process of developing a licensing and reporting regime consistent with how the
North American Proposal would phase down HFCs under the Montreal Protocol. Most recently,
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
they published a notice that requires information to be provided on HFCs manufactured, imported
or exported in bulk during the 2015 calendar year. Following consultations with industry, Canada
is considering three approaches: 1) a phasedown of FIFC consumption (manufacture, imports and
exports); 2) prohibitions on specific HFC-containing products, such as air-conditioning and
refrigeration equipment, foam insulation products and aerosol products; and 3) a hybrid approach
that combines elements of the first two. The hybrid approach is similar to the one used to
successfully phase out ozone-depleting substances in Canada. Work on defining the proposed
controls and moving through the regulatory development process is ongoing. The target date for
publication is late 2016.5
Japanese Fluorinated Gas Regulation
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 phasedown 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 and additional capacity-building efforts.
4. BYPRODUCT EMISSIONS OF HFC-23
PROPOSED AMENDMENT AND CURRENT MITIGATION ACTIVITIES
HFC-23 is a potent greenhouse gas that is 14,800 times more damaging to the Earth's climate
system than carbon dioxide. The North American Amendment proposal, as well as two other
proposals, includes provisions that limit HFC-23 byproduct emissions resulting from the
production of HFCs andHCFCs, particularly HCFC-22. HCFC-22 is an ODS used primarily as a
refrigerant and as a feedstock for manufacturing synthetic polymers. Non-feedstock production of
HCFC-22 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 in plasma-etching processes in semiconductor
manufacturing, as a fire suppressant, and either neat or as a blend component in cryogenic
5 The reporting requirement can be found in Canada Gazette, Part I: Vol. 150. No. 24. available at
http://gazette.gc.ca/rp-pr/pl/2016/2016-06-l l/html/notice-avis-eng.php#nl4. For the proposed measures see
Amendments to the Ozone-depleting Substances and Halocarbon Alternatives Regulations, available at
https://www.ec.gc.ca/ozone/default.asp?lang=En&n=77A94123-l&offset=l&toc=show.
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Benefits of Addressing HFCs under the Montreal Protocol - July 2016
refrigeration, the vast maj ority of HFC-23 produced is not used and is either emitted, captured or
destroyed. The capture and destruction technologies for HFC-23 byproduct emissions are proven
and readily available. Yet, recent studies6 indicate that HFC-23 emissions continue to increase in
developing countries, despite global efforts to curb emissions.
BENEFITS FROM BYPRODUCT CONTROLS
TABLE 6: ESTIMATED BENEFITS OF HFC-23 BYPRODUCT EMISSION CONTROLS
Cumulative HFC-23 Byproduct Emission Reductions through 2050 (MMTCCheq)
World Byproduct Controls
13,000
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 of the 43 identified production lines. While the agreement will phase out
HCFC-22 production for consumption, this analysis accounts for the HCFC-22 phaseout as well as
the growth in HCFC-22 production for feedstock use. On September 25, 2015, the United States
and China made a joint presidential statement on climate change that states that, for China,
"Actions on HFCs continue to be supported and accelerated, including effectively controlling
HFC-23 emissions by 2020."
5. SUMMARY
One of the world's most significant climate mitigation opportunities of 2016 is the adoption of
an ambitious amendment to the Montreal Protocol to phase down production and consumption of
HFCs. This analysis estimates the projected climate benefits of phasing down HFCs in
accordance with the proposed North American Amendment to the Montreal Protocol. Adoption
of its provisions would produce cumulative climate benefits of 90,000-111,000 MMTCO2eq
through 2050. Table 7 displays the projected cumulative benefits of adoption of the proposal as
submitted in 2015.
TABLE 7: ESTIMATED BENEFITS OF THE AMENDMENT PROPOSAL
Cumulative HFC Reductions (GtCCheq) through 2050
HFCPhasedown-
Consumption Reductions
Byproduct Controls -
Emissions Reductions
Total
A5 & Non-A5 Parties
78-99
13
90-111
* Totals may not sum due to independent rounding.
Although both the HFC proposal and the HCFC controls would be effective concurrently,
individual countries would still have the ability to examine their specific conditions and
obligations, and to determine how best to meet their obligations under the two regimes. Transitions
from HCFCs could include interim steps using a range of HFCs in various end uses, transit! oning
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).
6 S. A. Montzka, 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 (2010): L02808. Accessible from
http://ontinelibrarv.wilev.com/doi/10.1029/2009GL041195/full.
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