Regulatory Impact Analysis Addendum:
Analysis of the Economic Impact and Benefits of the
Final Rule: Management of Certain
Hydrofluorocarbons and Substitutes Under
Subsection (h) of the American Innovation and
Manufacturing Act of 2020
U.S. Environmental Protection Agency
Stratospheric Protection Division
Office of Atmospheric Programs
1200 Pennsylvania Avenue, NW
Washington, DC 20460
September 2024
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1. Contents
Executive Summary 7
Climate Benefits 8
Compliance Costs 8
Net Benefits 9
Relationship to Previously Estimated Results for Allocation Rules and 2023 Technology Transitions
Rules 10
Chapter 1. Introduction 11
1.1 Statutory Purposes 11
1.2 Summary of Regulatory Requirements 12
1.3 Regulated Community 14
Chapter 2. Overview of the Analysis 14
2.1 Introduction 14
2.2 Organization of the Analysis 15
2.3 Years of Analysis 17
2.4 Factors Analyzed 17
2.5 Vintaging Model 17
2.6 Regulatory Option 18
2.7 Uncertainty 18
Chapter 3. Methodology 19
3.1 Reference Case and Relationship to Prior Analyses 19
3.2 Equipment Characterization 22
3.3 Marginal Abatement Cost Model 33
3.4 Other Costs from Rule Requirements 41
3.5 Monetization of Emissions Benefits 49
3.6 Other Potential Benefits of this Rule 50
Chapter 4. Compliance Costs 51
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4.1 Leak repair and inspection, reclamation, and fire suppression requirements 51
4.2 Disposable cylinder management requirements 53
4.3 RCRA alternative standards 53
4.4 Recordkeeping and reporting requirements 54
Chapter 5. Climate Benefits 55
5.1 Consumption and Emission Reductions 55
5.2 Benefits of Reducing HFC Emissions 57
5.3 Monetized Climate Benefits Results 60
Chapter 6. Comparison of Costs and Benefits 65
Chapter 7. Environmental Justice 67
7.1 Introduction and Background 67
7.2 Environmental Justice at EPA 68
7.3 Environmental Justice Analysis for this Rule 69
7.4 Aggregate Average Characteristics of Communities Near Potentially Affected Facilities 71
7.5 Previous Violation and Enforcement Actions 74
7.6 Conclusion 76
References 77
Appendices: 83
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2. List of Tables
Table 3-1: HFC Consumption under original BAUand reference case (MMTEVe) 20
Table 3-2: Estimated Installed Stock (MT) and Emissions (MT) by Equipment Type (2025) 23
Table 3-3: Estimated Installed Stock (MT) and Leak Emissions (MT) by Equipment Type (2025) 25
Table 3-4: Apportionment of Appliance Types by Refrigerant Charge Size 27
Table 3-5: Affected Refrigerant-Containing Appliance Assumptions by Appliance Sector, Type, and Size
29
Table 3-6: Service Demand of HFCs for Applicable RACHP Subsectors in 2029 31
Table 3-7: Summary of HFC reclaim and consumption 31
Table 3-8: Modeled Recovery and Service Demand for HFCs in 2029 (RACHP only) 32
Table 3-9: Summary of abatement measures modeled and key factors evaluated to derive MAC estimates
35
Table 3-10: Applicability of Requirements by Appliance Sector and Equipment Type 35
Table 3-11: Estimated Distances for Disposable Cylinder Transportation Compared with BAU (Miles)" A3
Table 3-12: Additional Disposable Cylinder Cost Assumptions 44
Table 3-13: Labor Rates 46
Table 4-1: Incremental Annual Compliance Costs of MAC Abatement Measures (Millions 2022$) 51
Table 4-2: Estimated Compliance Costs for Cylinder Management Provisions (Millions 2022$) 53
Table 4-3: Total Respondent Burden Costs Over the Three-year ICR Period (2023$s) 54
Table 4-4: Total Respondent Burden Costs Over the Three-year ICR Period (2022$s) 55
Table 5-1: Annual Incremental Consumption Reductions (MMTCChe) for ER&R Rule - Base Case
Scenario 56
Table 5-2: Annual Incremental Emissions Reductions (MMTCChe) for ER&R Rule - Base Case Scenario
57
Table 5-3: Undiscounted Monetized Climate Benefits 2026-2050 (2022$)ab c d 61
Table 6-1: Summary of Annual Incremental Undiscounted Climate Benefits, Costs, and Net Benefits in
Base Case Scenario for the 2026-2050 Timeframe (millions of 2022$)a b c d e f 65
Table 6-2: Present Value of Incremental Climate Benefits, Costs, and Net Benefits by type of rule
provision in Base Case Scenario for the 2026-2050 Timeframe (millions of 2022$, discounted to
2024)'d 67
Table 7-1: Overall Community Profile and 2019 AirToxScreen Risks for Communities Near Identified
Facilities 72
Table 7-2: Number of facilities falling under one or more environmental compliance regime 74
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3. List of Acronyms
AC
Air conditioning
AIM Act
American Innovation and Manufacturing Act of 2020, codified at 42 U.S.C.
ALD
Automatic Leak Detection
ASHRAE
American Society of Heating, Refrigerating and Air-Conditioning Engineers
BAU
Business as usual
CAA
Clean Air Act
CARB
California Air Resources Board
CC
Comfort cooling
CFC
Chlorofluorocarbon
C02
Carbon dioxide
CONUS
Contiguous United States
CR
Commercial refrigeration
CWA
Clean Water Act
DSCIM
Data-driven Spatial Climate Impact Model
EAV
Equivalent annualized value
ECHO
Enforcement and Compliance History Online
EPA
Environmental Protection Agency
EO
Executive Order
ER&R
Emissions Reduction and Reclamation
FrEDI
Framework for Evaluating Damages and Impacts
FRS
Facility Registry Service
GDP
Gross Domestic Product
GHGs
Greenhouse gases
GIVE
Greenhouse Gas Impact Value Estimator
GWP
Global Warming Potential
HCFC
Hydrochlorofluorocarbon
HFCs
Hydrofluorocarbons
HFOs
Hydrofluoroolefins
IAM
Integrated Assessment Model
ICR
Information Collection Request
IPCC
Intergovernmental Panel on Climate Change
IPR
Industrial process refrigeration
IWG
Interagency Working Group on the SC-GHG
MAC
Marginal abatement cost
MACC
Marginal abatement cost curve
MT
Metric ton
MTC02eq
Metric tons of C02 equivalent
MMTC02eq
Million metric tons of CO2 equivalent
NPDES
National Pollutant Discharge Elimination System
NPRM
Notice of Proposed Rulemaking
NPV
Net Present Value
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Table 7-3: Clean Water Act Compliance Status and Recent Enforcement History by Facility
Table 7-4: Resource Recovery and Conservation Act (RCRA) Compliance Status and Recent
Enforcement History by Facility
Table 7-5: Clean Air Act (CAA) Compliance Status and Recent Enforcement History by Facility
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NSPS/EG
New Source Performance Standard / Emission Guidelines
ODS
Ozone-depleting substances
O&M
operations and maintenance
PV
Present value
RACHP
Refrigeration, AC, and heat pump
RCRA
Resource Conservation and Recovery Act
RIA
Regulatory Impact Analysis
RMP
Refrigerant Management Program
SBREFA
Small Business Regulatory Enforcement Fairness Act of 1996
SC-CH4
Social Cost of Methane
SC-CO2
Social Cost of Carbon
SC-GHG
Social Cost of Greenhouse Gases
SC-HFCs
Social cost of HFCs
SC-N2O
Social Cost of Nitrous Oxide
SISNOSE
Substantial Number of Small Entities
U.S.
United States
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Executive Summary
This Regulatory Impact Analysis (RIA) addendum provides an assessment of the costs and benefits of
the final rule implementing provisions under subsection (h) of the American Innovation and
Manufacturing Act of 2020, codified at 42 U.S.C. § 7675 (AIM Act or the Act), titled Phasedown of
Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h)
of the American Innovation and Manufacturing Act of2020, also referred to in this document as the
Emissions Reduction and Reclamation (ER&R) rule. Subsection (h) of the AIM Act, entitled
"Management of regulated substances," directs the United States (U.S.) Environmental Protection Agency
(EPA) to promulgate regulations to control, where appropriate, any practice, process, or activity regarding
the servicing, repair, disposal, or installation of equipment that involves: a regulated substance (used
interchangeably with "HFCs" in the final rulemaking and in this RIA addendum), a substitute for a
regulated substance, the reclaiming of a regulated substance used as a refrigerant, or the reclaiming of a
substitute for a regulated substance used as a refrigerant.
This rulemaking follows an already finalized rule issued separately under the AIM Act, Phasedown of
Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program Under the American
Innovation and Manufacturing Act (Allocation Framework Rule, 86 FR 55116, October 5, 2021), as well
as a later rule for the same program, Phasedown of Hydrofluorocarbons: Allowance Allocation
Methodology for 2024 and Later Years (2024 Allocation Rule, 88 FR 46836, July 20, 2023)/ This
rulemaking also follows the final rule issued under subsection (i) of the AIM Act, Phasedown of
Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under the American
Innovation and Manufacturing Act of2020 (2023 Technology Transitions Rule, 88 FR 73098, October
24, 2023).2 The analysis presented in the sections below provides estimated economic costs and
environmental impacts of the provisions of the ER&R rule. The analysis also provides a comparison of
these costs and benefits with those assessed for the previously finalized 2023 Technology Transitions and
Allocation Rules to provide the public with an understanding of any potential changes in economic and
environmental impacts relative to existing regulations. Results and methods from these analyses are
referenced throughout this document. As with the 2024 Allocation Rule analysis and the 2023
Technology Transitions Rule analysis, this document is presented as an addendum to the original
Allocation Framework RIA. In addition, for the purposes of identifying potential environmental justice
1 Throughout this document, we use "Allocation Framework RIA" and "2024 Allocation Rule RIA Addendum" to refer to the
analyses of these rules. We use "Allocation Rules" and "Allocation Rules RIA" to refer to combined or cumulative effect of
those two rules; i.e., the Allocation Framework RIA as updated by the 2024 Allocation Rule RIA Addendum.
2 Throughout this document, we use "2023 Technology Transitions RIA" to refer to the analysis of this rule, noting this analysis
included the Allocation Rules RIA as the reference case from which costs and benefits were derived.
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issues, the analysis presents EPA's assessment of the characteristics of communities near facilities
reclaiming HFCs that are expected to be affected by the rule.
This analysis is intended to provide the public with information on the relevant costs and benefits of
this rule and to comply with executive orders. While significant, the estimated benefits detailed in this
document are considered incidental and secondary to the rule's objectives of serving the purposes
identified in subsection (h) of the AIM Act, including maximizing reclamation and minimizing releases of
certain hydrofluorocarbons (HFCs) from equipment.
Climate Benefits
The climate benefits of this rule derive from reducing damages from climate change induced by
reduced emissions of greenhouse gases (GHGs), specifically HFCs. The reduction in HFC emissions stem
from provisions contained in the final rule aimed at maximizing reclamation and minimizing the release
of certain HFCs and substitutes. The benefits of avoided climate damages are monetized using the same
social cost of HFCs (SC-HFCs) estimates applied in the proposal RIA addendum and are presented in
Table ES-1. As discussed in the proposal RIA the methodology underlying these SC-HFC estimates are
consistent with the interim social cost of greenhouse gas (SC-GHG) estimates recommended by the
Interagency Working Group on the SC-GHG (IWG) under Executive Order 13990. In our base case
estimate of incremental climate benefits, the final rule's provisions are estimated to produce a present
value (PV) of climate benefits of $8.4 billion over 2026 to 2050, in 2022 dollars and discounted to 2024
at 3 percent. We also present the net climate benefits using updated SC-HFC estimates that reflect
scientific advances, including the latest evidence on appropriate consumption-based discounting for
intergenerational impacts.
Compliance Costs
Incremental compliance costs stem from factors including industry transitions in service and
maintenance practices as well as installation of equipment required to comply with provisions contained
in the final rule. These include leak repair and inspection costs as well as Automatic Leak Detection
(ALD) system costs for owners and operators of affected equipment. Incremental costs also stem from
recordkeeping and reporting requirements detailed in the final rule. Reducing HFC emissions due to
fixing leaks earlier will also be anticipated to lead to savings for some system owner/operators, as less
new refrigerant would need to be purchased to replace leaked refrigerant. The estimated combined net
incremental compliance costs (costs less anticipated savings) stemming from all provisions contained in
the final rule are shown in Table ES-1 in 2022 dollars, discounted to 2024 at 2 percent, 3 percent, and 7
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percent.3 The present value of total compliance costs resulting from provisions contained in the rule is
estimated to be $1.5 billion at a 2 percent discount rate, $1.3 billion at a 3 percent discount rate, or $0.9
billion at a 7 percent discount rate. The equivalent annual value for each is $77 million, $77 million, and
$76 million, respectively.
Net Benefits
The net benefits of the final rule are estimated as the climate benefits minus the net compliance costs
(i.e., including any monetary benefits from reduced need of HFCs) in each year. Undiscounted annual
costs, benefits, and net benefits for select years over the 2026-2050 time period are presented in Table
ES-1, along with the present value and equivalent annualized value at various discount rates. End of year
discounting is used throughout this document. When a discount rate of 2 percent is used for the costs, the
present value of the incremental net benefits is estimated at $6.9 billion. When a discount rate of 3 percent
is used for the costs, the present value of the incremental net benefits is estimated at $7 billion. When a
discount rate of 7 percent is used for the costs, the present value of the incremental net benefits is
estimated at $7.5 billion. These estimates are equivalent to $403-$404 million in incremental annual net
benefits over a 25-year period.
Table ES-1: Summary of Undiscounted Annual Values, Present Values, and Equivalent Annualized
Values select years for the 2026-2050 Timeframe for Estimated Compliance Costs, Benefits, and Net
Benefits for this Rule (millions of2022$, discounted to 2024) - Base Case Scenario a-b-cAe
Year
(limine
IkniTils
Cosls
V'( lUiK'I'ils
2026
$428
$92
$336
2030
$102
$574
2035
so i3
$87
$526
2040
S4w->
$67
$399
2045
$3 15
$51
$264
2050
s:o3
$52
$211
Discouni rale
3"'ii
2"i.
3v
7%
2"/i<
3v
7%
PV
$8,356
$1,499
$1,335
$884
$6,857
$7,021
$7,471
EAV
$480
$77
$77
$76
$403
$403
$404
3 Results using the 2 percent discount rate were not included in the analysis for the proposal for this action. The 2003 version of
OMB's Circular A-4 had generally recommended 3 percent and 7 percent as default rates to discount social costs and benefits.
The analysis of the proposed rule used these two recommended rates. In November 2023, OMB finalized an update to Circular
A-4, in which it recommended the general application of a 2 percent rate to discount social costs and benefits (subject to regular
updates), which is an estimate of consumption-based discount rate. Given the substantial evidence supporting a 2 percent
discount rate, we include results calculated using a 2 percent discount rate consistent with the update to Circular A-4. While
climate benefits are calculated using the same SC-HFC estimates used in the proposal RIA addendum, we also present in
Appendix J the climate benefits of the final rule using a new set of SC-HFC estimates that incorporate recent research and
methodological advances, including an updated approach to discounting intergenerational impacts.
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a Benefits include only those related to climate. Climate benefits are based on changes (reductions) in HFC
emissions and are calculated using four different estimates of the social cost of HFCs (SC-HFCs): model average at
2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate. For the presentational
purposes of this table, we show the benefits associated with the average SC-HFC at a 3 percent discount rate. See
Chapter 5 for more discussion of the SC-HFC methodology.
bRows may not appear to add correctly due to rounding.
0 Present values are calculated using end of year discounting.
d The annualized present value of costs and benefits are calculated as if they occur over a 25-year period.
e The PV for the net benefits column is found by taking the difference between the PV of climate benefits at 3
percent and the PV of costs discounted at 7 percent, 3 percent or 2 percent. Because the SC-HFC estimates reflect
net climate change damages in terms of reduced consumption (or monetary consumption equivalents), the use of the
social rate of return on capital (7 percent under OMB Circular A-4 (2003)) to discount damages estimated in terms
of reduced consumption would inappropriately underestimate the impacts of climate change for the purposes of
estimating the SC-HFC. See Chapter 5 for more discussion.
Relationship to Previously Estimated Results for Allocation Rules and 2023
Technology Transitions Rules
EPA has previously estimated costs and benefits of the HFC phasedown, which are detailed in the
Allocation Framework RIA and 2024 Allocation Rule RIA Addendum. EPA has also estimated further
incremental costs and benefits of the 2023 Technology Transitions Rule, detailed in 2023 Technology
Transitions Rule RIA Addendum. The final ER&R Rule focuses on statutory provisions under the AIM
Act that are separate from those addressed in the Allocation Framework Rule and 2023 Technology
Transitions Rules. However, in order to avoid double counting or overestimating of costs and benefits, for
the purposes of this analysis EPA's prior estimates are assumed to be the status quo from which
incremental benefits may be calculated. Specifically, the compliance pathways and associated costs and
benefits evaluated in the 2023 Technology Transitions Rule RIA Addendum serve as the reference case4
for this analysis, thus ensuring that results presented in this document are reflective of the most up-to-date
policy status quo.
As detailed in the Allocation Framework Rule RIA, 2024 Allocation Rule RIA Addendum, and 2023
Technology Transitions Rule RIA Addendum, EPA relied upon a marginal abatement cost curve
(MACC) approach in order to estimate the full set of industry transitions and associated compliance costs
required to meet statutory requirements. Analysis for this rule builds on this previously used methodology
by adding on additional measures required by the final ER&R Rule and evaluating their incremental
impact relative to the previously modeled set of transitions.
4 Incremental costs and benefits in this analysis calculated relative to a policy status quo derived from EPA's previous analyses
conducted for the Allocation and 2023 Technology Transitions Rules. This status quo is referred to as a "reference case" rather
than "baseline" throughout this document to avoid confusion with the statutory baseline for the Allocation Rules.
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Results from this analysis indicate that the final rule will yield incremental HFC emissions reductions
relative to the previously modeled compliance pathways / However, the extent of these incremental
benefits depends in part on whether some of the HFC consumption- and emissions-reducing activities
required by this final rule would have already been undertaken by industry in order to comply with, or
otherwise address market outcomes from, the Allocation and 2023 Technology Transitions rules. As
detailed in the 2023 Technology Transitions RIA Addendum, the precise set of transitions that will be
undertaken by industry in response to both the Allocation and 2023 Technology Transitions Rules is
uncertain, leading to a range in potential incremental benefits.
For the primary, base case analysis presented in this RIA Addendum, all measures found to be
required to meet compliance with the Allocation and 2023 Technology Transitions Rules, based on EPA's
prior analyses, are assumed to occur in the reference case. Additional measures included in EPA's prior
analyses as possible industry outcomes that are not explicitly required to meet compliance with the
Allocation and 2023 Technology Transitions rules are excluded. These include measures such as
improvements to leak repair, enhanced recovery, and transitions in the fire suppression sector. Given the
uncertainty regarding whether industry may undertake these measures in the absence of explicit
requirements, in Appendix F EPA has also provided an alternative scenario where we assume that these
measures do occur as reference case assumptions, effectively illustrating a lower-bound of the
incremental benefits of the final ER&R rule.
More details on these assumptions can be found in Chapter 3 as well as the appendices accompanying
this document. Finally, EPA notes that these assumptions are made for technical analytic purposes and to
avoid double counting of benefits. They should not be interpreted as a reflection of the merits of any
particular provision contained in the final rule.
Chapter 1. Introduction
1.1 Statutory Purposes
This Regulatory Impact Analysis (RIA) addendum evaluates the impact associated with the Final
Rulemaking referred to in this document as the "Emissions Reduction and Reclamation" or ER&R rule.
Under the American Innovation and Manufacturing Act of 2020 (the AIM) Act or the Act), the United
States (U.S.) Environmental Protection Agency (EPA) is directed under subsection (h), "Management of
Regulated Substances," to promulgate certain regulations for purposes that include maximizing
5 However, the schedule for the production and consumption phasedown is not made more stringent than the schedule under
subsection (e)(2)(C) of the AIM Act (i.e., the production and consumption caps contained in the Allocation Rules are
unchanged).
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reclamation and minimizing releases of certain hydrofluorocarbons (HFCs), those which are designated as
regulated substances under the Act. Subsection (h)(1) of the AIM Act authorizes EPA to establish
regulations to control, where appropriate, practices, processes, or activities regarding the servicing, repair,
disposal, or installation of equipment, for purposes of maximizing the reclamation and minimizing the
release of HFCs from equipment and ensuring the safety of technicians and consumers. This rule
implements the purposes of this statutory provision and is designed to serve the purposes identified in it
of maximizing reclamation and minimizing releases of HFCs from equipment, as well as ensuring the
safety of technicians and consumers. The requirements in this rule will also support the domestic
phasedown of HFCs and the overall implementation of the AIM Act.
Among other things, subsection (h) also provides for the Agency to consider options to increase
opportunities for reclaiming HFCs used as refrigerants and provides that the Agency may coordinate
regulations carrying out subsection (h) of the AIM Act with similar EPA regulations. Those regulations
could, for example, include those implementing the refrigerant management program established under
Title VI of the Clean Air Act (CAA).
1.2 Summary of Regulatory Requirements
Pursuant to subsection (h) of the AIM Act, EPA is requiring the following:
• Applying a suite of leak repair requirements to refrigerant-containing appliances, including
comfort cooling (CC)6, commercial refrigeration (CR), and industrial process refrigeration
(IPR) appliances, containing 15 or more pounds of a refrigerant containing a
hydrofluorocarbon (HFCs) or a substitute for an HFC with a global warming potential (GWP)
above 53 (e.g., would not apply to carbon dioxide (CO2), ammonia, certain
hydrofluoroolefins (HFOs), and other substitutes for HFCs with a GWP of 53 or below).7
This includes:
o Requiring annual leak inspection for all CR and IPR appliances containing 15 pounds
up to 500 pounds of such refrigerant upon discovering the applicable leak rate
threshold (20% per year and 30% per year for CR and IPR appliances, respectively)
is exceeded.
6 EPA is exempting from the suite of leak repair requirements under subsection (h) any refrigerant-containing appliance used for
the residential and light commercial air conditioning and heat pumps subsector.
7 For brevity, unless otherwise stated, in this document we use the term "refrigerant" to include regulated HFCs and substitutes
for HFCs with a GWP greater than 53.
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o Requiring annual leak inspection for all CC and other appliances containing 15
pounds of such refrigerant upon discovering the applicable leak rate threshold (10%
per year) is exceeded,
o Requiring quarterly leak inspection for all CR and IPR appliances that contain 500
pounds or more of such refrigerant upon discovering the applicable leak rate
threshold is exceeded (unless ALD equipment meeting certain requirements is used
for compliance).
o Requiring repair of leaks and initial and follow-up verification tests on the repairs for
all appliances containing 15 or more pounds of such refrigerant (i.e., CC, CR, and
IPR) when the applicable leak rate threshold is exceeded,
o Allowing owners/operators of all CC, CR, and IPR appliances containing 15 or more
pounds of such refrigerant to request extensions to the leak repair and retrofit
timeline.
o Applying recordkeeping and reporting requirements associated with leak inspection
and leak repair to appliances containing 15 pounds or more of such refrigerant.
Installation and use of ALD systems for CR and IPR appliances containing 1,500 pounds or
more of a refrigerant for new appliances installed on or after January 1, 2026, and for existing
appliances installed on or after January 1, 2017, and before January 1, 2026, as of January 1,
2027.
The servicing and/or repair of refrigerant-containing equipment to be done to with reclaimed
HFC refrigerants as of January 1, 2029, in the following RACHP subsectors: supermarket
systems, refrigerated transport, and automatic commercial ice makers.
For the servicing, repair, disposal, or installation of fire suppression equipment that contains
HFC, the servicing and/or repair of fire suppression equipment with recycled HFCs as of
January 1, 2026, and the initial installation of fire suppression equipment with recycled HFCs
as of January 1, 2030.
Requiring as of January 1, 2028, that disposable cylinders that have been used for the
servicing, repair, or installation of refrigerant-containing equipment be transported to an
entity in the supply and disposal chain (e.g., a distributor, wholesaler, refrigerant repackager,
an EPA-certified reclaimer, or a landfill or metal-recovery operator) and that such entities
remove or ensure removal (e.g., by forwarding to an EPA-certified reclaimer) of all HFCs
from disposable cylinders prior to discarding the cylinder.
Requiring that disposable cylinders that have been used for the servicing, repair, or
installation of fire suppression equipment be transported to a fire suppressant recycler and
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that fire suppressant recyclers remove all HFCs from disposable cylinders prior to discarding
the cylinder.
• Finally, EPA is establishing alternative Resource Recovery and Conservation Act (RCRA)
standards for ignitable spent refrigerants when recycled for reuse, as the term is to be defined
under RCRA. EPA is stipulating that the 40 CFR part 266 Subpart Q RCRA alternative
standards apply to HFCs and their substitutes that are lower flammability ignitable spent
refrigerants.
1.3 Regulated Community
The HFC industry is composed of several types of entities. As noted in the RIA for the Allocation
Framework Rule, entities potentially affected by this previous action include those that produce, import,
export, destroy, use as a feedstock, reclaim, package, or otherwise distribute bulk HFCs. This analysis—
which serves as an addendum to the above-mentioned Allocation Framework RIA—assesses a final rule
under subsection (h) of the AIM Act that regulates certain practices, processes, or activities regarding the
servicing, repair, disposal, or installation of equipment, for purposes of maximizing the reclamation and
minimizing the release of HFCs from equipment and ensuring the safety of technicians and consumers.
This rule affects certain entities who own, operate, service, repair, recycle, dispose, or install equipment
containing HFCs or their substitutes, as well as those who recover, recycle, or reclaim HFCs or their
substitutes. Manufacturers or sellers of equipment containing HFCs, or their substitutes may also be
potentially affected. A detailed list of industries potentially affected by this rule can be found in Appendix
H.
Chapter 2. Overview of the Analysis
2.1 Introduction
The purpose of this RIA addendum is to provide the public with information on the relevant costs and
benefits of this action, as finalized, and to comply with executive orders. The document contains results
of a costs and benefits assessment to help EPA and the public evaluate the impact of this final rulemaking
across the affected businesses. Costs and benefits presented in this analysis include compliance costs
(including recordkeeping and reporting costs), climate benefits, and combined net benefits.
Given that the rule establishes an emissions reduction and reclamation program for the management
of HFCs, which are subject to previously finalized rulemakings under the AIM Act, EPA relied on
previous analyses conducted for the Allocation Framework Rule (86 FR 55116; October 5, 2021), the
2024 Allocation Rule (88 FR 46836; July 20, 2023), and 2023 Technology Transitions Rule (88 FR
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73098; October 24, 2023) as a starting point for the assessment of costs and benefits of this rule. We then
evaluated how the provisions contained in this final rulemaking would yield potential incremental
impacts.
In addition to a cost and benefits analysis, EPA conducted an environmental justice analysis
evaluating facilities and surrounding communities that may be impacted by this rule. Following the
analytical approach used in the Allocation Framework Rule RIA, the 2024 Allocation Rule RIA
Addendum, and 2023 Technology Transitions Rule RIA Addendum, EPA has provided demographic data
and the cancer and respiratory risks to surrounding communities.
2.2 Organization of the Analysis
The analysis contained in this document is organized as follows:
Chapter 3 summarizes key methodological assumptions relied upon for this analysis, including
discussion of EPA's approach for evaluating incremental impacts relative to previous rulemakings and the
marginal abatement cost (MAC) approach used for modeling the impact of regulatory requirements in this
rule. Chapter 3 also summarizes assumptions and underlying data regarding the types of equipment
affected by this rule. This includes equipment that relies on HFCs in the fire suppression, commercial
refrigeration, industrial process refrigeration, and comfort cooling sectors. Using data from EPA's
Vintaging Model, equipment is broken out by estimated average charge size (in pounds of refrigerant) and
assumed leak rate.
Chapter 4 provides an assessment of the anticipated compliance costs resulting from the
requirements contained in the final rule, including results from the MAC modeling approach. Estimated
incremental costs are relative to those previously estimated by EPA for the Allocation and 2023
Technology Transitions Rules.
Chapter 5 provides an assessment of the anticipated environmental benefits resulting from the
requirements contained in the final rule. As with results in chapter 4, estimated incremental benefits are
relative to those previously estimated by EPA for the Allocation and 2023 Technology Transitions Rules.
This chapter also provides details on the methodology used to calculate the social cost of HFCs (SC-
HFCs).
Chapter 6 combines the compliance costs and climate benefit estimates from the preceding chapters
to provide an assessment of total net benefits associated with the rule.
Chapter 7 covers the environmental justice analysis conducted for the rule. This analysis builds on
the environmental justice analysis conducted for the Allocation and 2023 Technology Transitions Rules
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and evaluates the demographic characteristics and baseline exposure of the communities near facilities
that reclaim HFCs.
Appendices A and B provide details on underlying data and assumptions used to estimate the costs
and benefits of leak repair and inspection provisions contained in the final rule and the specific leak rate
assumptions derived from EPA's Vintaging Model.
Appendix C provides detailed cost estimates by equipment category for the leak repair and
inspection provisions contained in the final rule. These estimates were used to model abatement costs on a
dollar-per-carbon dioxide equivalent (CC>2e)-ton basis for the MAC methodology.
Appendix D provides estimates of the servicing demand for equipment affected by reclamation
provisions contained in the final rule, by HFC gas.
Appendix E provides additional details on assumptions made in order to model requirements
contained in the final rule on a dollar-per-CChe-ton basis for the MAC methodology and a summary of
mitigation options modeled and estimated costs.
Appendix F provides results under an alternative reference case scenario in which industry is
assumed to undertake more leak repair and recovery activity in the reference case (i.e., in the absence of
this rulemaking), thus illustrating a lower bound of the potential incremental benefits of this rule.
Appendix G provides a Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996
analysis of estimated impact to small entities, including small businesses and small governments,
associated with establishing the leak repair and inspection provisions and ALD requirements to HFC and
substitutes for HFCs.
Appendix H lists the industries that might be affected by this rule.
Appendix I provides annual SC-HFC estimates used to estimate the climate benefits of this rule.
These values are consistent with the SC-HFC estimates used in the proposal RIA and in previous analysis
conducted for the Allocation and 2023 Technology Transitions Rules.
Appendix J provides estimated climate benefits of this rule using updated SC-HFC estimates. These
values were calculated following the methodology set forth in the EPA Report on the Social Cost of
Greenhouse Gases: Estimates Incorporating Recent Scientific Advances.
Appendix K provides a sensitivity analysis based on the assumed cost of reclaimed refrigerant vis a
vis virgin refrigerant.
16
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Appendix L provides a sensitivity analysis based on alternative ALD installation requirements
considered for the final rule.
Appendix M provides additional details on the evaluation of potential costs and benefits of the
requirement that disposable cylinders that contain HFCs and that have been used in the service, repair or
installation of refrigerant-containing equipment be sent to an EPA-certified reclaimer or another final
processor in the supply chain, as well as sensitivity analyses related to these costs and benefits.
2.3 Years of Analysis
This analysis estimates the costs and benefits of compliance with provisions contained in the final
rule. The earliest required compliance year is 2026, and—consistent with prior analyses conducted for the
Allocation and 2023 Technology Transitions Rules—EPA has evaluated cumulative costs and benefits
through the year 2050. For the purposes of this analysis, we have assumed that full compliance will be
reached for each provision contained in the final rule by the first year in which the requirement starts, and
that compliance continues through 2050 (the final year included in this analysis).
2.4 Factors Analyzed
This RIA addendum takes into consideration the compliance costs of meeting the requirements of this
rule as finalized as well as the associated the environmental benefits of the consequent reduction in HFC
emissions and the associated avoided global warming. Consistent with the Allocation Rules RIA and the
2023 Technology Transitions RIA Addendum, specific factors evaluated in this assessment include
capital costs, operations and maintenance (O&M) costs, recordkeeping and reporting costs, anticipated
refrigerant savings (e.g., from early leak detection and repair and heel recovery), and benefits resulting
from the avoided release of HFCs into the atmosphere. This analysis does not consider certain factors that
could potentially further reduce compliance costs, such as potential decreases in costs over time resulting
from economies of scale or the energy savings from reduced cooling demand as a result of avoided global
warming.
2.5 Vintaging Model
EPA uses the Vintaging Model to forecast the use and emissions of HFCs and other substances, by
sector and subsector, under a business as usual (BAU) scenario and under various policy compliance
scenarios. This analysis uses a version of the model intended to represent compliance with the AIM Act
HFC Phasedown and 2023 Technology Transitions Rule as a starting point and makes adjustments to
various subsectors of affected equipment and end uses as needed to align with the requirements of the
17
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final ER&R Rule. The resulting consumption and emissions are compared against the analysis developed
for the Allocation and 2023 Technology Transitions Rules to evaluate incremental impacts.
The model tracks the use and emissions of regulated substances separately for each generation or
"vintage" of equipment. The Vintaging Model is used to produce the estimates of GHG emissions in the
official U.S. GHG Inventory and is updated and enhanced annually. Information on the version of the
model used for this analysis, the various assumptions used, and HFC emissions may be found in EPA's
Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014. A more detailed explanation of the
Vintaging Model is also found in Section 3.2.1 of the Allocation Framework RIA.
2.6 Regulatory Option
The primary costs/benefits analysis conducted for this RIA addendum is based on the estimated
compliance costs and benefits of the requirements contained in the final rule. In our analysis of the
proposed rule, we investigated the potential costs and benefits of alternative regulatory scenarios,
including alternative equipment charge size threshold for the leak repair requirements. In this updated
RIA Addendum for the final ER&R Rule, EPA is providing additional costs and benefits scenarios for
alternative options considered for the final rule. These include:
• Alternative cutoff years for the final rule's ALD installation requirements for existing equipment,
including scenarios where the requirements would have covered systems installed within 5 years
of the compliance deadline or where the requirements would have covered all existing equipment
(i.e., no cutoff date). See Appendix L for these results.
• Alternative compliance start years for the rule's provisions related to the management of
disposable cylinders. See Appendix M for these results.
Importantly, the statutory direction for this final rule is not dependent on the analysis of costs and
benefits, but rather the rule is designed to serve the purposes identified in subsection (h) of the Act of
"maximizing reclaiming and minimizing the release of a regulated substance from equipment and
ensuring the safety of technicians and consumers." We refer the reader to the final rule for further
explanation of the requirements finalized therein.
2.7 Uncertainty
Throughout this RIA Addendum, EPA has included a number of sensitivity analyses on particular
modeling parameters and assumptions relied upon for this analysis. These include:
• Assumed cost of reclaimed HFCs vis-a-vis virgin manufactured HFCs (see Appendix K)
18
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• Assumed industry behavior including improvements to leak repair and recovery that would occur
in the reference case for this analysis (i.e., in the absence of this rulemaking) and resulting
incremental benefits (see Appendix F)
• The number of disposable refrigerant cylinders in circulation in the United States, the average
volume of heel gas remaining in disposable cylinders, and the average rate of venting of heel gas
versus removal (see Appendix M)
Uncertainty regarding the social cost of HFC (SC-HFC) methodology utilized in this RIA Addendum
is also discussed in Error! Reference source not found..
Chapter 3. Methodology
3.1 Reference Case and Relationship to Prior Analyses
Background
Through the Allocation Framework Rule (86 FR 55116, October 5, 2021) as well as an update to that
rule, 2024 Allocation Rule (88 FR 46836, July 20, 2023), EPA has established a consumption baseline for
the phasedown of HFCs.8 The consumption baseline was established using the average annual quantity of
all regulated substances consumed in the United States from January 1, 2011, through December 31,
2013, and additional quantities of past chlorofluorocarbon (CFC) and hydrochlorofluorocarbon (HCFC)
consumption. More details on the methodology used to establish this baseline can be found in the
Allocation Framework Rule.9 The baseline serves as the starting point from which statutorily mandated
percentage reductions are taken to implement the AIM Act HFC phasedown.
Following the finalization of these rules, EPA furthered the implementation of the AIM Act by
finalizing the 2023 Technology Transitions Rule (88 FR 73098, October 24, 2023). The rule includes
restrictions on the use of certain hydrofluorocarbons (HFCs) above a certain global warming potential
(GWP) whether neat or used in a blend, and restrictions on certain HFCs and certain blends containing
HFCs, in specific sectors or subsectors where HFCs are used.
EPA has previously estimated costs and benefits of the HFC phasedown, which are detailed in the
Allocation Framework RIA and 2024 Allocation Rule RIA Addendum, and for the 2023 Technology
Transitions Rule, which are updated in the 2023 Technology Transitions Rule RIA Addendum. The final
ER&R Rule focuses on statutory provisions under the AIM Act that are separate from those addressed in
the Allocation Rules and 2023 Technology Transitions Rule. However, in order to avoid double counting
8 The shorthand "Allocation Rules" is used throughout this document to refer to these rules together.
9 httvs://www. federalreeister. gov/documents/2021/10/05/2021-21030/vhasedown-of-hvdrofluorocarbons-establishing-the-
allowance-allocation-and-trading-vrogram-under-the.
19
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or overestimating of costs and benefits of this rule, for the purposes of this analysis the estimated
economic and environmental impacts of these prior rules are assumed to be the status quo or "reference
case"10 from which incremental impacts may be calculated.
As detailed in the Allocation Framework Rule RIA, 2024 Allocation Rule RIA Addendum, and 2023
Technology Transitions Rule RIA Addendum, EPA relied upon a MACC approach in order to estimate
the full set of industry transitions and associated compliance costs required to meet statutory
requirements. Emissions benefits were estimated based on the difference between HFC emissions in the
compliance pathway and HFC emissions under a BAU scenario without the statutory requirements in
place. Analysis for this rule builds on this previously used methodology by adding on additional measures
required by the final ER&R Rule and evaluating their incremental impact.
HFC Consumption under BAU and Reference Case Projection
Under the previously modeled compliance pathways for the Allocation and 2023 Technology
Transitions Rules, HFC consumption and emissions overtime for appliances across all major sectors
(including fire suppression, CC, IPR, and CR) are significantly lower (in CC^e terms) than they otherwise
would be under a BAU scenario. Since this analysis assumes these transitions occur in the reference case,
the estimated avoided emissions from some of the provisions contained in this final rule are less than
what they would be if a BAU scenario were used that does not assume these transitions and improved
service activities occur.
Table 3-1 below shows the consumption-based BAU originally used to quantify benefits in the
Allocation Rule analyses, as well as estimated consumption under the reference case used for this analysis
that also incorporates impacts from the 2023 Technology Transitions Rule. The latter is used to quantify
incremental benefits in this analysis.
Table 3-1: HFC Consumption under original BAU and reference case (MMTEVe)11
) ear
IIl '(' ( onsumprion
under HA I' (i.e., no
MM Act)
IIIX' ( onsumprion under
lilt Alt It tile reference case
(i.e., with . Mlocation and 2023
1 echnolo^y Transitions Rules)
2025
315
126
2030
317
60
10 As a disambiguation, throughout this document we refer to the Allocation and 2023 Technology Transitions Rules estimates as
the "reference case" rather than "baseline," to avoid confusion with the statutory baseline for the Allocation Rules.
11 In this document, units for consumption and emission reductions are presented in Million Metric Tons Exchange Value
Equivalent (MMTEVe) or Metric Tons Exchange Value Equivalent (MTEVe). As explained in the Allocation Framework Rule, a
metric ton of exchange value equivalent is numerically equal to a metric ton of carbon dioxide equivalent (MTCChe) and we use
these terms interchangeably throughout this document.
20
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2035
324
16
2040
337
27
2045
352
30
2050
366
33
Approach for Estimating Incremental Impacts
Results from this analysis indicate that the final ER&R Rule will yield incremental HFC consumption
and emissions reductions relative to the previously modeled compliance pathways.12 However, the extent
of these incremental benefits depends in part on whether some of the HFC consumption- and emissions-
reducing activities required by this final rule (such as improvements to detect and repair leaks) would
have already been undertaken by industry in order to comply with, or otherwise address market outcomes
from, the Allocation and 2023 Technology Transitions Rules.
As detailed in the 2023 Technology Transitions RIA Addendum, the precise set of transitions that
will be undertaken by industry to meet compliance is uncertain, leading to a range in potential
incremental benefits. The 2023 Technology Transitions RIA Addendum included two primary
compliance scenarios illustrating this uncertainty:
a) a base case scenario where compliance options not explicitly required by the rule but
envisioned under the Allocation Rules were excluded, thus yielding benefits (i.e., greater
reductions in HFC consumption and emissions) for certain subsectors but also disbenefits (i.e.,
lower reductions in HFC consumption and emissions) for other subsectors, relative to the
Allocation Rule results.
b) an upper-bound scenario of incremental benefits where compliance options from the
Allocation Rules were assumed to occur even though not explicitly required by the 2023
Technology Transitions Rule, including actions taken in the fire protection subsector, improved
leak repair, and additional recovery at disposal.13
To evaluate the incremental impacts of the ER&R Rule relative to the policy status quo, the former,
base case scenario from the 2023 Technology Transitions RIA Addendum is used as the primary
12 However, the schedule for the production and consumption phasedown is not made more stringent than the schedule under
subsection (e)(2)(C) of the AIM Act (i.e., the production and consumption caps contained in the Allocation Rules are
unchanged).
13 The 2023 Technology Transitions rule was finalized in October 2023. Restrictions apply to the use of certain high GWP HFCs
in aerosols, foams, and refrigeration, air conditioning, and heat pump products and equipment. Beginning January 1, 2025 (or
model year 2025, but no earlier than one year after publication of the final rule, for some motor vehicle air conditioners), certain
technologies will need to restrict use of higher-GWP HFCs or HFC blends. Compliance deadlines and GWP limits vary based on
sector and subsector.
21
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reference case from which additional costs and benefits are evaluated in this analysis. In this way, all
measures found to be required to meet compliance with the Allocation and 2023 Technology Transitions
Rules, based EPA's prior analyses, are assumed to occur in the reference case. Additional measures from
the above-mentioned upper-bound scenario, which are not required to meet compliance with the
Allocation and 2023 Technology Transitions rules (namely, enhanced recovery, leak repair, and
transitions in the fire protection sector), are not assumed to occur in the reference case.
Given the uncertainty regarding whether industry may undertake these measures in the absence of
explicit requirements, in Appendix F EPA has also provided an alternative scenario where we assume that
the above-mentioned improvements to leak repair and recovery would occur even in the absence of this
rule and they are therefore included in the reference case. This alternative scenario effectively illustrates a
lower-bound of the incremental benefits of the final ER&R rule.
EPA notes that the above assumptions are made to 1) explore potential uncertainties around plausible
scenarios and outcomes and 2) avoid double counting of benefits.
Moreover, there are potential additional benefits associated with provisions contained in the final rule
that are not quantified in the incremental benefits presented in this document. These include, but are not
limited to:
• the life-cycle cost savings associated with the use of reclaimed HFCs and substitutes for HFCs as
opposed to virgin HFCs and substitutes for HFCs;14
• the moderation of future spikes in the cost of HFCs due to increased availability of reclaimed
HFCs;
• the freeing up of available virgin HFCs for applications where reclaimed HFCs have not been
proven effective for use; and
• avoided supply shortages of HFCs that are still needed for servicing certain appliances, by
maximizing the supply of reclaimed refrigerant;
• thus, protecting the cold chain needed to deliver food and vaccines.
3.2 Equipment Characterization
In order to evaluate costs and benefits, EPA relied on the Vintaging Model (described in section 2.5
above) to construct an inventory of equipment and appliances potentially affected by specific provisions
contained in the final rule as well as associated use and disposition of regulated substances over time.
14 For example, see Yasaka et al. (2023), which discusses additional life-cycle benefits from the use of reclaimed HFCs.
22
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This section provides a description of assumptions made to determine the universe of equipment and
appliances affected. Qualitative descriptions of the broad categories of affected equipment and appliances
are also provided.
Equipment in the Fire Suppression Sector
Fire suppression equipment covered by this final rule fall into two categories, and both types of
equipment may contain HFCs that would be discharged in the event of a fire. Total flooding systems are
designed to automatically discharge a fire extinguishing agent by detection and related controls (or
manually by a system operator) and achieve a specified minimum agent concentration throughout a
confined space (i.e., volume percent of the agent in air) that is sufficient to suppress development of a
fire. Streaming applications use portable fire extinguishers that can be manually manipulated to discharge
an agent in a specific direction and release a specific quantity of extinguishing agent at the fire. Table 3
summarizes reference case stock and emissions in 2025 for both end-uses within the Fire Suppression
sector.
Table 3-2: Estimated Installed Stock (MT) and Emissions (MT) by Equipment Type (2025)
Hqnipmenl type
Installed Stock
(MT)
"n of lot III
Inst tilled Stock
l.euk amissions (Ml)
"n oj lot ill
Leak
amissions
Total Flooding Systems
14,976
89%
374
85%
Streaming Units
i.x-:
1 1".,
(.(.
15".,
Total
16,84')
440
Refrigeration and Comfort Cooling Appliances
A variety of Refrigeration, Air Conditioning, and Heat Pump (RACHP) appliances used in the United
States contain refrigerants, and these appliances can be organized into charge size groups such as the
following: 1) appliances containing five or fewer pounds of a refrigerant containing an HFC or substitute
for an HFC, 2) appliances containing between five and 15 pounds of such refrigerant, and 3) appliances
containing more than 15 pounds of such refrigerant. For this analysis, affected equipment is considered to
be refrigeration and air conditioning (AC) appliances containing 15 pounds or more of a refrigerant
containing an HFC or substitute for an HFC with a GWP greater than 53,15
15 For brevity, unless otherwise stated, in this document we use the term "refrigerant" to include regulated HFCs and substitutes
for HFCs with a GWP greater than 53.
23
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Figure 3-1 shows the projected installed stock of HFC refrigerant by RACHP appliance type across
all equipment sizes in the United States in 2025, as modeled in EPA's Vintaging Model (EPA 2023f)16
and Figure 3-2 shows estimated annual leak emissions (exclusive of loss during disposal) by appliance
type in 2025. These appliances contain approximately 0.85 million MT (1.9 billion pounds) of HFC
refrigerant and are estimated to release approximately 71,600 MT (157 million pounds) of HFC
refrigerant in 2025 (an aggregate average leak rate of 8.4%) in the absence of control measures required
by this rule. Table 3 summarizes stock and leak emissions in 2025 for each appliance type.
Figure 3-1: Projected Installed Stock (MT) of HFC Refrigerant by RACHP Appliance Type and Charge
Size (2025)
Ref Transport (5-15 lbs)
Ref Transport (>15 lbs)
Commercial Ref
(5-15 lbs)
Unitary AC and HPs
(<5 lbs)
1 Commercial Ref (>l^Jtfsj
LrV
a
Chillers (>1
MVAC (<5 lbs)
Unitary AC and HPs
(5-15 lbs)
Unitary AC and
HPs (>15 lbs)
Buses, Trains
(5-15 lbs)
Buses, Trains (>15 lbs)
10 As explained in the RIA to the Allocation Framework Rule and associated addenda to that RIA, the Vintaging Model estimates
the consumption and emissions from subsectors that traditionally relied on ODS and are transitioning to HFCs and other
alternatives. The EPA 2023f version of the model (VMIO file_v4.4_02.04.16_Final TT Rule 2023 High Addition.xls)
incorporates the transitions and practices anticipated to occur under the 2023 Technology Transitions RIA Addendum High
Additionality Case, which in turn incorporates provisions of that rule and other actions anticipated under the 2024 Allocation
Rule not otherwise adjusted based on the 2023 Technology Transitions Rule.
24
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Figure 3-2: Estimated Leak Emissions (MT) of HFC Refrigerant by RACHP Appliance Type and Charge
Size (2025)
Unitary AC and HPs
(5-15 lbs)
Unitary AC and HPs
(>15 lbs)
>es, Trains (5-15 lbs)
Trains (>15 lbs)
15 lbs)
Table 3-3: Estimated Installed Stock (MT) and Leak Emissions (MT) by Equipment Type (2025)
Equipment Type
Installed Stock
(MT)
% of Total
Installed Stock
leak Emissions (MT)
% of Total
leak
Emissions
Motor Vehicle Air
83,200
10%
7,100
10%
Conditioning (<5 lbs)
Unitary AC and Heat Pumps
(<5 lbs)
338,600
40%
35,400
50%
Small Appliances (<5 lbs)
76,400
9%
400
0.6%
<5 lbs total
498,200
42,900
Buses, Trains (5-15 lbs)
1,600
0.2%
200
0.3%
Ref Transport (5-15 lbs)
5,500
1%
1,700
2%
Commercial Ref (5-15 lbs)
7,600
1%
400
1%
Unitary AC and Heat Pumps
(5-15 ibs)
27,900
3%
2,200
3%
5-15 lbs total
42,600
4,500
Buses, Trains (>15 lbs)
1,500
0.2%
100
0.1%
Chillers (>15 lbs)
157,200
18%
2,100
3%
IPR (>15 lbs)
77,100
9%
5,500
8%
Commercial Ref (>15 lbs)
69,000
8%
14,600
20%
Ref Transport (>15 lbs)
4,900
1%
1,600
2%
Unitary AC and Heat Pumps
(>15 lbs)
2,700
0.3%
200
0.3%
>15 lbs Total
312,400
24,100
Total
853,200
71,500
Ref Transport
(5-15 lbs)
Ref Transport (>15
lbs)
Small Appliances
(<5 lbs)
Commercial Ref (5-15 lbs)
Buses,
Chillers (>
IPR (>15 lbs)
25
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The ER&R Rule covers three broad categories of RACHP appliances, which can be summarized as
follows:
• Commercial refrigeration (CR) equipment are the refrigerant-containing appliances used in
the retail food and cold storage warehouse sectors and refrigerated transport systems. Retail
food appliances include the refrigeration equipment found in supermarkets, convenience
stores, restaurants, and other food service establishments and include multiplex rack systems
and condensing unit systems. Cold storage appliances include the equipment used to store
meat, produce, dairy products, and other perishable goods. Refrigerated transport appliances
include the equipment to move perishable goods (e.g., food) and pharmaceutical products by
various modes of transportation, including rail and ships.
• Industrial Process Refrigeration (IPR) equipment are complex, customized refrigerant-
containing appliances used in the chemical, pharmaceutical, petrochemical, and
manufacturing industries. These appliances are directly linked to the industrial process. This
sector also includes industrial ice machines, refrigerant-containing appliances used directly in
the generation of electricity, and ice rinks.
• Comfort Cooling (CC) equipment includes stationary refrigerant-containing appliances that
provide cooling in order to control temperature and/or humidity in occupied facilities, such as
office buildings and commercial buildings, and mobile AC equipment. Comfort cooling
appliances include building chillers (which can be further broken down by compressor type)
and mobile AC for transit, school, and tour buses and passenger trains.
Additional description of the Vintaging Model end-uses within each sector and equipment category is
provided in Appendix B.
Equipment Affected by Leak Repair and Inspection Provisions
The leak repair and inspection provisions contained in the final rule affect refrigerant-containing
appliances with a charge size (i.e., amount of refrigerant in a given independent circuit) of 15 pounds or
more. CR, CC, and IPR appliances containing 15 pounds or more of HFC refrigerant17 were identified
using EPA's Vintaging Model, which models equipment using average charge sizes. To provide
additional variation in potential costs and benefits for larger refrigerant-containing appliances where a
more significant range of possible charge sizes is likely such that at least some portion of the appliances
17 Although the final rule also covers substitutes for an HFC, this analysis focuses on HFCs and HFC-containing blends,
including HFC-containing substitutes, noting that most other HFC substitutes modeled have small to zero GWPs (e.g.,
hydrocarbons, hydrofluoroolefrns, carbon dioxide, and ammonia).
26
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are addressed by this rule, end-uses were distributed into "low" (i.e., 50 percent of the modeled average
charge size), "average" (i.e., the modeled average charge size), and "high" (i.e., 150 percent of the
modeled average charge size) groups. Each group was assigned one-third of the total units, and the charge
size distributions equal the weighted average charge size modeled in the Vintaging Model. Each end-
use/charge size group was then categorized as sub-small (containing between 15 and 50 pounds of
refrigerant), small (containing between 51 and 199 pounds of refrigerant), medium (containing between
200 and 1,999 pounds of refrigerant), and large (containing greater than 2,000 pounds of refrigerant). The
categorization is done because provisions in the rule vary by charge size. Table 3-3 provides a mapping of
end-uses into these three charge size groups and categorization. A more detailed version showing each
end-use separately is available in Appendix A.
Table 3-4: Apportionment of Appliance Types by Refrigerant Charge Size
. \ppliunce
. \ppliunce I'ype'1'
. 1 veruge
Distributed
C It urge Size
Equipment
Sector
C bur^e Size
(lbs)'
C barge Size
(iroup
. \nulyzed
Obs)
Size
School & Tour Bus
AC
Low
5
N/A
13
Average
1 1
N/A
High
l(>
Sub-small
Low
S
N/A
Transit Bus AC
16
Average
l(>
Sub-small
High
24
Sub-small
Comfort
Passenger Train
AC
Low
20
Sub-small
Cooling
41
Average
41
Sub-small
High
61
Small
Low
2<>^ «J2'J
Medium
Chillers
1,105
Average
52<> I.X5"
Medium
Medium -
Large
High
794 - 2,786
Modern Rail
Transport
Low
8
N/A
17
Average
r
Sub-small
High
25
Sub-small
Vintage Rail
Transport
Low
r
Sub-small
33
Average
Sub-small
High
so
Sub-small
Low
2 '
Sub-small
Commercial
Refrigeration
Condensing Unit
47
Average
4"
Sub-small
High
"u
Small
Low
194 - 827
Small -
Medium
Marine Transport
1,021
Average
.XX l,(.5 ^
Medium
High
582 - 2,480
Medium -
Large
Low
l.ul')
Medium
Rack
2,038
Average
2.ii iX
Large
High
Vi >5"
Large
27
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Low
12,110 -
12,716
Large
Cold Storage
24,755
Average
24,220 -
25,431
Large
High
36,331 -
38,147
Large
Industrial
Low
972-7,939
Medium -
Large
Process
Refrigeration
IPR
6,633
Average
1,945 -
15,877
Medium -
Large
High
2,917-
23,816
Large
a Only end-uses within appliance sectors CC, CR, and IPR are shown.
b End-uses with charge sizes less than 10 pounds are not shown as even under the "high" charge size group, they will
not be affected by the leak inspection and repair provisions of the rule.
0 For some appliance types, the Vintaging Model simulates multiple subsectors that are distinguished by size,
original ozone-depleting substances (ODS) refrigerant type, or technology. In those cases, a range is provided.
Refrigerant-containing appliances with a charge size greater than or equal to 15 pounds must also
exceed specified annual leak thresholds to trigger the leak repair and inspection requirements contained in
the final rule, and CR and IPR appliances with refrigerant charge sizes of 1,500 pounds or more must use
an ALD system.18 The proportion of refrigerant-containing appliances above the applicable leak rate
thresholds was based on appliance stock estimated in the Vintaging Model. Because the Vintaging Model
models appliances using average leak rates,19 appliance stock was distributed into quintiles, each
containing 20 percent of units, where the leak rate distributions equal the weighted average leak rate
modeled in the Vintaging Model for each appliance type. Based on this approach, it is assumed that each
subsector has at least 20 percent of its stock (i.e., one quintile) above the threshold leak rate. By
distributing leak rates in this way, we estimate the percentage of each end-use that leaks above the
threshold rates over which actions are required by this rule.20 As an example, Transit Bus AC has an
average leak rate of 10% per year (ICF International 2005). We divide the end-use into five quintiles,
with annual leak rates of 5%, 7.5%, 10%, 12.5%, and 15%. Therefore, we calculate that 40% of the
18 Owners and operators of refrigerant-containing appliances that are not required to install an ALD system (e.g., those with a
charge size of less than 1,500 pounds) may voluntarily choose to install an ALD system as a compliance option for leak repair
requirements in lieu of the applicable requirements for periodic leak inspections and certain recordkeeping and reporting
requirements. However, leak inspections are required to be performed for the portions of the appliance where the ALD system is
not monitoring for leaks.
19 Under the base case scenario in this document, for chillers, large retail food (rack systems), cold storage, and industrial process
refrigeration systems, the leak rate distributions were applied to the average leak rate modeled in the Vintaging Model as of 2026
with a 40 percent leak rate reduction, which is consistent with the assumption that larger refrigeration and AC equipment will
experience enhanced leak recovery under the 2024 Allocation Rule as explained in the RIA to the Allocation Framework Rule
and associated addenda to that RIA.
20 The threshold leak rates are the same as those established under 40 CFR, part 82, subpart F; namely, 30% per year for CR
appliances, 20% per year for IPR appliances, and 10% per year for CC and all other refrigerant-containing appliances.
28
-------
appliances (those in the last two quintiles), exceed the threshold leak rate of 10% per year, See Appendix
B for more detail.
Table 3-5 presents the assumptions made for this analysis regarding the proportion of affected
refrigerant-containing appliances experiencing leaks above the threshold.
Table 3-5: Affected Refrigerant-Containing Appliance Assumptions by Appliance Sector, Type, and Size
. \ppliance Sector
. ippliame lypc
. \ppliance
She
. 1 venire
C barge Size
(lbs)'1
Percentage of. \ppliances
Experiencing Leaks. 1 hove the
Threshold Hate
Comfort Cooling
School & Tour
Bus ACb
Sub-small
16
13%
Transit Bus AC
Sub-small
16
40%
Passenger Train
AC
Sub-small
41
20%
Chiller
Medium
265 - 1,985
20%
Large
2,084 - 2,786
20%
Commercial
Refrigeration
Modern Rail
Transport0
Sub-small
17
80%
Vintage Rail
Transport0
Sub-small
33
80%
Condensing Unit
Sub-small
47
20%
Marine Transport
Small
194
80%
Medium
388- 1,653
60% - 80%
Large
2,480
60%
Rack
Medium
986-1,972
20%
Large
2,959
20%
Cold Storage
Large
10,655 -
38,147
20%
Industrial Process
Refrigeration
IPR
Medium
1,049 - 1,059
20%
Large
2,099-23,816
20%
aFor some equipment types, the Vintaging Model models multiple subsectors which are distinguished by size,
original ozone-depleting substances (ODS) refrigerant type, or technology. In those cases, a range is provided.
b66 percent of School & Tour Bus AC units have charge sizes below the charge size threshold of 15 lbs. and
therefore are not included as affected appliances (EPA 2023f).
0 The Vintaging Model models two subsectors for refrigerated rail car transport: vintage and modern. Modern rail
refrigeration systems are considered to be easily replaceable units previously developed for road transport and
adapted for rail use, have a lifetime of approximately 9 years, and a refrigerant charge size less than 20 pounds. Older
or vintage units were typically developed specifically for rail use and operate for the whole lifetime of the railcar
itself (i.e., 40 years) and have larger charge sizes than modern systems (EPA 2023f).
Equipment Affected by the Automatic Leak Detection Provisions
Refrigerant-containing appliances within the CC and IPR sectors are required to install an ALD
system if the normal charge size is equal to 1,500 pounds or more. Some refrigerant-containing
appliances are assumed to already have an ALD system installed. For instance, some refrigerant-
29
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containing appliances are provided with an ALD system, or have an option to include such. In this
analysis, we assume 10 percent of affected refrigerant-containing appliances already have an ALD system
installed in the reference case, and hence do not yield costs or benefits based on this rule.
In addition, the State of California requires the use of an ALD system if the refrigerant charge size
exceeds 2,000 pounds. California comprises -12 percent of the total population of the United States.
Thus, we assume 12 percent of appliances with refrigerant charge sizes exceeding 2,000 pounds have an
ALD system installed, in addition to the 10 percent reference case assumption. Combining these, and
assuming a portion of the 10 percent reference case is in California, we estimate that 20.8 percent of
appliances with refrigerant charge sizes over 2,000 pounds already have an ALD system installed.
For appliances between 1,500 and 2,000 pounds of refrigerant, we assume that an additional seven
percent of affected appliances will already have an ALD system installed. This is the approximate percent
of supermarkets represented under EPA's GreenChill voluntary program. As above, combining these two
factors yields the assumption that 16.3 percent of affected appliances with refrigerant charge sizes
between 1,500 and 2,000 pounds already have an ALD system installed.
Equipment Affected by Reclamation Provisions
The final ER&R Rule also requires the servicing and/or repair of existing refrigerant-containing
equipment to be done with reclaimed HFCs in specific RACHP subsectors. The servicing and/or repair of
refrigerant-containing equipment in the supermarket systems, refrigerated transport, and automatic
commercial ice makers subsectors must be done with reclaimed refrigerants containing HFCs when
refrigerant containing HFCs is needed to service and/or repair the equipment. The universe of refrigerant-
containing equipment affected by these provisions and corresponding refrigerant demand was estimated
using EPA's Vintaging Model (EPA 2023f). In 2029 (the first compliance year for these provisions),
accounting for the leak repair provisions in the final rule, total reclaimed refrigerant demand is estimated
to be approximately 12,168 MT as shown in Table 3-6: below. Note that these totals only reflect the AIM-
listed HFCs, including those that are incorporated in blends; for example, HFOs, whether neat or in a
blend with HFCs, are not included because the requirement to use reclaimed refrigerants for service
applies only to the regulated HFCs.
Appendix D provides additional, detailed tables showing estimated servicing demand by specific
HFC gas for refrigerant-containing equipment affected by these provisions.
30
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Table 3-6: Service Demand ofHFCs for Applicable RACHP Subsectors in 2029
Subsector
Rcfrigerant-i ontainin%
Fi/nipmenr lype
Service Demand
(Ml)
Siipcrm;irkcl S\ sicnis
X.(i(i()
Road
1.405
Vintage
10
Refrigerated Transport
Modern Rail
9
Intermodal Containers
304
Marine
1.705
Automatic Commercial Ice Makers
75
1 (Mill
12.I()S
Reclamation ofHFCs and refrigerants in general has been practiced for many years. While the
requirements for servicing and/or repair of equipment with reclaimed HFCs in the above-listed subsectors
may direct more reclaimed refrigerant thereto, it is likely that reclaimed refrigerants, to the extent
available, will still be used in other subsectors. Recently reported total annual reclaim levels (4,115 MT in
2023) fall short of the above estimated demand for 2029, indicating that industry would have to make
strides to increase reclamation totals in the coming years. This can be expected and has been seen in past
refrigerant phaseouts. For instance, production of HCFC-22 for service ceased in 2020, yet numerous
equipment continues to operate and continues to be serviced with reclaimed HCFC-22. Indeed, HCFC-22
has been the substance reclaimed the most (by mass) since at least the year 2000 (EPA, 2023e). To
provide a perspective on recent reclaimed HFC levels, Table 3-7 below displays the amount of reclaim, in
MT and million MT of CC^e (MMTCChe), compared to consumption.
Table 3-7: Summary of HFC reclaim and consumption
Yan-
Red,timed UK \ (M T) '
Reclaimed ///¦'( s
(MMK (he)-'
( imsiimplitm (MMK <>:e):
ion
:.'()<>
4.9
290
2018
:.'s:
5 1
306
2019
:."4')
5 5
314
2020
:.44^
5 u
309
2021
:.4^
5 u
462
2022
V4* (i
7.2
253
2023
4,115
00
00
Not Available
a (EPA, 2024d)
b Years 2017-2021 from EPA's Greenhouse Gas Reporting Program (EPA, 2024b); 2022 from EPA's HFC Data
Hub (EPA, 2024c).
These data indicate that there remains a wide gap between consumption of virgin regulated
substances versus the amount that is reclaimed each year (a ratio of over 40 to 1 in 2022), and that
significant increases in recovery and reclamation rates are possible. According to estimates from EPA's
Vintaging Model, the amount ofHFCs available for recovery at disposal (i.e., as equipment reaches the
31
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end of its useful life) in the coming years significantly exceeds the amount of demand from the subsectors
required by the rule to use reclaimed refrigerant and shown in Table 3-6 above and Table 3-8 below.
Reference case rates of recovery at disposal are derived from EPA's vintaging model BAU and
correspond to equipment end-of-life loss rates of 5 to 65 percent of remaining refrigerant depending on
equipment type.21 At these rates, EPA estimates total annual recovery of HFCs from refrigerant-
containing equipment of 35,458 MT in 2029, or almost three times the demand required by the final
ER&R Rule's servicing reclaim provisions, and well more than three times if 15 percent of the demand
for reclaim shown above were met with virgin HFCs. Table 3-8 below provides assumed recovery and
demand for HFCs estimated to be necessary to meet servicing requirements in 2029.
Table 3-8: Modeled Recovery and Service Demand for HFCs in 2029 (RACHP only)
( ids
lislinwlcil lic/crcncc
( use liccovcry ill 202')
(Ml)
lislinwlcil Demand
licsnlling Jroni l:liX H
Servicing licchrim
Provisions in 202V
(Ml)
Hslinwlcil Demand
licsnlling Jrom l:liXli
Servicing licchrim
Provisions in 202V -
S5"„ (Mi)''
HFC-125
11,153
5,110
4,344
HFC-134a
1 V^76
V'Sl
2.874
HFC-143a
l.-QO
:.:59
1.920
HFC-32
9,229
1,417
1,204
a Assumes 15% of reclaim demand will be met with virgin HFCs, consistent with regulatory requirements, thus
reducing overall required demand for reclaimed HFCs.
b For blends, the assumed 15% reduction in demand shown in this table is applied proportionally across
constituent HFCs. However, actual mix of virgin versus reclaimed of HFCs may vary. For example, a
hypothetical 15/85 blend of HFC-143a and HFC-125 could comprise entirely virgin HFC-143a (a gas with
shorter supply of estimated recovery in the above table), so long as the HFC-125 share (a gas with greater supply
of estimated recovery in the above table) came entirely from reclaimed HFCs.
The values in Table 3-8 do not take into account industry's ability to leverage existing stocks and
inventory of reclaimed material (provided they conform with the rule's requirement), which are likely to
contribute to meeting the requirements of the rule, since reclaimed HFCs used to meet the requirements of
the rule may have been recovered in prior years. In addition, the above values are inclusive of recovery
and demand of specific blends, broken out by constituent HFCs. For example, a large share of the
estimated recovery of HFC-125 and HFC-32 shown in Table 3-8 is driven by modeled recovery of R-
410A (a 50/50 by weight blend of these two gases). These gases may then presumably be available to
meet demand for blends such as R-452B (11% HFC-32 and 59% HFC-125), which drives a significant
share of the estimated demand for these gases in Table 3-8. These dynamics may also indicate a need for
21 The Vintaging Model assumes disposal recovery from equipment reaching end-of-life in a particular year is recovered and
used, possibly after reclamation, to meet consumption demand for the same subsector and substance (i.e., new chemical demand
plus servicing demand) in the same year.
32
-------
continued industry capacity to reconstitute the component HFCs of recovered blends as demand changes
in response to the 2023 Technology Transitions and ER&R Rules.
3.3 Marginal Abatement Cost Model
To generate cost estimates for the leak repair and inspection, fire suppression, and reclamation
requirements of the final ER&R Rule, EPA relied on a marginal abatement cost (MAC) methodology
consistent with the approach used in the Allocation Framework RIA (see Section 3.2 of the Allocation
Framework RIA) and the 2023 Technology Transitions RIA Addendum. As before, consumption- and
emissions-reducing measures that meet compliance with the rule were modeled in terms of their costs on
a dollars-per-ton of C02e avoided basis and added to an integrated MAC curve of abatement measures
required to meet compliance with existing regulatory requirements. The amount of regulated substance
"available" to be avoided through measures required by the final rule was determined using EPA's
Vintaging Model and refrigerant-containing equipment characterization assumptions detailed in section
3.2 above. Additional details on these assumptions as well as cost assumptions can be found in
Appendices A, B, and C of this RIA Addendum.
The use of a MAC approach allows for consistency and comparability with EPA's prior results and
for assessment of the costs of the final rule within the context of EPA's previously finalized regulations
under the AIM Act. Similar to the approach taken for the 2023 Technology Transitions Rule, all
abatement activities required to achieve compliance with the rule are assumed to occur in the compliance
pathway. This differs from the approach originally used for the Allocation Framework Rule, which is
agnostic in terms of the specific abatement measures that industry may take up in order to meet
compliance with the statutory phasedown caps. Whereas for the Allocation Framework Rule a least-cost
pathway was modeled which included only the level of abatement necessary to meet the statutory caps in
each step-down year, the approach taken for the final ER&R Rule as well as the 2023 Technology
Transitions Rule assumes a specific compliance pathway informed by the sector-, subsector, and/or end-
use-specific requirements of the rule.
Abatement Measures Modeled
This analysis uses the full set of required industry transitions previously modeled in the 2023
Technology Transitions Rule RIA addendum as the starting point from which potential incremental costs
may be evaluated (i.e., the "base case" from the 2023 Technology Transitions RIA addendum). As
discussed in the Allocation Framework Rule RIA, abatement measures can stem from a variety of
compliance strategies, including reducing the amount of HFCs used in a piece of equipment (e.g.,
33
-------
lowering charge sizes) and transitioning from using HFCs to alternatives such as hydrocarbons, ammonia,
and hydrofluoroolefins (HFOs), which are not covered by the provisions of this rule as long as their GWP
is 53 or lower, or HFC/HFO blends, which are covered by this rule as they contain an HFC. To model
specific requirements from the final ER&R Rule, EPA evaluated abatement measures falling into the
following two general categories:
• Direct reduction in HFC losses from equipment (e.g., through leak repair)
• Use of reclaimed/recycled HFCs (e.g., to meet equipment servicing and/or repair or initial
installation demand)
Table 3-9: below provides a summary of abatement measures modeled to evaluate the impact of
specific ER&R Rule requirements. For each abatement option modeled, total net costs associated with the
strategy (e.g., leak detection costs minus any anticipated savings from reduced refrigerant consumption)
are divided by the total amount of avoided HFC consumption to derive a cost estimate on a dollars-per-
ton C02e basis. Based on this approach, the average dollar-per-ton "break-even" cost tends to be lower
for larger appliances or subsectors with large charge sizes, as opposed to smaller pieces of equipment
where the amount of tons avoided per dollar is lower and hence the break-even cost is higher. For
example, leak repair of large IPR systems has an estimated consumption abatement cost of approximately
$ 1 per ton, whereas leak repair of medium IPR systems has an estimated consumption abatement cost of
approximately $38 per ton.22 Appendix E contains additional details on all abatement options developed
and modeled for the final rule as well as their assumed break-even abatement costs in dollars per ton.
Specific factors included in overall dollar-per-ton costs include equipment capital costs (e.g., ALD
systems), labor costs (e.g., for conducting inspections and repairs), and savings associated with the
avoided purchase of HFCs for servicing. For details on the bottom-up approach taken to estimate these
factors for all affected equipment, including underlying data and assumptions used, see Appendix A.
22 Unless stated elsewise, monetary figures are in 2022 U.S. dollars.
34
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Table 3-9: Summary of abatement measures modeled and key factors evaluated to derive MAC estimates
Type of
abatement
strategy modeled
C orresponding ISRt&R Utile
Requirements
Key / 'actors Evaluated to develop
M. I(' abatement measure
Direct reduction
in HFC losses
from equipment
• Leak detection and repair for
appliances containing 15 lbs or
more of refrigerant
• Use of ALD systems for CR and
IPR appliances containing 1,500
pounds or more of refrigerant
• Minimize releases of HFCs during
the servicing, repair, disposal, or
installation of fire suppression
equipment containing HFCs or
during the use of such equipment
for technician training
Abatement: avoided virgin HFC
consumption required to meet
servicing demand
Costs: labor and equipment for
conducting leak detection/
inspections and repairs; capital and
O&M costs for ALD systems
Savings: HFC savings associated
with detecting and repairing
refrigerant leaks earlier and
avoiding refrigerant and fire
suppression agent emissions
Use of reclaimed/
recycled HFCs
• Servicing and/or repair of
refrigerant-containing equipment
for specific RACHP subsectors
with reclaimed HFCs
• Initial installation of fire
suppression equipment with
recycled HFCs
• Servicing and/or repair of existing
fire suppression equipment with
recycled HFCs
Abatement: avoided virgin HFC
consumption required to meet
demand for initial installation or
servicing
Costs: cost of reclaimed/recycled
HFCs vis a vis virgin manufactured
HFCs
Savings: avoided purchase of virgin
HFCs
Table 3-10 below shows which provisions of the final rule were modeled to apply to which end-uses
within the RACHP sector, and which charge size groups of those end-uses.
Table 3-10: Applicability of Requirements by Appliance Sector and Equipment Type
Provision (Start Date)
Sector
Hi/iiipment
Type
Distributed
C barge
. 1 verage
C barge
Leak
Inspection
I se of. 1 LI)
Reclaimed
Refrigerant
Si~e (iroup
Size (lbs)
& Repair
(2()2h2()27y'
Servicing
(2021))
School & Tour
Bus AC
Low
Average
Wi'jh "
11
1
Comfort
Cooling
Transit Bus
AC
Low
1
Average
16
Midi
1
Passenger
Train AC
Low
Average
41
1
1
1 liLili
V
35
-------
Pr
ovision (Start Date)
Sector
l^t/uipnient
Type
Distributed
C barge
Size (iron/)
. 1 venire
( barge
Size (lbs)
Leak
Inspection
ARepair
(2026)
I se of. 1I.I)
(202h2027)-'
Reclaimed
Refrigerant
Servicing
(202V)
CFC-11
Low
V
Centrifugal
Average
1,504
V
V
Chillers
Midi
1
CFC-12
Centrifugal
Chillers
Low
Average
1 liLili
1,566
1
V
1
Low
1
R-500 Chillers
Average
High ~
2,012
1
1
CFC-114
Chillers
Low
1
Average
1,389
V
iiigh
1
Screw Chillers
Low
Average
661
1
1
1 ligh
V
Scroll Chillers
Low
Average
iiigh
529
V
1
1
Reciprocating
Chillers
Low
1
Average
529
V
High
V
Modern Rail
Transport
Low
1
V
Average
17
iiigh
1
Vintage Rail
Transport
Low
Average
33
V
1
V
iiigh
1
Condensing
Unit
Low
1
Average
High'
47
V
1
Road
Transport13
Low
V
Commercial
Refrigeration
Average
10
High
Intermodal
Containers'3
Low
Average
10
V
High
1
V
1
Reefer Ships
Low
Average
1 ligh
1,653
]
]
Merchant
Low
1
Fishing
Average
388
1
Transport
High
1
Low
2,038
V
V
Average
V
V
V
36
-------
Provision (Start Date)
Sector
l^t/uipnient
Type
Distributed
C barge
. 1 venire
( barge
Leak
Inspection
( se of. 1I.I)
Reclaimed
Refrigerant
Size (iron/)
Size (lbs)
ARepair
(2026)
(2026/2027)"
Servicing
(202V)
CFC-12 Large
Retail Food
High
V
V
V
(supermarkets)
V
1
1
R-502 Large
Retail Food
Low
Average
2,038
(supermarkets)
1 liLili
V
V
V
CFC-12 Cold
Storage
Low
Average
Midi "
25,431
1
1
1
HCFC-22
Cold Storage
Low
V
V
Average
24,220
1
Midi
1
R-502 Cold
Storage
Low
Average
24,613
1
1
1
1 liLili
V
V
Low
Ice Makers'3
Average
High
6
1
Low
V
CFC-11IPR
Average
High'
1,945
V
1
V
Industrial
Low
1
Zf
Process
CFC-12 IPR
Average
2,078
1
Refrigeration
Midi
V
V
Low
1
HCFC-22 IPR
Average
15,877
1
High
1
a Where required, refrigerant-containing appliances that were installed on or after January 1, 2017, and before
January 1, 2026, must include an ALD system as of January 1, 2027. Refrigerant-containing appliances installed on
or after January 1, 2026 must include an ALD system upon installation or within 30 days of installation of the
refrigerant-containing appliance. As described above, a portion of equipment is assumed to have an ALD installed in
the reference case and therefore does not incur capital costs attributable to this rule.
bRoad Transport and Intermodal Containers average charge sizes are less than 10 pounds but shown as rounded
values. Therefore, these appliance types (even under the "High" distributed charge size group) along with Ice
Makers are not affected by the leak repair or ALD provisions but are affected by the reclaim provisions.
Model limitations and assumptions regarding the impact of reclaim requirements
The EPA Vintaging Model estimates HFC consumption and the resulting emissions without explicitly
defining the mix of virgin vs. reclaimed or recycled gases that is used by end use category. Certain
assumptions were necessary to determine the reduction in consumption and emissions attributable to
reclamation activity as: (1) the ER&R Rule provisions pertaining to reclaimed HFCs allow for reclaimed
HFCs to be mixed with up to 15 percent virgin HFCs; and (2) some reclamation activity would be
37
-------
expected to occur in the absence of this rule. To account for these factors, the modeled change in
consumption for options requiring reclaimed HFCs is scaled to remove the proportion not attributable to
the rule. Thus, for a particular measure requiring reclaim, the change in consumption is determined as,
AC] = AC'„( 1 — (/)/, + />,.))
where AC0 is the initially calculated change in consumption from the Vintaging Model (e.g., total demand
for a given end use to be met using reclaimed HFCs), is the proportion attributable to reclamation
already assumed in the reference case, and pv is the proportion coming from virgin HFCs (assumed to be
15%, i.e., the maximum share allowable).
Specific approaches for determining consumption and emission reductions resulting from ER&R Rule
abatement measures are summarized as follows:
• For measures in which the required servicing and/or repair with recovered/reclaimed HFCs was
modeled:
o Consistent with the above formula, EPA first factored out share of demand already met
by recovery and reclamation activity assumed in the reference case23, and the 15%
maximum share of virgin HFCs that may be included in "reclaimed" refrigerant per
regulatory definitions was also factored out.
o EPA conservatively assumed that the measure would not result in an additional reduction
in emissions beyond the emissions reductions from recovery of HFCs and avoided
venting at disposal and servicing already included in the reference case.
• For measures in which a direct reduction in HFC losses from equipment was modeled (e.g., due
to leak repair or ALD requirements), and the affected equipment category was not covered by a
requirement for servicing and/or repair with reclaimed HFCs, it was assumed the servicing
demand would have been met using virgin HFCs. A reduction in consumption of virgin HFCs
equivalent to total avoided emissions was assumed.
• For measures in which a direct reduction in HFC losses from equipment was modeled (e.g., due
to leak repair or ALD requirements), and the affected equipment category was also covered by a
requirement for servicing and/or repair with reclaimed HFCs, it was assumed the servicing
demand would have been met through reclaimed HFCs. The full emission reduction associated
with the leak repair activity was assumed. EPA then used the above methodology to convert from
emissions reductions to consumption reductions attributable to the rule.
23A reference case share of demand met by recovery and reclamation of 26.5% was used, derived from the Vintaging Model
BAU. For more details, see Appendix E.
38
-------
For more details on these and other specific assumptions applied to the abatement measures modeled
for this rule, see Appendix E.
Updated MAC Compliance Path
The leak repair, automatic leak detection, fire suppression, and reclaim provisions modeled as
abatement measures each have a net cost or savings estimated per ton of CO2 equivalent consumption or
emissions avoided. To evaluate the incremental cost of these provisions relative to EPA's previous
analysis, these options were integrated with the set of MAC options previously assumed to achieve
compliance with the Allocation and 2023 Technology Transitions Rules. The result is an updated
compliance path which combines ER&R Rule provisions' measures with those previously modeled.
For reference,
Figure 3-3 below shows the consumption MAC curves associated with the Allocation Rules and 2023
Technology Transitions Rule compliance path. These curves illustrate all compliance measures modeled
to be achieved as a result of implementation of these rules, with each point representing the dollar-per-ton
cost associated with abatement at a given threshold when moving (left-to-right) from lowest-to-highest
cost measures. The compliance path for these previous rules is the reference case for this analysis, and is
shown for 2026 (the first compliance year for the ER&R Rule) and 2036 (the final step-down year under
the Allocation Rules). These curves illustrate all measures assumed in the compliance path in each year
from lowest-cost to highest-cost, with total consumption abatement reaching approximately 242.3 MMT
C02e in 2026 and 323.1 MMT C02e in 2036.
39
-------
Figure 3-3: Marginal Abatement Cost Curves in 2026 and 2036 - Allocation and 2023 Technology
Transitions Rule Reference Case
$100.0
AF/TT Reference
20^6
»
20^6
3
c
o
o
u
$10.0
$1.0
f
/
50
100 150 200
Total Abatement (MMTCC^e)
f
J
I
250
300
Figure 3-4 below then shows the additional abatement measures modeled for the final ER&R Rule
described in the preceding sections. As shown, consumption abatement from these measures reaches an
additional approximately 3.7 MMT C02e in 2026 and 7.3 MMT C02e in 2036.
Figure 3-4: Marginal Abatement Cost Curves in 2026 and 2036 - Additional ER&R Rule Measures
40
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ER&R
$1000.0
c
o
tsi
o
u
c
Z3
$100.0
$10.0
$1.0
6 8 10
Total Abatement (MMTCC>2e)
12
2(
20
36
r*—
~-«
r
/
s
J
14
16
Finally,
below shows the integrated MAC curves reflecting both the reference case compliance measures
assumed for the Allocation and 2023 Technology Transitions Rules as well as the updated measures
evaluated for the final ER&R Rule. These curves illustrate total abatement assumed and assumed costs-
per-abatement measure for the full suite of existing AIM Act regulations including the final ER&R Rule.
A dashed vertical line showing the total amount of abatement required by the Allocation Rule (i.e., the
abatement necessary to meet the HFC phasedown steps) in 2026 (blue) and 2036 (red) is provided for
reference.24
Figure 3-5: Revised Integrated Cost Curves in 2026 and 2036 -Allocation and 2023 Technology
Transitions Rules with additional ER&R Rule measures
24However, the schedule for the production and consumption phasedown is not made more stringent than the schedule under
subsection (e)(2)(C) of the AIM Act (i.e., the production and consumption caps contained in the Allocation Rules are
unchanged).
41
-------
Combined (Reference + ER&R)
$1000.0
c
o
tsi
o
u
c
Z3
$100.0
$10.0
$1.0
2036
50
100 150 200
Total Abatement (/WMTCC^e)
250
300
3.4 Other Costs from Rule Requirements
Certain requirements contained in the final rule were not modeled using a MACC approach described
above, either because they do not directly impact HFC consumption and emissions or because they relate
to HFC consumption and emissions sources that are exogenous to the Vintaging Model. For these
measures, separate approaches were used to evaluate compliance costs and avoided consumption and/or
emissions of HFCs, as detailed below. These measures include:
• Requirements pertaining to the management of disposable cylinders of refrigerants and fire
suppressants
• Alternative Resource Conservation and Recovery Act (RCRA) standards for ignitable spent
refrigerants being recycled for reuse
• Recordkeeping and reporting requirements
Disposable cylinder management requirements
The provisions of this Rule include requirements to remove the heel from used disposable cylinders
before the cylinders are discarded; the requirement covers disposable cylinders used for servicing, repair,
disposal, or installation of refrigerant-containing appliances. For analytical purposes, the Agency focused
on anticipated additional reductions in HFC consumption and emissions as well as industry costs and the
potential savings from avoided refrigerant loss.
42
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To assess the impact of these provisions, EPA relied in part on the report, Refrigerant Cylinders:
Analysis of Use, Disposal, and Distribution of Refrigerants (EPA 2024a), analyzing the costs and benefits
of the requirement that disposable cylinders that have been used for the servicing, repair, or installation of
refrigerant-containing equipment be transported to an EPA-certified reclaimer or another final processor
within the supply and disposal chain (e.g., a distributor, repackager, wholesaler, landfill operator, or scrap
metal recycler), and that these entities remove all HFCs (i.e., heel) from disposable cylinders prior to
discarding the cylinder. If the heel is removed by a final processor or otherwise in the supply and disposal
chain, the removed heels may be consolidated, but must be sent to an EPA-certified reclaimer or a fire
suppressant recycler.
The report assesses the typical distribution of refrigerants in cylinders, including refrigerant changes
expected under the Base Case; i.e., the scenario incorporating the 2023 Technology Transitions Rule.
Based on the wide range of disposal practices currently employed and expected to continue in absence of
this final rule, three scenarios were developed to estimate the emissions avoided: a low scenario (i.e., a
lower heel left in the cylinder), a central scenario, and a high scenario.
The emissions avoided by removing such heels are dependent on the number of disposable cylinders
in circulation and the average heel that would otherwise be emitted, and hence not available for reclaim,
in absence of this rule. Based on the report cited above, we assume in the central scenario that there are
approximately 4.5 million cylinders in circulation, of which 99 percent are disposable. Further, we
estimate that the average heel is approximately 4 percent by weight of the nominal capacity (e.g., 0.96
pounds for a 24-pound cylinder).25 Because of the other regulations in place, it is expected that the
average GWP of the refrigerant in such cylinders will decrease. Other emissions associated with
cylinders—for example, during transport and storage—are not expected to change based on this rule.
To account for the costs associated with the change in procedure for handling of cylinders (i.e.,
returning the cylinders for heels to be removed) we analyze possible ways a cylinder might travel before
the heel is removed and the truly-empty cylinder is landfilled or recycled. This analysis assumes that
some cylinders will be: (a) sent directly to the reclaimer; (b) returned to a wholesaler or distributor, who
will ship disposable cylinders to a landfill or steel recycling facility, which would combine heels for
shipment to a reclaimer; and (c) shipped directly from the end-user or technician to a landfill or steel
recyling facility, which would combine heels for shipment to a reclaimer. For paths (b) and (c) above, we
assume the landfill or steel recycling facility would reduce costs by combining 25 refrigerant heels (at
0.96 pounds as discussed above) of each HFC or blend containing an HFC (e.g., HFC/HFO blends) they
25 R-404A is typically sold in a 24-pound cylinder. Cylinders for other HFC refrigerants are typically larger, from 25 to 50
pounds. We use 24 pounds as a conservative estimate here.
43
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receive into individual 24-pound cylinders before sending those to a reclaimer. After recovering heels,
reclaimers are assumed to send disposable cylinders to a landfill or steel recycler.
Neat HFOs, which are not regulated substances under this rulemaking but are used in some RACHP
equipment, are not accounted for in the analysis. For HFCs and blends containing an HFC, we divide
cylinders equally amongst the transportation paths described above. Thus, we assume one-third follow
path (a), one-third follow path (b), and one-third follow path (c). Table 3-11 displays the estimated
mileage for each leg of the paths taken compared to the business-as-usual (BAU) route.
Table 3-11: Estimated Distances for Disposable Cylinder Transportation Compared with BAU (Miles)"
'/ ransportation /. e^
HAL
(a) Und-user
to Reclaimer
to l.undJill
(b) Und-user
to
Distributor
In Reclaimer
(c) Und-user
to l andfill
Producer/Filler to Wholesale Distributor
1,000
1,000
1,000
1,000
Wholesale Distributor to End User/Technician
25
25
25
25
End User/Technician to Steel Recycler/Landfill
75
NA
NA
75
End User/Technician to Reclaimer
NA
50
NA
NA
End User/Technician to Wholesale Distributor
NA
NA
25
NA
Distributor or Reclaimer to Steel Recycler/Landfill
NA
75
75
NA
Liiidlill sciidinu Rea»\eivd kdimcniil In kcchiimcr
\ \
\ \
~5
loliil Miles per ( \Under
1.100
1.150
I.I2X
1.103
a California Air Resources Board (CARB 2011)
bEach cylinder sent represents 25 cylinders received with heels.
The additional travel costs are influenced by how many cylinders fit on a truck, the fuel to drive the
extra distances, and the incremental labor for such. By removing heels that would have otherwise been
emitted and hence not available for reclaim, an additional supply is provided that would offset virgin
production providing additional benefits based on the cost of refrigerant. These assumptions are shown in
Table 3 below.
Table 3-1213: Additional Disposable Cylinder Cost Assumptions
/¦'actor (units)
1 a/tie
Source
Xole.s
Cylinders per Truck
Average Truck Speed
(miles per hour)
Truck Transport Labor Rate
($/hour)
Average Fuel Consumption
(miles per gallon)
1,120
CARB (2011)
50
CARB (2011)
$53.59
Bureau of Labor Statistics (BLS 2022)
May 2022
mean, including
110% overhead
6.1
Geotab (2017)
Average across
all states
44
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Fuel cost ($/gallon)
$4,034
U.S. Energy Information Administration (EIA
2024)
Price of diesel
as of March 25,
2024
Cost of HFC refrigerant
($/pound)
$4
Consistent with
past AIM Act
analyses
Accounting for the fuel and labor associated with the additional shipment of cylinders and the cost of
refrigerants, we estimate costs and benefits, and hence the net benefits, as shown in Section 4.2 below and
Appendix L.
Further details on the costs and benefits of the cylinder management requirements and a sensitivity
analysis around some of the assumptions above are provided in Appendix L.
RCRA alternative standards
The final rule includes alternative RCRA (Resource Conservation and Recovery Act) standards for
ignitable spent refrigerant. The purpose of these alternative standards is to help reduce emissions of
ignitable spent refrigerants to the lowest achievable level by maximizing the recapture and safe
reclamation/recycling of such refrigerants during the maintenance, service, repair, and disposal of
refrigerant-containing appliances. The estimated compliance costs and savings resulting from these
alternative standards are provided in this RIA Addendum for informational purposes. However, because
they fall under a separate statutory authority from the AIM Act, they are not directly incorporated into the
overall compliance costs and benefits estimates associated with this rulemaking and presented elsewhere
in this document.
These alternative standards may incentivize additional reclamation of ignitable spent refrigerant over
disposal, although EPA has not assumed they will result in additional recovery and reclamation
consumption and emissions benefits beyond those already accounted for in response to other provisions
contained in the final ER&R Rule. The alternative standards also are expected to result in an overall
reduction in compliance costs for management of ignitable spent refrigerant under RCRA. Avoided costs
include reduced transportation costs (hazardous waste manifest and transporter not required under the
alternative standards), avoided compliance costs of complying with hazardous waste generator regulations
for appliance owners and technicians, and avoided hazardous waste incineration costs for recovered
ignitable spent refrigerant. Offsetting these avoided costs would be the cost to reclaimers for meeting the
new standards for emergency preparedness and response, and for documenting that the ignitable spent
refrigerant is not speculatively accumulated.
45
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These cost estimates are heavily dependent on the future market for ignitable spent refrigerant sent for
reclamation, which is difficult to predict with currently available data. In addition, because the alternative
RCRA standards are voluntary, and regulated entities can always choose to dispose of ignitable spent
refrigerant under the full RCRA standards if that is the economically preferred option, EPA anticipates
that the RCRA alternative standards would either be economically neutral or result in an overall cost
savings.
Reporting and Recordkeeping Requirements
The final rule includes provisions that are expected to result in additional recordkeeping and reporting
costs for owners and operators of refrigerant-containing appliances related to leak repair and inspection.
Additional recordkeeping and reporting costs are also anticipated for the requirement to include a
certification that reclaimed refrigerant contains no more than 15 percent virgin HFC. For owners and
operators of fire suppression systems, and entities that employ technicians who install or maintain fire
suppression systems, additional reporting and recordkeeping requirements apply. All recordkeeping and
reporting costs are calculated by multiplying the estimated burden (hours) times the average annual
respondent hourly cost (labor plus overhead).
In deriving these costs, EPA identified applicable standard occupational classifications for each
respondent and used the corresponding median hourly rate from the Bureau of Labor Statistics (BLS
2023).26 The resulting costs outlined in Table 3-14: are the median hourly administrative cost of labor
plus overhead for private firms (assumed to be 110 percent).
Table 3-14: Labor Rates
Respondent
liurcmi oj l.ubor Statistics Information
lot nl
Standard
Occupational
( lassification
Occupational Title
Median II a^e
Technicians
49-9021
Heating, Air-Conditioning, and Refrigeration
Mechanics and Installers
$27.55
$57.86
Owners/
Operators
17-2111
Health and Safety Engineers
$49.85
$104.69
A brief summary of the specific approaches and assumptions applied for recordkeeping and reporting
requirements is provided below. Additional details on assumptions and methods related to estimating
recordkeeping and reporting costs can also be found in the Supporting Statement for the information
collection request (ICR) prepared for this rulemaking (ICR Number 2778.02), which is contained in the
docket for the final rule.
26 Note figures here are in 2023 dollars.
46
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Requests for extensions to the leak repair and retrofit timelines
Owners or operators of CC, CR, and IPR appliances normally containing 15 or more pounds of HFC
refrigerant can apply to EPA for an extension to the leak repair and appliance retrofit timeframe. The total
number of extension requests for CC, CR, and IPR HFC equipment was estimated by scaling the number
of extension requests estimated for Ozone Depleting Substance (ODS)-containing equipment in the
supporting ICR 1626.1827 based on the proportion of total HFC equipment to ODS equipment modeled
in EPA's Vintaging Model (EPA 2023f).
Installation records
Consistent with the ICR, this analysis assumes 1.5 minutes of burden time each time a refrigerant-
containing appliance is installed.28 Vintaging Model assumptions described in section 3.2 were used to
identify the pool of affected appliances (i.e., new appliances with refrigerant charge sizes at or above 15
pounds) (EPA 2023f).
Purchase and service records
Consistent with the ICR, this analysis assumes 1.5 minutes of burden time each time a refrigerant-
containing appliance that contains an HFC or a substitute for an HFC with a GWP greater than 53 is
serviced.29 Vintaging Model assumptions described in section 3.2 were used to identify the pool of
affected appliances (i.e., all appliances with refrigerant charge sizes at or above 15 pounds) and the
expected number of times that the affected appliances would be serviced. The total number of servicing
events is assumed to be equal to the number of times that service technicians provide invoices (i.e., one
time per year for all refrigerant-containing appliances with charge sizes at or above 15 pounds) (EPA
2023f).
Results of verification tests
The final rule includes leak repair regulations that require initial and follow-up verification tests on
repairs made after the leak rate threshold is exceeded for a refrigerant-containing appliance. EPA's
Vintaging Model was used to identify the affected pool of appliances (as described in section 3.2). For
every occurrence of a refrigerant-containing appliance exceeding the applicable leak rate threshold, 1.5
minutes of burden time was assumed to maintain reports on the results of verification tests (EPA 2023f).
27 ICR 1626.18 was developed to estimate burden associated with reporting and recordkeeping of leak repair and inspection
requirements for appliances containing more than 50 pounds of ODS refrigerant.
28 This burden time is associated with writing the record and filing, not the time associated with filling or installing the system.
This assumption is consistent with prior ODS and HFC ICRs.
29 This assumption is premised on service technicians already needing to record information on services for invoicing, so the only
incremental burden is in saving the data to a record file. For the significant percentage of service companies that record service
information digitally in apps or other software, no additional time is needed to save logged data.
47
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Leak inspections
The final rule requires that covered CR and IPR appliances with a refrigerant charge size less than
500 pounds or CC and other appliances with a refrigerant charge size of at least 15 pounds conduct a leak
inspection once per calendar year until the owner or operator can demonstrate through leak detection
calculations that the refrigerant-containing appliance has not leaked in excess of the applicable leak rate
for one year. CR and IPR appliances with a refrigerant charge size from 500 pounds up to 1,500 pounds
would be required to conduct a leak inspection quarterly (i.e., once per three-month period). Appliances,
or portions of appliances, continuously monitored with an ALD system that is certified annually,
including appliances with a refrigerant charge size of 1,500 or more pounds, would not be required to
conduct an annual leak inspection. This analysis assumes that the recordkeeping time associated with
maintaining leak inspection records is one minute. EPA's Vintaging Model was used to identify the
affected pool of appliances (as described in section 3.2) (EPA 2023f).
Plans to retrofit appliances
The final rule requires that owners or operators of IPR, CC, and CR appliances normally containing
15 or more pounds of a refrigerant must develop and maintain a plan to retire or retrofit the appliance in
the following cases after the applicable leak rate is exceeded: an owner or operator chooses to retrofit or
retire rather than repair a leak, an owner or operator fails to take action to repair or identify a leak, or a
refrigerant-containing appliance continues to leak above the applicable leak threshold after a repair
attempt was made. The total number of retrofit requests for CC, CR, and IPR appliances containing 15 or
more pounds of a refrigerant was estimated as 1 percent of all affected appliances leaking above the
threshold (see section 3.2). For each retrofit plan, 8 hours of burden time was assumed.
Reports on systems that leak 125 percent or more
EPA is requiring owners/operators of refrigerant-containing appliances subject to the leak repair and
inspection provisions to prepare and submit reports describing efforts to identify and repair leaks for
appliances that leak 125 percent or more of the full charge in a calendar year. Using the assumptions in
the ICR for ODS equipment and scaling proportionately based on the ratio of affected ODS and HFC
appliances, this analysis estimates that approximately 388 appliances have an annual leak rate greater than
125 percent. For each refrigerant-containing appliance meeting or exceeding this leak rate threshold, 1
hour of burden time was assumed to prepare and submit a report for each occurrence.
Requests to cease a retrofit
The final rule allows owners/operators of appliances containing 15 or more pounds of refrigerant to
submit a request to cease a retrofit if certain requirements are met, including an agreement to repair all
identified leaks within one year of the retrofit plan's date. To estimate the costs for this reporting
48
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requirement, it was assumed that 5 percent of those that develop a retrofit plan will submit a request to
cease their retrofit. Each request is assumed to take 30 minutes to complete.
Annual calibration of ALD system
The final rule requires owners/operators of refrigerant-containing appliances using ALD systems to
maintain records regarding the annual calibration or audit of the ALD system. Records must be
maintained each time an ALD system detects a leak, whether that be based on the applicable ppm
threshold for a direct ALD system or the indicated loss of refrigerant measured in the ALD system. EPA
assumes indirect ALD systems will collect and store this directly and no burden is assumed. For
owners/operators of direct ALD systems, 1 minute of burden time is assumed.30
Labeling of reclaimed material with no more than 15% virgin material
It was assumed that reclaimers already label material and, therefore, will only need to modify labels
to indicate the batch contains no more than 15% virgin material. The label modification was assumed to
require 9 hours of both graphic design and administrative work.
Fire Suppression requirements
The final rule requires recordkeeping and reporting in the Fire Suppression sector. Those who first fill
a fire suppression equipment with a regulated substance must report annually on the amount of such
substances based on what is sold, recovered, recycled or virgin material and likewise on material sent for
disposal. In addition, fire suppression technician employers must maintain records regarding the training
used and documentation that the training was provided. Owners and operators of fire suppression
equipment must also maintain records documenting that the regulated substances were recovered prior to
sending the equipment for disposal. All records must be maintained for three years. EPA estimates that it
will take 9.4 hours annually for the reporting, and an additional 40 hours annually for recordkeeping, per
entity. We assume there will be 20 entities that will be required to perform the recordkeeping and
reporting, including 15 reporters that already collect and share information under the voluntary HFC
Emissions Estimating Program (HEEP).
3.5 Monetization of Emissions Benefits
The primary benefits of this final rule would derive from preventing the emissions of HFCs, thus
reducing the damage from climate change that would have been induced by those emissions. The 18
HFCs and their isomers regulated under the AIM Act are GHGs that can trap much more heat per ton
30 This burden time is associated with filing a record of the calibration of the ALD system, not the activity of calibrating the ALD
system. Burden associated with ALD calibration is outside the ICR and is captured with the O&M compliance costs for the ALD
systems. This assumption is consistent with prior ODS and HFC ICRs.
49
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emitted than CO2, a ratio shown in each chemical's GWP. The ratio of the amount of heat trapped by one
ton of a chemical in the 100 years after it is emitted to the amount of heat trapped by one ton of CO2 in
100 years after being emitted is the chemical's 100-year GWP, and the HFCs regulated under the
phasedown have 100-year GWPs ranging from 53 to 14,80031, with the vast majority of HFCs emitted
having GWPs over 1,000. Prior to HFC regulation under the AIM Act, it was anticipated that HFC use
and emissions would continue to rise, helping to drive global climate change. Thus, reducing the amount
of HFCs that are used and emitted prevents climate damage and associated social costs that would have
been induced by those HFC emissions. A more complete discussion of climate change damages and the
social benefits of preventing them can be found in Sections 4.1 and 4.2 of the Allocation Framework Rule
RIA.
While there may be other benefits to reducing emissions and increasing reclamation of HFCs, the
benefits monetized in this analysis are limited to the climate benefits of reduced HFC emissions. More
details on the social cost of HFCs (SC-HFC) methodology applied for this analysis and resulting
monetized climate benefits can be found in Error! Reference source not found..
3.6 Other Potential Benefits of this Rule
The estimated benefits of this rule that are quantified and presented in this analysis are the benefits of
avoiding GHG emissions that would contribute to climate damages. There are, however, additional
potential benefits that would follow from the provisions, some of which that are not quantified in this
analysis.
The provisions that require leak inspections, the repair of leaks, and/or the installation of ALD
systems for certain refrigerant-containing appliances are best practices for the maintenance and upkeep of
such appliances. Following such best practices accrues benefits for the owner/operator of the appliance by
reducing the loss of refrigerant, resulting in savings that are estimated in this analysis. Many unquantified
benefits from such best practices also exist. A regular practice of inspecting refrigerant-containing
appliances and repairing leaks when detected (rather than topping-up the appliance) also prevents such
appliances from breaking down as often and can prolong the effective service life of the appliances
(Barnish et al., 1997; Crippa et al., 2021). Fewer repairs of broken appliances and extending their service
life directly benefits owner/operators, and in the case of refrigerant-containing appliances, reducing
operation failures has the additional benefit of reducing the loss of refrigerated stock (Brush et al., 2011).
The costs of a refrigerant-containing appliance at a retail store failing and thousands of pounds of
31 EPA has determined that the exchange values included in subsection (c) of the AIM Act are identical to the 100-year GWPs
included in IPCC (2007). In this context, EPA uses the terms "global warming potential" and "exchange value" interchangeably.
One MTEVe is therefore equivalent to one MTCChe.
50
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perishable stock being lost are considerable, and the aggregate costs of such food waste to the U.S.
economy are also significant. In 2021, approximately 344,000 MT of food were lost due to refrigerant-
containing equipment issues in the retail and food service sectors, with a value of $ 1.87 billion (ReFED,
2021).
The provisions of this rule designed to maximize reclaim would provide a number of additional
benefits that are not quantified. As the HFC phasedown progresses, the supply of virgin HFCs will be
reduced, but the demand for refrigerants, fire suppression agents, aerosol propellants, etc. may continue to
grow. When complying with restrictions set by the 2023 Technology Transitions Rule, many uses of
HFCs are expected to transition to using lower-GWP—and in some cases non-HFC—substitutes, but it is
expected that demand for HFCs will continue, in part based on historic experience with the ODS
phaseout. For example, although halons have not been produced or imported into the United States for
decades, recycled halons are still used for the initial installation and servicing of certain fire suppression
equipment. Reclaimed and recycled HFCs will be needed to meet the continuing demand and to meet
certain requirements in the Rule.
By avoiding supply shortages of HFCs that are still needed for servicing certain appliances,
maximizing reclaim avoids the economic disruption that might occur, including the stranding of
equipment. A robust supply of reclaimed refrigerant would also protect the cold chain needed to deliver
food and vaccines. Maximizing reclaim would also benefit sectors not directly covered by provisions of
this rule, including certain specialized uses that cannot use reclaimed HFCs.
Chapter 4. Compliance Costs
Using the methodological approaches described chapter Chapter 3 of this RIA addendum, EPA has
estimated the compliance costs associated with the provisions contained in the final ER&R Rule.
Compliance costs also include all estimated savings (e.g., savings associated with avoided purchase of
virgin refrigerant) and may therefore be net negative in certain cases.
The sections below summarize the estimated compliance costs for all relevant provisions contained in
the final rule.
4.1 Leak repair and inspection, reclamation, and fire suppression
requirements
As described in chapter Chapter 3, compliance costs for the leak repair and inspection, reclamation,
and fire suppression requirements contained in the final rule for the affected equipment types shown in
Table 3-10 were estimated using a marginal abatement cost (MAC) modeling approach. The additional
51
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HFC consumption- and emissions-reducing measures required by the final rule and their associated costs
were estimated on a cost-per-ton of CC^e basis and integrated with the broader set of abatement measures
previously assumed in the compliance path for the Allocation and 2023 Technology Transitions Rules.
Results of the base case scenario from the 2023 Technology Transitions Rule RIA Addendum were used
as the status quo from which the incremental costs stemming from the additional ER&R measures were
evaluated.
Table 4-1 below shows the estimated incremental costs for a subset of model years included in the
analysis by provision type.
Table 4-1: Incremental Annual Compliance Costs of MAC Abatement Measures (Millions 2022$)
Yesir
l.esik Kep;iii7.\l.l)
I so of Keeliiim lor
Sen icing
l-'ire Suppression
Ke(|ii iremeiils
2026
$79.5
$-
$0.2
2030
$88.3
$3.9
$0.8
2035
$75.0
$3.1
$0.9
2040
$57.5
$2.3
$0.9
2045
$43.4
SI 8
$1.0
2050
$43.3
$1.9
$1.0
The cost curves below illustrate an updated, integrated compliance path that includes the abatement
measures assumed in for the Allocation and 2023 Technology Transitions Rules compliance pathway
along with the additional abatement measures required by the ER&R Rule. The curves present rolling
total compliance costs and U.S. HFC consumption in a given year as abatement measures are applied
from lowest- to highest-cost measures (left to right). The curves help to show the relationship between
total abatement and costs. Notably, and as illustrated in Table 4-1 above, for certain ER&R measures such
as leak repair, annual abatement and costs decrease over time as HFCs in remaining stocks of equipment
reduces. By contrast, abatement and costs (or savings) for the previously modeled 2023 Technology
Transitions Rule build overtime as the market penetration of HFC alternatives builds overtime. The
curves represent all options assumed to be undertaken to meet compliance, so the rightmost data point
shows the resulting abatement and total cost in a given year (i.e., the rightmost points represent final
abatement and net costs in each year after all required measures are applied).
52
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Figure 4-1: Integrated Annual Abatement Pathways under AIM Rules
0.5
o.o
c
o
co —0-5
in
o
U
"fD
A-i
.o
-1.0
-1.5
2,0 0 50 100 150 200 250 300
Cumulative Abatement (MMTC02e)
Figure Description: The curves above start with total costs incurred with the cheapest (or most cost-effective)
abatement measures applied, with more expensive options added as the curve moves left to right. Points to the left of
the low point on each curve represent measures with assumed net negative costs (or cost savings), while points to
the right of the low point on each curve represent measures with assumed net positive costs. The rightmost point on
each curve for a given year in each figure represents the final total net cost with all required abatement options being
applied.
4.2 Disposable cylinder management requirements
To assess the impact of these provisions, EPA relied in part on the report, Re frigerant Cylinders:
Analysis of Use, Disposal and Distribution of Refrigerants (EPA 2024a). The report assesses the cost
implications for the requirement for heel removal, accounting for the costs associated with the change in
procedure for handling of cylinders (e.g., transporting the cylinders for heel removal prior to discarding
the cylinder) and the potential savings from avoided refrigerant loss from heel emissions. Because neat
HFOs, C02, ammonia, and hydrocarbons are not regulated substances, these costs and benefits do not
reflect possible handling of those refrigerants. For the cylinders containing HFCs (and blends containing
HFCs), this analysis assumes that one third will be returned directly to a reclaimer, another third will be
returned to a distributor, and the other third will be shipped directly to a landfill or scrap recycling center.
Table 4-2 below summarizes the estimated net costs of these requirements for a subset of model years
from 2025-2050. Further detail including sensitivity analyses around some of the assumptions may be
found in Appendix L.
Integrated Annual Abatement Pathways under AIM Rules
Net Savings (+$)
2026
2031
2036
53
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Table 4-2: Estimated Compliance Costs for Cylinder Management Provisions (Millions 2022$)
Yc.ir
li'iiiispoi'liilioii
Cosls
KclVi^ci'iinl S;i\ in lis
V( Cosls
2028
$0.14
$12.9
-$12.8
2030
$0.14
si: 6
-$12.4
2035
$0.13
SI I -
-$ 11.6
2040
$0.12
SI 1 3
-$11.2
2045
$0.12
SI 1 1
-$10.9
2050
$0.12
$11.0
-$10.9
4.3 RCRA alternative standards
As described in Chapter 3, the amendments to RCRA standards for reclaimers are anticipated to be
cost neutral or to provide some savings from reduced compliance burden on these entities. As
documented in the ICR (ICRNumber 2778.02), the average annual reduction in compliance burden is
approximately $2,131,844. Taking this value as the net benefit of the amendments for each year from
2026 (the first year in which the avoided costs are estimated to accrue) through 2050 and discounting the
savings to 2024, the present value of the savings benefits would be $21.7 million (7 percent discount
rate), $35 million (3 percent), or $40 million (2 percent). As discussed in Chapter 3, due to uncertainty
and the voluntary nature of the alternative standards, the net benefits may be lower and are shown in this
document as a range from $0 to the discounted values above. In addition, these standards fall under a
separate statutory authority from the AIM Act and are therefore not incorporated into the overall
compliance costs and benefits estimates associated with this rulemaking presented elsewhere in this
document.
4.4 Recordkeeping and reporting requirements
The final ER&R Rule contains several provisions that EPA has estimated will result in additional
recordkeeping and reporting cost burden for affected industries. EPA has prepared an information
collection request (ICR), ICR Number 2778.02, and a Supporting Statement which can be found in the
docket.32 The information collection requirements for recordkeeping, reporting, and labeling are not
enforceable until OMB approves them. Among other things, EPA calculated the estimated time and
financial burden over a three-year period (ICRs generally cover three-year time periods) for respondents
to implement labeling practices and to electronically report data to the Agency on an annual basis. A
summary of the respondent burden estimates follows. A summary of underlying assumptions and
32 Docket ID: EPA-HQ-OAR-2022-0606
54
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methods used can be found in section 3.4 of this document, and the full methodology for these
calculations can be found in the docket.
For the three years covered in the ICR, the total respondent burden associated with information
collection will average approximately 254 thousand hours per year and the respondent cost will average
$19.2 million per year. This does not include over 31 thousand hours and $2.1 million avoided per year in
RCRA reclamation reporting and recordkeeping (see section 4.3). The breakdown of the burden per year
is provided in Table 4-3 in 2023 dollars, based on 2023 labor rates. The ICR will be subject to renewal
after the three-year time period is over.
Table 4-3: Total Respondent Burden Costs Over the Three-year ICR Period (2023$s)
) ear
Totul
/{espouses
lotal Hours
iota! Labor
( osts
Total O&M
( osrs
Total ( osts
Year 1 (2026)
3yr ICR Annual
Average
4,445,381
141,372
$12,155,355.28
$0.00
si:,155,355
4,810,033
223,029
$17,580,430.39
$0.00
$17,580,430
5,115,220
396,447
$27,869,424.28
$0.00
$27,869,424
4,790,211
253,616
$19,201,736.65
$0.00
$19,201,737
For this analysis, these recordkeeping and reporting costs are also shown in 2022 dollars (based on
2022 labor rates) in Table 4-4 below.
Table 4-4: Total Respondent Burden Costs Over the Three-year ICR Period (2022$s)
) ear
Total
Respouses
l otal Hours
l otal Labor
( osts
Total (.
Si:.l55.S5(.
Year 2 (2027)
4.810.033
223,029
$18,485,140.57
$0.00
$18,485,141
Year 3 (2028)
5,115,220
396,447
$28,854,376.49
$0.00
$28,854,376
3yr ICR Annual
Average
4,790,211
253,616
$19,831,791.01
$0.00
$19,831,791
Chapter 5. Climate Benefits
5.1 Consumption and Emission Reductions
EPA's Vintaging Model is used to estimate both consumption and emissions for each regulated
substance for each generation or "vintage" of equipment in both a reference case scenario and policy
compliance scenario. Reductions in consumption (in units of MMTEVe) are calculated for a given year
55
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by summing the total tons of virgin manufacture of HFCs avoided resulting from compliance with the
rule across all end-uses. Emission reductions are similarly calculated by summing total HFC emissions
avoided across end-uses in the compliance scenario. For many of the requirements contained in the final
ER&R Rule, emissions reductions are assumed to occur in the same year as corresponding reductions in
consumption and vice versa. For example, leak repair and inspection measures result in avoided emissions
from equipment leaks and an equivalent amount of avoided demand (i.e., consumption) that would
otherwise be required to "top off' the leaking equipment. In this case, both the emissions reduction and
equivalent consumption reduction are modeled as occurring in the same year. As another example,
measures that require increased recovery of HFCs from equipment at disposal also yield a reduction in
emissions (since it is assumed the gas would otherwise be released), however the timing of when this
recovered material will then be placed back onto the market as reclaimed refrigerant is uncertain and may
well occur well after the material was recovered.
The reference case for this analysis includes baseline levels of recovery of HFCs and resulting
avoided emissions, derived from the Vintaging Model BAU. While the requirements pertaining to
servicing and/or repair of certain equipment with reclaimed HFCs contained in the final rule may yield
further recovery of HFCs and resulting avoided emissions, EPA has conservatively assumed that these
measures do not necessarily yield incremental HFC emissions reductions beyond these baseline levels.33
EPA has further assumed that not all reclaimed HFCs utilized for the servicing and/or repair of certain
refrigerant-containing equipment would be in direct response to this rule, and that some reclamation
would occur in the absence of policy. In this way, EPA has conservatively estimated the amount of HFC
recovery, re-use, and reclamation activity attributable to the rule's provisions versus the amount that
would otherwise occur in the absence of the requirements. More details on these assumptions can be
found in Chapter 3 as well as the appendices accompanying this document.
Due to these factors and assumptions, in the results presented below consumption and emission
reductions resulting from the measures included in this analysis may not occur on a one-to-one basis in a
given year and may also be less than the full amount of refrigerant demand affected by a particular
provision. For more details on these assumptions, please see section 3.3 and Appendix E of this RIA
Addendum.
33 This assumption is made for technical analytic purposes and to avoid over-estimation of incremental benefits
relative to the established model BAU relied upon for previous analyses including the Allocation Rules and 2023
Technology Transitions Rule RIA and RIA Addenda, and should not be interpreted as a reflection of the merits of
any particular provision contained in the final rule.
56
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Table 5-1 below shows the consumption reductions by year corresponding to the final ER&R Rule
compliance scenario (base case) evaluated in this analysis. As discussed in Chapter 3 of this document,
incremental benefits reflect reductions that are additional to the compliance scenario previously assessed
by EPA in the 2023 Technology Transitions Rule RIA Addendum.
Table 5-1: Annual Incremental Consumption Reductions (MMTC02e) for ER&R Rule - Base Case
Scenario
Year
Leak Repair and
All)
I'ire Suppression
I se of Reclaim
(Sen icinu)
Cylinder
Management
2026
5.4
0.77
0.0
0.0
2030
4.7
4.1
12
2.1
2035
3.9
4.3
8.4
1.5
2040
2.6
4.5
5.7
1.1
2045
1.3
4.7
4.4
0.94
2050
0.68
4.9
4.5
0.90
Total
(2026-2050)
78
«>8
151
31
Table 5-2 below shows the emissions reductions by year corresponding to the final ER&R Rule
compliance scenario (base case) evaluated in this analysis. As discussed in Chapter 3 of this document,
incremental benefits reflect reductions that are additional to the compliance scenario previously assessed
by EPA in the 2023 Technology Transitions Rule RIA addendum.
Table 5-2: Annual Incremental Emissions Reductions (MMTCO^e) for ER&R Rule Base Case Scenario
Year
Leak Repair and
AM)
l ire Suppression
I se of Reclaim
(Sen icin»)
Cylinder
Management
2026
5 4
i) ii|
-*
0 0
2030
5.6
0.01
-
2.1
2035
4.6
0.01
-
1.5
2040
3.0
0.01
-
1.1
2045
1.5
0.01
-
0.94
2050
0.92
0.01
-
0.90
Total
(2026-2050)
SS
0.21
-
31
*Reclaim requirements may lead to additional emissions reductions by inducing increased recovery of refrigerant at
servicing and disposal that may otherwise be released or vented. In our base case scenario, EPA does not estimate an
increase in these avoided emissions beyond reference case assumptions.
57
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The mix and distribution of HFCs in refrigerant-containing appliances is anticipated to change
significantly in the coming decades, resulting in different leak repair and inspection benefits for later
years. As shown in Table 5-2 above, the annual GWP-weighted GHG emissions avoided from HFC
refrigerants resulting from leak repair and ALD provisions in 2050 is less than half that of 2026. This is
not due to decreased efficacy of leak repair or ALD systems or a decrease in use of refrigerant, but rather
is a result of the reduction over time in the average GWP of the refrigerant contained in equipment that
would otherwise leak.
5.2 Benefits of Reducing HFC Emissions
The primary benefits of this final rule are expected to derive from preventing the emissions of HFCs,
thus reducing the damage from climate change that would have been induced by those emissions. The 18
HFCs and their isomers regulated under the AIM Act are GHGs that can trap much more heat per ton
emitted than CO2, a ratio shown in each chemical's GWP. The ratio of the amount of heat trapped by one
ton of a chemical in the 100 years after it is emitted to the amount of heat trapped by one ton of CO2 in
100 years after being emitted is the chemical's 100-year GWP, and the HFCs regulated under the
phasedown have 100-year GWPs ranging from 53 to 14,800, with the vast majority of HFCs emitted
having GWPs over 1,000. Prior to HFC regulation under the AIM Act, it was anticipated that HFC use
and emissions would continue to rise, helping to drive global climate change. Thus, reducing the amount
of HFCs that are used and emitted prevents climate damage and associated social costs that would have
been induced by those HFC emissions. A more complete discussion of climate change damages and the
social benefits of preventing them can be found in Sections 4.1 and 4.2 of the Allocation Framework Rule
RIA.34 While there may be other benefits to phasing down HFCs, the benefits monetized in this analysis
are limited to the climate benefits of reduced HFC emissions.
While CO2 is the most prevalent GHG emitted by humans, it is not the only GHG with climate
impacts. The EPA Endangerment Finding (2009) defined a basket of six gases as the GHG air pollutant
addressed in the finding, comprising CO2, methane (CH4), nitrous oxide (N2O), HFCs, perfluorocarbons
(PFCs), and sulfur hexafluoride (SF6). The climate impact of the emission of a molecule of each of these
gases is generally a function of their lifetime in the atmosphere and the radiative efficiency of that
molecule. We estimate the climate benefits for this rulemaking using estimates of the social cost of each
HFC (collectively referred to as SC-HFC) that is affected by the rule. The SC-HFC is the monetary value
of the net harm to society associated with a marginal increase in HFC emissions in a given year, or the
benefit of avoiding that increase. In principle, SC-HFC includes the value of all climate change impacts,
34 Available at: https://www.regulations.gov/document/EPA-HO-QAR-2021 -0044-0227
58
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including (but not limited to) changes in net agricultural productivity, human health effects, property
damage from increased flood risk and natural disasters, disruption of energy systems, risk of conflict,
environmental migration, and the value of ecosystem services. The SC-HFC, therefore, reflects the
societal value of reducing emissions of the HFC in question by one metric ton. The SC-HFC is the
theoretically appropriate value to use in conducting benefit-cost analyses of policies that affect HFC
emissions.
The monetization of climate benefits in this analysis uses the same HFC-specific SC-HFC estimates
as used in the proposal RIA and in the estimation of the benefits in the Allocation Framework Rule RIA.
That is, for the primary benefits analysis in this final RIA, EPA uses SC-HFC estimates that are consistent
with the methodology underlying the interim SC-GHG estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive Order
13990 (IWG-SCGHG, 2021) that the Interagency Working Group (IWG) on the SC-GHG recommended
for use until updated estimates that address the National Academies' recommendations are available. The
SC-HFC estimates (shown in Appendix I) are presented in 2022 dollars per metric ton of HFC emitted by
year. As explained in Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under E.O.
13990, it is appropriate for agencies to revert to the same set of four values drawn from the social cost of
greenhouse gases (SC-GHG) distributions based on three discount rates as were used in regulatory
analyses between 2010 and 2016 and subject to public comment (2.5 percent, 3 percent, and 5 percent),
plus a fourth value, selected as the 95th percentile of estimates based on a 3 percent discount rate. The
fourth value was included to provide information on potentially higher-than-expected economic impacts
from climate change, conditional on the 3 percent estimate of the discount rate. In that document it was
also found that the use of the social rate of return on capital (7 percent under current OMB Circular A-4
guidance) to discount the future benefits of reducing GHG emissions inappropriately underestimates the
impacts of climate change for the purposes of estimating the SC-GHG. For purposes of capturing
uncertainty around the SC-HFC estimates in analyses, we emphasize the importance of considering all
four values for each HFC affected by the rule. For each HFC, the SC-HFC estimate increases over time
within the models—i.e., the societal harm from one metric ton emitted in 2030 is higher than the harm
caused by one metric ton emitted in 2025—because future emissions produce larger incremental damages
as physical and economic systems become more stressed in response to greater climatic change, and
because gross domestic product (GDP) is growing over time and many damage categories are modeled as
proportional to GDP. A more complete discussion of the development of these SC-HFC estimates can be
found in section 4.1 of the Allocation Framework Rule RIA.
59
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In addition to the climate benefits presented in Section 5.3 below, in Appendix J, EPA presents the
monetized climate benefits of the final rule using a new set of SC-HFC estimates that reflect recent
advances in the scientific literature on climate change and its economic impacts and incorporate
recommendations made by the National Academies of Science, Engineering, and Medicine (NASEM,
2017). The methodology underlying these updated SC-HFC estimates is consistent with the SC-GHG
estimates used in the EPA's 2023 RIA for the Final Oil and Gas New Source Performance Standards
(NSPS)/Emissions Guidelines (EG) Rulemaking, "Standards of Performance for New, Reconstructed, and
Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate
Review". As EPA noted in the proposal RIA for this rulemaking, EPA solicited public comment on the
methodology and use of these estimates in the RIA for the agency's December 2022 Oil and Gas
NSPS/EG Supplemental Proposal (EPA 2022)35 and has conducted an external peer review of these
estimates, as described further below.
The EPA solicited public comment on the sensitivity analysis and the accompanying draft technical
report, External Review Draft of Report on the Social Cost of Greenhouse Gases: Estimates Incorporating
Recent Scientific Advances, which explains the methodology underlying the new set of estimates, in the
December 2022 Supplemental Oil and Gas Proposal. The response to comments document can be found
in the docket for that action.
To ensure that the methodological updates adopted in the technical report are consistent with
economic theory and reflect the latest science, the EPA also initiated an external peer review panel to
conduct a high-quality review of the technical report, completed in May 2023 (EPA 2023c). The peer
reviewers commended the agency on its development of the draft update, calling it a much-needed
improvement in estimating the SC-GHG and a significant step towards addressing the National
Academies' recommendations with defensible modeling choices based on current science. The peer
reviewers provided numerous recommendations for refining the presentation and for future modeling
improvements, especially with respect to climate change impacts and associated damages that are not
currently included in the analysis. Additional discussion of omitted impacts and other updates have been
incorporated in the technical report to address peer reviewer recommendations. Complete information
about the external peer review, including the peer reviewer selection process, the final report with
individual recommendations from peer reviewers, and the EPA's response to each recommendation is
available on EPA's website.36 Appendix J presents the climate benefits of the final rule using the updated
35 EPA, 2022. Standard of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing
Sources: Oil and Natural Gas Sector Climate Review. A Proposed Rule by the EPA on 12/06/22.
36 https://www.epa.gov/environmental-economics/scghg
60
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methodology set forth in EPA 2023d37 for the calculation of SC-HFC. For more information on the
updated SC-HFC estimates please also see the files included with this rule in the docket, titled
GLOBAL 2023 AIM.
5.3 Monetized Climate Benefits Results
To monetize the climate benefits resulting from the final ER&R Rule provisions evaluated in this
analysis, the HFC emission reductions in each year are multiplied by the corresponding SC-HFC for that
HFC in that year.
Table 5-3 below shows the undiscounted monetized incremental climate benefits from all regulated
HFCs under the base case. When the base case benefits are discounted to 2024 using a discount rate of 3
percent, the present value of the incremental benefits of the final rule provisions evaluated in this analysis
are estimated to be $8.4 billion in 2022 dollars (under a 3% constant discount rate). This is equivalent to
an annual incremental benefit of $0.5 billion per year over that timeframe.
Table 5-34: Undiscounted Monetized Climate Benefits 2026-2050 (2022$)a'b'c'd
liasc ( use
Incremental ( Umatc licncjits (millions 2H22S)
Year
S( -///¦'( 1 Discount Rate am! Statistic
¦)
- . O
.1 vcra^c
.> o
¦ 1rcratfc
o
¦ 1 vcra^c
J"o
V.V' Percentile
2025
$0.00
$0.00
$0.00
$0.00
2026
$580.00
$430.00
$180.00
$1,100.00
2027 "
$670.00
$500.00
$210.00
$1,300.00
2028
$920.00
$690.00
$290.00 _
$1,800.00
2029
$910.00
$290.00
$1,800.00
2030
$900.00
$680.00
$290.00 _
$1,800.00
2031
$890.00
$290.00
$1,800.00
2032
$870.00
$660.00
$290.00
$1,800.00
2033
$860.00
$290.00
$1,700.00
2034
$840.00
$640.00
$280.00
$1,700.00
2035
$800.00
$610.00
$270.00
$1,600.00
2036
$760.00
$590.00
$270.00
$1,600.00
2037
$730.00
$250.00
$1,500.00
2038
$680.00
$530.00
$240.00 _
$1,400.00
2039
$640.00
$500.00
$230.00
$1,300.00
2040
$600.00
$470.00
$220.00 _
$1,300.00
2041
$570.00
$440.00
$210.00
$1,200.00
2042
$510.00
$400.00
$190.00
$1,100.00
37 EPA, 2023d. Regulatory Impact Analysis of the Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.
61
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2043
$470.00
S.<
$180.00
$980.00
2044
$430.00
$340.00
$170.00
$910.00
2045
$400.00
$320.00
$160.00
$850.00
2046
$380.00
$300.00
$150.00
$800.00
2047
$360.00
$280.00
$140.00
$760.00
2048
$340.00
$270.00
$140.00
$730.00
2049
$330.00
$140.00
$710.00
2050
S14
PY
.Dili) nil
::<)<)<).<)(>
I'.AY
l,.t)()l)
4X<) on
2I()()()()
i .oo.di)
a Rows may not appear to add correctly due to rounding.
b Present values are calculated using end of year discounting.
c The equivalent annual values of benefits are calculated over a 25-year period.
'' Climate benefits are based on changes in HFC emissions and are calculated using four different estimates of the
SC-HFCs (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount
rate).
Unlike many environmental problems where the causes and impacts are distributed more locally,
GHG emissions are a global externality making climate change a true global challenge. GHG emissions
contribute to damages around the world regardless of where they are emitted. Because of the distinctive
global nature of climate change, in the RIA for this final rule the EPA centers attention on a global
measure of climate benefits from the HFC emission reductions.
Consistent with all IWG recommended SC-GHG estimates to date, Table 5-3 presents the monetized
global climate impacts of the HFC emission changes expected from the final rule. This approach is the
same as that taken in EPA regulatory analyses from 2009 through 2016 and since 2021, including in the
RIA for the proposal rule. It is also consistent with guidance in (OMB, 2003) (OMB, 2023) that
recommends reporting of important international effects38. EPA also notes that EPA's cost estimates in
38 The 2003 version of OMB Circular A-4 states when a regulation is likely to have international effects, "these effects should be
reported"; while OMB Circular A-4 recommends that international effects we reported separately, the guidance also explains that
"[different regulations may call for different emphases in the analysis, depending on the nature and complexity of the regulatory
issues." (OMB, 2003).
The 2023 update to Circular A-4 states that "In certain contexts, it may be particularly appropriate to include effects experienced
by noncitizens residing abroad in your primary analysis. Such contexts include, for example, when:
• assessing effects on noncitizens residing abroad provides a useful proxy for effects on U.S. citizens and residents that are
difficult to otherwise estimate;
• assessing effects on noncitizens residing abroad provides a useful proxy for effects on U.S. national interests that are not
otherwise fully captured by effects experienced by particular U.S. citizens and residents (e.g., national security interests,
diplomatic interests, etc.);
• regulating an externality on the basis of its global effects supports a cooperative international approach to the regulation of the
externality by potentially inducing other countries to follow suit or maintain existing efforts; or
• international or domestic legal obligations require or support a global calculation of regulatory effects" (OMB 2023). Due to the
global nature of the climate change problem, the OMB recommendations of appropriate contexts for considering international
effects are relevant to the HFC emission reductions expected from the final rule. For example, as discussed in this RIA, a global
focus in evaluating the climate impacts of changes in HFC emissions supports a cooperative international approach to GHG
mitigation by potentially inducing other countries to follow suit or maintain existing efforts, and the global SC-HFC estimates
62
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RIAs, including the cost estimates contained in this RIA, regularly do not differentiate between the share
of compliance costs expected to accrue to U.S. firms versus foreign interests, such as to foreign investors
in regulated entities39. A global perspective on climate effects is therefore consistent with the approach
EPA takes on costs. There are many reasons, as summarized in this section - and as articulated by OMB
and in IWG assessments (IWG-SCC 2010; IWG-SCC 2013; IWG-SCGHG 2016a; IWG-SCGHG 2016b;
IWG-SCGHG 2021), the 2015 Response to Comments (IWG-SSC 2015) and in detail in EPA (2023c)
and in Appendix A of the Response to Comments document for the December 2023 Final Oil and Gas
NSPS/EG Rulemaking - why the EPA focuses on the global value of climate change impacts when
analyzing policies that affect GHG emissions.
International cooperation and reciprocity are essential to successfully addressing climate change, as
the global nature of greenhouse gases means that a ton of GHGs emitted in any other country harms those
in the U.S. just as much as aton emitted within the territorial U.S. Assessing the benefits of U.S. GHG
mitigation activities requires consideration of how those actions may affect mitigation activities by other
countries, as those international mitigation actions will provide a benefit to U.S. citizens and residents by
mitigating climate impacts that affect U.S. citizens and residents. This is a classic public goods problem
because each country's reductions benefit everyone else, and no country can be excluded from enjoying
the benefits of other countries' reductions. The only way to achieve an efficient allocation of resources for
emissions reduction on a global basis — and so benefit the U.S. and its citizens and residents — is for all
countries to base their policies on global estimates of damages. A wide range of scientific and economic
experts have emphasized the issue of international cooperation and reciprocity as support for assessing
global damages of GHG emission in domestic policy analysis. Using a global estimate of damages in U.S.
analyses of regulatory actions allows the U.S. to continue to actively encourage other nations, including
emerging major economies, to also assess global climate damages of their policies and to take steps to
reduce emissions. Several recent studies have empirically examined the evidence on international GHG
mitigation reciprocity, through both policy diffusion and technology diffusion effects. See EPA (2023d)
for more discussion.
For all of these reasons, the EPA believes that a global metric is appropriate for assessing the climate
impacts of GHG emissions in this final RIA. In addition, as emphasized in the (NASEM, 2017)
recommendations, "[i]t is important to consider what constitutes a domestic impact in the case of a global
better capture effects on U.S. citizens and residents and U.S. national interests that are difficult to estimate and not otherwise
fully captured.
39 For example, in the RIA for the 2018 Proposed Reconsideration of the Oil and Natural Gas Sector Emission Standards for
New, Reconstructed, and Modified Sources, the EPA acknowledged that some portion of regulatory costs will likely "accrufe] to
entities outside U.S. borders" through foreign ownership, employment, or consumption. In general, a significant share of U.S.
corporate debt and equities are foreign-owned, including in the oil and gas industry.
63
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pollutant that could have international implications that impact the United States." The global nature of
GHG pollution and its impacts means that U.S. interests are affected by climate change impacts through a
multitude of pathways and these need to be considered when evaluating the benefits of GHG mitigation to
U.S. citizens and residents. The increasing interconnectedness of global economy and populations means
that impacts occuring outside of U.S. borders can have significant impacts on U.S. interests. Examples of
affected interests include direct effects on U.S. citizens and assets located abroad, international trade, and
tourism, and spillover pathways such as economic and political destabilization and global migration that
can lead to adverse impacts on U.S. national security, public health, and humanitarian concerns. Those
impacts point to the global nature of the climate change problem and are better captured within global
measures of the social cost of greenhouse gases.
In the case of these global pollutants, for the reasons articulated in this section, the assessment of
global net damages of GHG emissions allows EPA to fully disclose and contextualize the net climate
benefits of HFC emission reductions expected from this final rule. The EPA disagrees with public
comments received on the December 2022 Oil and Gas NSPS/EG Supplemental Proposal that suggested
that the EPA can or should use a metric focused on benefits resulting solely from changes in climate
impacts occurring within U.S. borders. The global models used in the SC-GHG modeling do not lend
themselves to be disaggregated in a way that could provide comprehensive information about the
distribution of the rule's climate impacts to citizens and residents of particular countries, or population
groups across the globe and within the U.S. As discussed in the Allocation Framework Rule RIA, these
estimates are only a partial accounting and do not capture all of the pathways through which climate
change affects public health and welfare. Thus, they only cover a subset of potential climate change
impacts. Furthermore, the estimates do not capture spillover or indirect effects whereby climate impacts
in one country or region can affect the welfare of residents in other countries or regions— such as how
economic and health conditions across countries will impact U.S. business, investments, and travel
abroad.40
Additional modeling efforts can and have shed further light on some omitted damage categories. For
example, the Framework for Evaluating Damages and Impacts (FrEDI) is an open-source modeling
40The limitations discussed in this paragraph also apply to the models used in the updated SC-HFC estimates used in Appendix J.
For example, two of the models used to inform the updated methodology, the Greenhouse Gas Impact Value Estimator (GIVE)
and Data-driven Spatial Climate Impact Model (DSCIM) models, have spatial resolution that allows for some geographic
disaggregation of future climate impacts across the world. This permits the calculation of a partial GIVE and DSCIM-based SC-
GHG measuring the damages from four or five climate impact categories projected to physically occur within the U.S.,
respectively, subject to caveats. As discussed at length in EPA (2023c), these damage modules are only a partial accounting and
do not capture all of the pathways through which climate change affects public health and welfare. For example, this modeling
omits most of the consequences of changes in precipitation, damages from extreme weather events (e.g., wildfires), the potential
for nongradual damages from passing critical thresholds (e.g., tipping elements) in natural or socioeconomic systems, and non-
climate mediated effects of GHG emissions other than CO2 fertilization.
64
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framework developed by EPA to facilitate the characterization of net annual climate change impacts in
numerous impact categories within the contiguous United States (CONUS) (i.e., excluding Hawaii,
Alaska, and U.S. territories) and monetize the associated distribution of modeled damages (Hartin et al.,
2023; EPA, 2021) 41 The additional impact categories included in FrEDI reflect the availability of U.S.-
specific data and research on climate change effects. Results from FrEDI show that annual damages
resulting from climate change impacts within CONUS and for impact categories not represented in the
latest global models are expected to be substantial. For example, applying U.S.-specific partial SC-HFC
estimates derived from FrEDI to the HFC emission reductions expected under the final rule would yield
substantial climate benefits. The present value of the climate benefits of the final rule as measured by
FrEDI from climate change impacts in CONUS are estimated to be $2.98 billion (under a 2 percent near-
term Ramsey discount rate)42. However, the numerous explicitly omitted damage categories and other
modeling limitations discussed above and throughout EPA (2023d) make it likely that these estimates
underestimate the climate benefits to U.S. citizens and residents of the HFC emission reductions from the
final rule.43 The limitations in developing a U.S.-specific estimate that accurately captures direct and
spillover effects on U.S. citizens and residents further demonstrates that it is more appropriate to use a
global measure of climate impacts from GHG emissions. The EPA will continue to review developments
in the literature, including more robust methodologies for estimating the magnitude of the various
damages to U.S. populations from climate impacts and reciprocal international mitigation activities, and
explore ways to better inform the public of the full range of GHG impacts.
Chapter 6. Comparison of Costs and Benefits
This section summarizes the total incremental compliance costs (or savings) and the monetized
incremental environmental benefits detailed in the sections above to provide an assessment of the total net
incremental costs/benefits of requirements contained in the final rule. As described above, abatement
costs for the ER&R Rule requirements were estimated using EPA's Vintaging Model and MACC
41 The FrEDI framework and Technical Documentation have been subject to a public review comment period and an independent
external peer review, following guidance in the EPA Peer-Review Handbook for Influential Scientific Information (ISI).
Information on the FrEDI peer-review is available at the EPA Science Inventory (EPA Science Inventory, 2021).
42 Please see the docket for the full calculation (FrEDI_2023_AIM.xlsx).. The inputs to the FrEDI modeling are consistent with
the methodological advances reflected in the updated SC-HFCs using in Appendix J.
43 Another method that has produced estimates of the effect of climate change on U.S.-specific outcomes uses a top-down
approach to estimate aggregate damage functions. Published research using this approach include total-economy empirical
studies that econometrically estimate the relationship between GDP and a climate variable, usually temperature. As discussed in
EPA (2023c) the modeling framework used in the existing published studies using this approach differ in important ways from
the inputs underlying the SC-GHG estimates described above (e.g., discounting, risk aversion, and scenario uncertainty) and
focus solely on CO2. Hence, we do not consider this line of evidence in the analysis for this RIA. Updating the framework of
total-economy empirical damage functions to be consistent with the methods described in this RIA and EPA (2023c) would
require new analysis. Finally, because total-economy empirical studies estimate market impacts, they do not include any non-
market impacts of climate change (e.g., heat related mortality) and therefore are also only a partial estimate. EPA will continue to
review developments in the literature and explore ways to better inform the public of the full range of GHG impacts.
65
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methodology, while monetized climate benefits were estimated based on SC-HFC methodology
consistent with the interim SC-GHG estimates recommended under E.O. 13990. The impact of additional
final rule requirements not modeled using the MACC methodology—including cylinder management
provisions and recordkeeping and reporting requirements—were then added on in order to estimate the
combined costs, benefits, and net benefits of the final rule.
Table 6-1 below provides annual incremental costs, benefits, and net incremental costs of the final
rule provisions. As shown, the present value of net incremental benefits is estimated to range from $6.9
billion to $7.5 billion in the base case scenario, using a 3% discount rate for climate benefits and either a
2%, 3%, or 7% discount rate for compliance costs.
Table 6-1: Summary of Annual Incremental Undiscounted Climate Benefits, Costs, and Net Benefits in
Base Case Scenario for the 2026 2050 Timeframe (millions of2022S)ah ade f
I* lt>< I'uuil liule Impai rs - linse ( use
Year
Incremental
CUmule lienejils
¦Innnul ( osls (savings)
.Yel lienejils
2026
$428
$92
$336
"'2627'
$498
$130
$368
2028
$688
$110
$579
2029
$683
$105
$579
2030
$676
$102
$574
2031
$670
$99
$57l"
2032
$662
$96
$565
2033
$653
' $93
$560
2034
$640
$91
$549
2035
$613
$87
$526
2036
$586
$83
$503
2037
$557
$79
$478
2038
$527
$75
$452
2039
$497"
$71
$426
2040
$466
$67
$399
2041
$440°
$64
$376
2042
$400
$59
$341
2043
$364
$55
$309
2044
$337
$53
$284
2045
$315
'$51
$264
2046
$298
$51
$246
2047
$283
$51
$232"
2048
$271
$51
$220
2049
$264
$51
$213
2050
$263
$52
$211
66
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Discount
rale
3"n
2"i.
3v
7%
2"ii
3"ii
7%
PV
$8,356
$1,499
$1,335
$884
$6,857
$7,021
S7,471
EAV
$480
$77
$77
$76
$403
$403
$404
aBenefits include only those related to climate. Climate benefits are based on changes (reductions) in HFC
emissions and are calculated using four different estimates of the social cost of HFCs (SC-HFCs): model average at
2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate. For the presentational
purposes of this table, we show the benefits associated with the average SC-HFC at a 3 percent discount rate.
b Rows may not appear to add correctly due to rounding.
0 Present values are calculated using end of year discounting.
d The annualized present value of costs and benefits are calculated as if they occur over a 25-year period.
e The costs presented in this table are annual estimates.
f The PV for the net benefits column is found by taking the difference between the PV of climate benefits at 3
percent and the PV of costs discounted at 7 percent, 3 percent or 2 percent. Because the SC-HFC estimates reflect
net climate change damages in terms of reduced consumption (or monetary consumption equivalents), the use of the
social rate of return on capital (7 percent under OMB Circular A-4 (2003)) to discount damages estimated in terms
of reduced consumption would inappropriately underestimate the impacts of climate change for the purposes of
estimating the SC-HFC. See Chapter 5 for more discussion.
Table 6-2 below provides the present value (discounted to 2024) of costs, benefits, and net
incremental by type of provision contained in the final rule. Present value for climate benefits is
calculated using a 3 percent discount rate, while present value for costs (or saving) is calculated using a 2,
3, and 7 percent discount rate.
Table 6-2: Present Value of Incremental Climate Benefits, Costs, and Net Benefits by type of rule
provision in Base Case Scenario for the 2026-2050 Timeframe (millions of2022$, discounted to
2024)a-b-c-d
Pro\ ision
Climale
Ik'iiclils
Costs Costs Costs
(Sa\ings) (Sa\ings) (Sa\ings)
(2V'ii) (3"o) t
Net Net Net
licncfils lienelils licncfils
3n;. <3n;. (3"'(,
lienel'ils. lienel'ils. liencfils.
2"/« Cosls) 3V'ii Cosls) ""!•'» Cosls)
Leak
Repair
And ALD
Fire
Suppressio
n
Cylinder
Manageme
nt
Use of
Reclaimed
HFCs for
Servicing
Recordkee
ping &
Reporting
$6,176
$1,285 $1,146 $760
$4,891 $5,031 $5,417
$14
$15 $13 $7
($1) $1 $7
$2,165
($195) ($169) ($101)
$2,360 $2,335 $2,266
$43 $38 $23
($43) ($38) ($23)
$350 $308 $195
($350) ($308) ($195)
67
-------
RCRA
Amendme
nts**
$0 to
($40)
$0 to
($35)
$0 to
($22)
$0 to $40 $0to$35 $0 to $22
*Reclaim requirements may lead to additional emissions reductions by inducing increased recovery of refrigerant at
servicing and disposal that may otherwise be released or vented. In our base case scenario, EPA does not estimate an
increase in these avoided emissions beyond baseline assumptions.
** RCRA Amendments are not included in the total benefits of this final rule as presented in the text above but are
included here for informational purposes.
Chapter 7. Environmental Justice
7.1 Introduction and Background
The environmental justice analyses that were conducted as part of the Allocation Framework Rule
RIA and subsequent 2024 Allocation Framework Rule and 2023 Technology Transitions Rule RIA
addenda addressed issues associated with the impacts of changes in the production of HFCs and certain
substitutes of HFCs on communities near facilities identified as producers of these chemicals. EPA could
not identify specific effects of the HFC phasedown or transitions on individual communities, but the
Agency did identify ten specific facilities with emissions likely to be affected by these rules. EPA
analyzed the demographic characteristics of the fence-line communities in the Census Block Groups
within 1-, 3-, 5-, and 10-mile radii of the affected facilities. Please refer to Chapter 6 of the Allocation
Framework Rule RIA for an extensive discussion of the environmental justice implications of HFC
production and transition.
This chapter provides an analysis of the environmental justice (EJ) implications of this final rule
under Subsection (h) of the AIM Act. The information provided in this section of this document is for
informational purposes only; EPA is not relying on the information in this section as a record basis for the
final action. This analysis is largely similar in approach to that used in the previous EJ analyses, in that it
focuses on the baseline environmental conditions in communities proximate to known HFC reclamation
facilities which EPA expects may be affected by the final rule.
As discussed in the preamble to this rule, the ER&R Rule establishes a program for the management
of hydrofluorocarbons that includes requirements for: leak repair and use of automatic leak detectors for
certain equipment containing HFC refrigerants; servicing and/or repair of refrigerant-containing
equipment in certain sectors or subsectors with reclaimed HFCs; the servicing, repair, disposal, or
installation of fire suppression equipment that contains HFCs; removal of HFCs from disposable
cylinders before discarding; and recordkeeping, reporting, and labeling. EPA is also establishing
alternative Resource Conservation and Recovery Act (RCRA) standards for ignitable spent refrigerants
68
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being recycled for reuse. The new standards require that ignitable spent refrigerant being recycled for
reuse be sent to EPA-certified reclamation facilities.
7.2 Environmental Justice at EPA
Executive Order 14096, signed April 21, 2023, builds on the prior executive orders to further advance
environmental justice (88 FR 25251), including Executive Order 12898 (59 FR7629, February 16, 1994)
and Executive Order 14008 (86 FR 7619, January 27, 2021) which establish federal executive policy on
environmental justice. EPA defines44 environmental justice as the "just treatment and meaningful
involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or
disability, in agency decision-making and other Federal activities that affect human health and the
environment so that people: (i) are fully protected from disproportionate and adverse human health and
environmental effects (including risks) and hazards, including those related to climate change, the
cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or
systemic barriers; and (ii) have equitable access to a healthy, sustainable, and resilient environment in
which to live, play, work, learn, grow, worship, and engage in cultural and subsistence practices."45 EPA
also released its "Technical Guidance for Assessing Environmental Justice in Regulatory Analysis" (EPA
2016) to provide recommendations that encourage analysts to conduct the highest quality analysis
feasible, recognizing that data limitations, time and resource constraints, and analytic challenges will vary
by media and circumstance. See Section VII of the final rule for further discussion on the implications of
this rule with respect to environmental justice.
As noted in the Allocation Framework Rule RIA, the production and consumption of HFCs is
expected to result in changes in the emissions of chemicals which burden communities surrounding HFC
production facilities. Because of the limited information regarding how much of each substitute would be
produced, which substitutes would be used, and what other factors might affect production and emissions
at those locations, it's unclear to what extent baseline risks from hazardous air toxics for communities
living near HFC production facilities may be affected. We recognize that communities neighboring
facilities that currently produce HFCs and HFC alternatives are often overburdened and disadvantaged.
The Agency has a strong interest in mitigating undue burden on underserved communities.
EPA stated its intention in the Allocation Framework Rule to "continue to monitor the impacts of this
program on HFC and substitute production, and emissions in neighboring communities, as we move
44 EPA recognizes that Executive Order 14096 (88 FR 25251, April 21, 2023) provides a new terminology and anew definition
for environmental justice. For additional information, see https://www.federalregister.gov/documents/2023/04/26/2023-
08955/revitalizing-our-nations-commitment-to-environmental-justice-for-all.
45 See, e.g., Environmental Protection Agency. "Environmental Justice." Available at: https://www.epa.gov/environmentaljustice.
69
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forward to implement this rule" (see 86 FR 55129). EPA will continue to work to address environmental
justice and equity concerns for the communities near the facilities identified in this analysis.
7.3 Environmental Justice Analysis for this Rule
In the Allocation Framework Rule, EPA summarized the public health and welfare effects of GHG
emissions (including HFCs), including findings that certain parts of the population may be especially
vulnerable to climate change risks based on their characteristics or circumstances, including the poor, the
elderly, the very young, those already in poor health, the disabled, those living alone, and/or indigenous
populations dependent on one or limited resources due to factors including but not limited to geography,
access, and mobility (86 FR 55124 - 55125). Potential impacts of climate change raise environmental
justice issues. Low-income communities can be especially vulnerable to climate change impacts because
they tend to have more limited capacity to bear the costs of adaptation and are more dependent on
climate-sensitive resources such as local water and food supplies. In corollary, some communities of
color, specifically populations defined jointly by both ethnic/racial characteristics and geographic
location, may be uniquely vulnerable to climate change health impacts in the United States.
As discussed in more detail in the RIA for the Allocation Framework Rule, the environmental justice
benefits of reducing climate change are significant. The ER&R Rule is expected to result in benefits in the
form of reduced GHG emissions, including by reducing the rates of leakage of HFCs to the atmosphere
from new and existing equipment. The analysis conducted for this rule also estimates that a portion of
these benefits would be incremental to emissions reductions that were anticipated under the Allocation
and 2023 Technology Transitions Rules, thus further reducing the risks of climate change.
HFCs are not a local pollutant and have low toxicity to humans. The final rule is expected to result in
increased activity at HFC recovery and reclamation facilities. EPA does not anticipate that there are
significant increased risks to human health in communities near these facilities due to the presence or
potential leakage of the HFCs themselves. It is possible that other chemicals which are potential
byproducts of HFC reclamation processes, such as petroleum-based lubricants and waste oils, may be
released from these facilities. In addition, the RCRA provisions allow lower flammability spent
refrigerants to be sent to HFC recovery and reclamation facilities, potentially increasing the potential for
fires at the facilities. To help address the risks posed by fires, the standards include emergency
preparedness and response requirements.
For the purposes of this rule, EPA assessed the characteristics of communities near facilities we
expect to be affected by this rule (i.e., HFC reclamation facilities). EPA used data from reports required
70
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under Section 608 of the Clean Air Act,46 EPA's Enforcement and Compliance History Online (ECHO)
database47 and information provided by company websites to identify facilities that are active HFC
reclaimers. Once reclaim facility locations were identified, EPA retrieved the Facility Registry Service
(FRS) IDs for each facility using the Agency's FRS national dataset48 EPA derived additional
information on the communities surrounding the facilities included in this analysis using data from
AirToxScreen 2019 (EPA 2023h) and the Census' American Community Survey 2019 (U.S. Census
Bureau 2021). These steps were conducted to facilitate extracting 1) an environmental profile and 2)
demographic information within 1, 3, 5 and 10 miles for each facility.
Fenceline communities may be impacted by emissions or chemical releases from facilities of the type
identified here, although there is uncertainty about the nature and risks of potential emissions or chemical
releases. This analysis notes several limits to our ability to assess the impact of this rule on the exposure
that specific communities may face:
• The facilities that we identified are diverse, ranging in size from small, boutique facilities that
recover and reclaim HFCs for small markets to large chemical production facilities that have
several lines of business that may result in atmospheric emissions. EPA does not have
information that allows us to distinguish possible fugitive emissions from HFC reclamation
and other potential chemical processing or manufacture.
• Many of the communities near the facilities expected to be affected by this rule are also near
other sources of toxic emissions which contribute to environmental justice concerns.
• The final rule, and other changes in the HFC reclamation market, would likely result in an
overall increase in reclamation, but may result in increases or decreases in the activity at any
given facility, or the construction of additional facilities.
• In regard to the effect of the RCRA alternative standards on flammable refrigerants, any
potential increase in volumes sent to reclamation facilities would likely be offset by a
decrease in volume sent to incineration facilities, or vented illegally.
Due to the limitations of the current data, we cannot make conclusions about the impact of this rule
on individuals or specific communities. For the purposes of identifying environmental justice issues;
however, it is important to understand the characteristics of the communities surrounding these facilities
to better ensure that future actions, as more information becomes available, can improve outcomes.
46 EPA reviewed Section 608 annual reclamation reports to determine facilities that currently reclaim HFCs and may therefore be
expected to continue to do so in the future.
47 EPA's Enforcement and Compliance History Online (ECHO) database was used to verify locations of HFC reclamation
facilities (EPA n.d.)
48 FRS National Data Set available at https://www.epa.gov/frs/epa-frs-facilities-state-single-file-csv-download (EPA 2023h)
71
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Following the format used for the Allocation Framework Rule RIA, this analysis focuses on information
that is available on the demographics and baseline exposure of the communities near these facilities.
7.4 Aggregate Average Characteristics of Communities Near Potentially
Affected Facilities
The RIA for the Allocation Framework Rule notes that a key issue for evaluating potential for
environmental justice concerns is the extent to which an individual might be exposed to feedstock,
catalyst, or byproduct emissions from production of HFCs or HFC alternatives. This final rule may result
in increases in the numbers of individuals exposed to chemicals in the process of reclaiming and recycling
HFCs.
EPA has not undertaken an analysis of how potential emissions from HFC reclamation affect nearby
communities. However, a proximity-based approach can identify correlations between the location of
these identified reclamation facilities and potential effects on nearby communities. Specifically, this
approach assumes that individuals living within a specific distance of an HFC reclamation facility are
more likely to be exposed to releases from the reclamation process. Those living further away are less
likely to be exposed to these releases. Census block groups that are located within 1,3,5 and 10 miles of
the facility are selected as potentially relevant distances to proxy for exposure. Socioeconomic and
demographic data from the American Community Survey 5-year data release for 2019 is used to examine
whether a greater percentage of population groups of concern live within a specific distance from a
reclamation facility compared to the national average.
In addition, AirToxScreen data from 2019 for census tracts within and outside of a 1-, 3-, 5- and 10-
mile distance are used to approximate the cumulative baseline cancer and respiratory risk due to air toxics
exposure for communities near these reclamation facilities. The total cancer risk is reported as the risk per
million people if exposed continuously to the specific concentration over an assumed lifetime. The total
respiratory risk is reported as a hazard quotient, which is the exposure to a substance divided by the level
at which no adverse effects are expected. Both total risk measures are the sum of the individual risk
values for all the chemicals evaluated in the AirToxScreen database (EPA 2023h). Note that these risks
are not necessarily only associated with a specific HFC reclamation facility. Industrial activity is often
concentrated (i.e., multiple facilities located within the same geographic area).
Table 7-1 presents summary information for the demographic data and AirToxScreen risks averaged
across the thirty-eight communities near the identified production facilities compared to the overall
national average.
72
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The values in the last four columns reflect population-weighted averages across the Census block
groups within the specified distance of the facility. While it is not possible to disaggregate the risk
information from AirToxScreen by race, ethnicity or income, the overall total cancer and total respiratory
risk in communities within 1, 3, 5 or 10 miles of the facilities does appear to be elevated compared to
national average.
Table 7-1: Overall Community Profile and 2019 AirToxScreen Risks for Communities Near Identified
Facilities
Overall
\alional
Average
II iill in I mile
oj reclamation
facilities
II illiinmiles
oj reclamation
facilities
II illiin 5 miles
oj reclamation
facilities
II illiin Id
miles
of reclamation
facilities
% White (race)
72
65
63
62
62
% Black or African
American (race)
13
15
16
16
17
% Other (race)
15
19
:i
::
21
% Hispanic (ethnic origin)
18
29
:•>
:x
26
Median Household Income
Jlk2019$)_
% Below Poverty Line
71
77
76
75
76
7.3
7.1
~ *
" 5
7.2
% Below Half the Poverty
Line
5.8
5.5
5.7
5.9
5.7
Total Cancer Risk (per
million)
26
28
28.6
29
29
Total Respiratory Risk
(hazard quotient)
0.31
0.34
0.34
0.35
0.35
Notes: Demographic categories are as described in the 2019 American Community Survey (U.S. Census Bureau
2021). The "hazard quotient" is defined as the ratio of the potential exposure to a substance and the level at which
no adverse effects are expected (calculated as the exposure divided by the appropriate chronic or acute value). A
hazard quotient of 1 or lower means adverse noncancer effects are unlikely and, thus, can be considered to have
negligible hazard. For HQs greater than one, the potential for adverse effects increases, but we do not know by how
much. Total cancer and respiratory risk are drawn from the AirToxScreen database (2019) (EPA 2023h).
Looking across the thirty-eight facilities (Table 7-1), a higher percentage of non-white individuals
live in the communities near HFC reclamation facilities compared to the national average. Within one
mile of the facilities, the percentage of Black or African Americans is slightly higher than the national
average, (15 percent compared to 13 percent) but the percentage increases to 16 percent and 17 percent
for the 3 mile and 5 mile, and ten mile distances, respectively. For the communities near these facilities,
there are more whose race is identified as "Other," and whose ethnicity is "Hispanic" than the national
average. In these communities, the percentage of White residents is higher within one mile of the facilities
than farther away. Within one mile, 65 percent of the residents are white, which is lower than the national
average of 72 percent.
73
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Median income is generally higher for the communities near these facilities compared to the national
average, with the highest median income within the 1-mile radius ($77,000 per year, compared to the
national average of $71,000). These communities also generally have similar percentages of low-income
households (below the poverty line) and very low-income households (with incomes less than half the
poverty line) compared to the national average. The national percentage of households with incomes less
than half of the poverty line is 5.8%. Within 1 mile of these specific facilities, the average percentage of
households with incomes less than half of the poverty line 5.5 percent. At the 3- and 5-mile distances, the
number rises to 5.7 percent and 5.9 percent—it is 5.7 percent in the average 10-mile radius.
For this analysis, we use the 2019 AirToxScreen data for total cancer risk and total respiratory risk.
The overall national average total cancer risk using the newest data is 26 per million. The Total
Respiratory Index average for the nation as a whole is 0.31. The average aggregate risks in communities
near these facilities are generally higher than the national averages. The analysis also shows that Total
Cancer Risk is higher for those within the 1-mile average radius and increase at the 3-, 5-, and 10-mile
radii. While the Total Respiratory index for communities within one mile of these 38 facilities is 0.34
compared to the national average of 0.31) the risk for those closest to the facilities appears smaller than
for those at greater distances. The analysis shows that 3-mile, 5-mile, and 10-mile Total Respiratory Risk
averages are 0.34, 0.35, and 0.35 respectively.
7.5 Previous Violation and Enforcement Actions
Table 7-2 below provides summary data for facilities identified in the above analysis that are
currently registered with one or more EPA compliance regimes under major statutes including CAA,
RCRA, and the Clean Water Act (CWA). The table also provides a count of the number of facilities
identified within a Native American tribal boundary or located within Census block groups in the 80th or
higher national percentile of one of the primary EJ indexes of EJSCREEN, EPA's screening tool for EJ
concerns. These data were obtained from EPA's ECHO. Notably, of the 38 facilities included in the
above analysis, EPA identified 19 that are currently registered under CAA, RCRA, the National Pollutant
Discharge Elimination System (NPDES), and/or CWA compliance regimes.
Table 7-2: Number offacilities falling under one or more environmental compliance regime
( turn! of
1Vtriable
Ih'.scriplion of 1 uritiblc
Identified III (
liccluim
liicililics
AIR 1 I.AC
l';icilil\ li;is ;iii \ir 1 ;icilil\ S\Mcin ( \I'S) II)
-
NPDES FLAG
Facility has a Clean Water Act NPDES ID
5
SDWIS FLAG
Facility has a Safe Drinking Water Information System
(SDWIS) ID
0
74
-------
Facility has a Resource Conservation and Recovery Act
Trrfnrm^tirvn ^vctpm PR ATnfo^ TD
12
illiUlllldllUll oyolClll I xvV^IVrvllllU) llv
Facility has a Toxics Release Inventory (TRI) ID (most recent
„
reporting year)
-----
Facility has a Greenhouse Gas (E-GGRT) ID
0
„
FRS Tribal Code Flag - a Y/N flag indicating whether or not an
_FLG
associated EPA program reported the facility as being within a
Native American tribal boundary.
Determines if the facility is a designated as a major.
0
A Y/N flag indicating if any of the associated ICIS-Air, ICIS-
\| UT\ |h C 13 A ar A nonrntc o111 on QptiT/p ctotnc
18
"Wsc^enT^gIus"'
IN-rUJ-zO, xv^xv/\ UI olv W r\ JJCllllllb die 111 all aLllVC blalllb.
Indicates facilities located in Census block groups in the 80th or
„
higher national percentile of one of the primary environmental
justice (EJ) indexes of EJSCREEN, EPA's screening tool for EJ
concerns.
Source: EPA's Enforcement and Compliance History Online (ECHO). Note: While EPA places a high priority on ensuring the
integrity of the national enforcement and compliance databases, some incorrect data may be present due to the large amount of
information compiled across multiple streams of data from state, local, and tribal agencies. Known data quality problems are
discussed at https://echo.epa.gov/resources/echo-data/knowa-data-problems (EPA n.d.).
Table 7-3, Table 7-4, and Table 7-5 below provide further information on formal and informal
enforcement actions which have occurred at identified facilities within the last 5 years. Out of the
registered facilities, five are registered under CWA, 12 under RCRA, and seven under CAA. Two
facilities have recent CWA enforcement violations, as shown in Table 7-3. None of the identified
facilities have recent RCRA or CAA enforcement violations.
Table 7-3: Clean Water Act Compliance Status and Recent Enforcement History by Facility
liicilily Wiiiic
(ir,i
\ni)/:s
lic'fiislrulioii
( II .1 ( oinplitiiuv
ShllH.S
Inj or imil
liii/orccinciil
Aclions (Iti.sl 5
yciirs)
I 'orilHll llllj(H'L 'L'lHe'll/
Actions (Insi 5years)
RECLAIM PA N
DELAWARE AVE
FAC
Y
Failure to Report DMR -
Not Received
4
3
PERFECT SCORE
TOO, LTD
Y
No Violation Identified
REFRIGERANT
RECYCLING INC
Y
No Violation Identified
A-GAS US
Y
No Violation Identified
NATIONAL
REFRIGERANTS
INC
Y
Violation Identified
Source: EPA's Enforcement and Compliance History Online (ECHO). Note: While EPA places a high priority on ensuring the
integrity of the national enforcement and compliance databases, some incorrect data may be present due to the large amount of
information compiled across multiple streams of data from state, local, and tribal agencies. Known data quality problems are
discussed at https://echo.epa.gov/resources/echo-data/known-data-problems (EPA n.d.).
75
-------
Table 7-4: Resource Recovery and Conservation Act (RCRA) Compliance Status and Recent Enforcement
History by Facility
i'ucilily Same
Hi JiA Hcvistrutiou
li( II I ( Ompl'mtu c Status
CERTIFIED REFRIGERANT SI :RVICES INC
[NC
Y
___
___
___
___
___
___
___
___
___
___
___
No Violation Idcnliricd
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
No Violation Identified
Source: EPA's Enforcement and Compliance History Online (ECHO). Note: While EPA places a high priority on ensuring the
integrity of the national enforcement and compliance databases, some incorrect data may be present due to the large amount of
information compiled across multiple streams of data from state, local, and tribal agencies. Known data quality problems are
discussed at httos://echo.epa.gov/resources/echo-data/known-data-problems (EPA n.d.).
Table 7-5: Clean Air Act (CAA) Compliance Status and Recent Enforcement History by Facility
i'uciHty Same
( . l. l Air I'ucilily System (M S)
lic'fiislruliou
Y
(. l. l ( om/>lidiuv
Status
ADVANCED REFRIGERANT
TECHNOLOGIES, LLC
FABRICATOR
No Violation
Identified
Y
No Violation
Identified
Y
No Violation
Identified
Y
No Violation
Identified
Y
No Violation
Identified
Y
No Violation
Identified
Y
No Violation
Identified
Source: EPA's Enforcement and Compliance History Online (ECHO). Note: While EPA places a high priority on ensuring the
integrity of the national enforcement and compliance databases, some incorrect data may be present due to the large amount of
information compiled across multiple streams of data from state, local, and tribal agencies. Known data quality problems are
discussed at https://echo.epa.gov/resources/echo-data/known-data-problems (EPA n.d.)
7.6 Conclusion
The provisions in this final rule are expected to result in benefits in the form of reduced GHG
emissions. The analysis conducted for the rule also estimates that a portion of these benefits would be
incremental to emissions reductions that were anticipated under the Allocation and 2023 Technology
Transitions rules, thus further reducing the risks of climate change.
76
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While providing additional overall climate benefits, this rule may also result in changes in emissions
of air pollutants or other chemicals which are potential byproducts of HFC reclamation processes at
affected facilities. The market for reclaimed HFCs could drive changes in potential risk for communities
living near these facilities. However, the nature and location of the emission changes are uncertain.
Moreover, there is insufficient information at this time about which facilities will change reclamation
processes. The proximity analysis of these communities demonstrates that:
• Total baseline cancer risk and total respiratory risk from air toxics (not all of which stem
from HFC reclamation) is generally higher within 1-10 miles of an HFC reclamation facility;
• Generally, higher percentages of Black or African American individuals live near these
facilities;
• Higher percentages of individuals whose race is identified as "Other" live near these
facilities;
• Higher percentages of individuals of Hispanic ethnicity live near these facilities;
• It is not clear the extent to which these baseline risks are directly related to HFC reclamation;
and,
• continued analysis of HFC reclamation facilities and associated environmental justice
concerns is appropriate.
Given limited information at this time, it is unclear to what extent this rule will have disproportionate
adverse effects on communities living near HFC reclamation facilities.49 The Agency will continue to
evaluate the impacts of this final rulemaking on affected communities, including communities with
environmental justice concerns and consider further action, as appropriate, to protect health in
communities affected by HFC reclamation.
References
49 Statements made in this chapter on the environmental justice concerns of the AIM Act draw support from the following
citations: Banzhaf, Spencer, Lala Ma, and Christopher Timmins. 2019. Environmental justice: The economics of race, place, and
pollution. Journal of Public Economics; Hernandez-Cortes, D. and Meng, K.C., 2023. Do environmental markets cause
environmental injustice? Evidence from California's carbon market (No. w27205). NBER; Hu, L., Montzka, S.A., Miller, B.R.,
Andrews, A.E., Miller, J.B., Lehman, S.J., Sweeney, C., Miller, S.M., Thoning, K., Siso, C. and Atlas, E.L., 2016. Continued
emissions of carbon tetrachloride from the United States nearly two decades after its phaseout for dispersive uses. Proceedings of
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77
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Appendices:
Appendix A. Underlying Data and Assumptions used to Estimate
Costs and Benefits for Leak Repair and Inspection Provisions
The sections below describe the method and assumptions used to estimate aggregate incremental costs
and benefits associated with the Agency's final regulations related to leak repair and inspection.
Refrigerant-Containing Equipment Mapping
To develop the scope of appliances affected by the leak inspection and repair requirements of the final
rule, EPA utilizes the Vintaging Model. As explained in section 3.2, we divide each end-use within the
model into three (low, average, and high) to estimate a range of charge sizes across any single end-use
because the model only provides an average charge size. From that distribution, we determine appliance
types that are not affected by the leak repair and inspection provisions of the final rule (charge size less
than 15 pounds) and divide those that are affected into four groups: sub-small (15 to 50 pound charge
size); small (51 to 199 pound charge size); medium (200 to 1,999 pound charge size); and large (2,000
pounds or greater charge size). This mapping for CC, CR, and IPR end-uses is shown in Table A-l.
Table A-l: Apportionment of Appliance Types by Charge Size
Appliance
Sector
Appliance Type '''
( barge
Si~e (lbs)
Distributed
( lunge Si-e
< ironp
(barge
She
Analyzed
(lis)
Hqnipment
She
Low
5
N/A
School & Tour Bus AC
11
Average
11
N/A
High
16
Sub-small
Low
8
N/A
Transit Bus AC
16
Average
16
Sub-small
High
24
Sub-small
Low
20
Sub-small
Comfort
Passenger Train AC
41
Average
41
Sub-small
Cooling
High
61
Small
Low
752
Medium
CFC-11 Centrifugal Chillers
1,504
Average
1,504
Medium
High
2,255
Large
Low
783
Medium
CFC-12 Centrifugal Chillers
1,566
Average
1,566
Medium
High
2,439
Large
83
-------
Low
1,006
Medium
R-500 Chillers
2,012
Average
2,012
Large
High
3,018
Large
Low
695
Medium
CFC-114 Chillers
1,389
Average
1,389
Medium
High
2,084
Large
Low
331
Medium
Screw Chillers
661
Average
661
Medium
High
992
Medium
Low
265
Medium
Scroll Chillers
529
Average
529
Medium
High
794
Medium
Low
265
Medium
Reciprocating Chillers
529
Average
529
Medium
High
794
Medium
Low
3
N/A
Ice Makersc
6
Average
6
N/A
High
8
N/A
Low
8
N/A
Modern Rail Transport
17
Average
17
Sub-small
High
25
Sub-small
Low
17
Sub-small
Vintage Rail Transport
33
Average
33
Sub-small
High
50
Sub-small
Low
5
N/A
Road Transport
10
Average
10
N/A
High
15
N/A
Commercial
Refrigeration
Low
5
N/A
Intermodal Containersc
10
Average
10
N/A
High
15
N/A
Low
23
Sub-small
Condensing Unit
47
Average
47
Sub-small
High
70
Small
Low
827
Medium
Reefer Ships
1,653
Average
1,653
Medium
High
2,480
Large
Low
194
Small
Merchant Fishing Transport
388
Average
388
Medium
High
582
Medium
Low
1,019
Medium
CFC-12 Large Retail Food
2,038
Average
2,038
Large
High
3,057
Large
84
-------
Low
1,019
Medium
R-502 Large Retail Food
2,038
Average
2,038
Large
High
3,057
Large
Low
12,716
Large
CFC-12 Cold Storage
25,431
Average
25,431
Large
High
38,147
Large
Low
12,110
Large
HCFC-22 Cold Storage
24,220
Average
24,220
Large
High
36,331
Large
Low
12,306
Large
R-502 Cold Storage
24,613
Average
24,613
Large
High
36,919
Large
CFC-11 Industrial Process
Refrigeration
Low
972
Medium
1,945
Average
1,945
Medium
High
2,917
Large
Industrial
Process
CFC-12 Industrial Process
Refrigeration
Low
1,039
Medium
2,078
Average
2,078
Large
Refrigeration
High
3,117
Large
HCFC-22 Industrial Process
Refrigeration
Low
7,939
Large
15,877
Average
15,877
Large
High
23,816
Large
" Only end-uses within appliance sectors CC, CR, and IPR are shown.
b End-uses with charge sizes less than 10 pounds are not shown as even under the "high" charge size group, they will
not be affected by the leak inspection and repair provisions of the rule.
cRoad Transport and Intermodal Containers average charge sizes are less than 10 pounds but shown as rounded
values. Therefore, these appliance types along with Ice Makers are not affected by the leak repair or ALD provisions
but are affected by the reclaim provisions.
Cost assumptions
The rule provisions associated with leak repair and inspection are expected to result in:
• Incremental compliance costs associated with conducting leak detection/inspections and
repairs.
• Refrigerant savings associated with detecting and repairing leaks earlier.
Costs and savings were first estimated using a model equipment approach, and then were scaled up
industry-wide based on the total number of affected refrigerant-containing appliances using EPA's
Vintaging Model (EPA 2023f).
Leak Repair
85
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The final regulation results in incremental compliance costs to owners and operators when leaks in
appliances containing 15 or more pounds of refrigerant containing an HFC or a substitute for an HFC that
has a GWP above 53 exceed the threshold leak rate. Owners and operators must repair leaks within 30
days, or, under certain circumstances, request an extension to conduct the repair. If leaks cannot be
repaired, the appliance must be retrofitted or retired. These requirements are incremental for owners and
operators of appliances containing 15 or more pounds of such refrigerant that exceeds the leak rate of 10
percent for CC, 20 percent for CR, or 30 percent for IPR equipment. When leaks are repaired, all
appliances must also conduct initial and follow-up verification tests.
Leak repair outcomes. Extending leak rate thresholds to these refrigerant-containing appliances
should result in leaks being identified and repaired sooner than previously assumed in the Allocation Rule
Reference Case previously evaluated by EPA. This analysis assumes that leaks will be detected and
repaired earlier across all CC, CR, and IPR appliances containing 15 pounds or more of HFC refrigerant.
Specifically, the analysis assumed that HFC appliances that experience a leak event requiring repair
realizes one of three outcomes:
• The standard repair outcome conservatively assumes that as a result of the leak rate threshold,
repairs are conducted six weeks earlier than they would have been conducted when waiting for
the system performance to noticeably change due to refrigerant loss. If the system is using ALD
monitoring, repairs are assumed to be conducted ten weeks earlier.
• Under the extension repair outcome, owners/operators request an extension for conducting the
repair. The analysis conservatively assumes that repairs are also conducted six weeks earlier as a
result of the leak repair requirements (or ten weeks earlier if the system is using ALD
monitoring). As mentioned above, the extension allows owners/operators additional time to repair
an appliance if components cannot be delivered within the necessary time.
• The retrofit outcome assumes that systems that require retrofitting are retrofitted 5 years earlier
than they would have been in the absence of the final regulations (i.e., five years were assumed to
be remaining before normal end-of-life).
Table A-2below shows the proportion of affected appliances assumed to experience each outcome.
Table A-2: Leak Repair Outcomes and Proportions
Outcome
II /'(Systems
Standard Repair
98%
Extension Re_pair
1%
Retrofit
1%
86
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Frequency of repair. Data reported under California's Refrigerant Management Program (RMP) was
reviewed to determine an appropriate assumption for the annual frequency of repair for refrigerant-
containing appliances that use ALD monitoring systems or are inspected annually or quarterly and are
leaking above the threshold annual leak rates in this final action. These data suggest that most appliances
with refrigerant charge sizes greater than 50 pounds are repaired once per year, with the exception of
larger (>500 pounds) cold storage systems, which are repaired about twice per year on average (CARB
2009).50 This analysis assumes that there would be a similar relationship between appliances that are
subject to this final rule (under subsection (h) of the AIM Act) as there is for the appliances subject to
California's RMP.
Repair effectiveness and baseline leak rates. For all equipment types and sizes, post-repair leak
rates reflect California Air Resources Board (CARB) (2009) estimates, which were based on EPA's
Vintaging Model and Intergovernmental Panel on Climate Change (IPCC)/Technology and Economic
Assessment Panel (TEAP) (2005) recommendations. The modeled leak rates represent an outcome in
which a post-repair leak rate of zero is not achieved. This assumption therefore may be more conservative
than what may be actually achieved once this rule is implemented (i.e., this may assume more post-repair
leakage than actually occurs). This is because the GWP-weighted amount of emissions prevented by a
given leak repair equals the number of weeks divided by 52 weeks per year, multiplied by the difference
of the leak rate pre-repair and the leak rate post-repair) multiplied by the charge size multiplied by the
GWP of the refrigerant leaking. A higher post-repair leak rate results in a lower change in leak rate, which
results in a lower estimate of emissions prevented. On the other hand, some owners and operators may
choose to repair the leak to the point where the leak rate does not trigger further leak repair, in which case
the assumed non-zero post-repair leak rate may be more reflective of actual industry behavior.
Table A-3below presents the final leak rate assumptions by equipment sector, type, and size for
refrigerant-containing appliances that are affected by the leak repair requirements (i.e., are expected to
leak above the leak rate thresholds).51 The percentage of each equipment type that is experiencing a
qualifying leak was presented earlier in section 3.2 of this document.
50 Cold storage systems that are repaired twice are assumed to follow a modified standard repair outcome. After the first leak is
repaired, the system is assumed to leak for six weeks (without ALD) or 10 weeks (with ALD) at the post-repair leak rate. At that
point, the system is assumed to experience a failure such that six weeks (without ALD) or 10 weeks (with ALD) after the original
repair the system has leaked a qualifying amount of refrigerant to require a second repair.
51 The average reference case annual leak rates shown in Table A-3 are based on actual leak rate data reported to the CARB
RMP. For sub-small equipment, the annual post-repair leak rates are based on the average Vintaging Model leak rate (if lower
than the leak rate threshold for the equipment type) or the quintile 1 or quintile 2 leak rate from the modeled leak rate
distributions (see Appendix B for more information).
87
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Table A-3: Leak Rate Assumptions by Equipment Sector, Type, and Size
Leak Rate
threshold
. \ppliance
Sector
liipupnient
Type
l^/iiipnient
She
liaseline Annual Leak Rate
(for lA{uipnient Requiring
Repair)
. 1 nnnal Rost-
repair Leak
Rate
10%
CC
School & Tour
Bus AC
Sub-small
13%
10%
Transit Bus
AC
Sub-small
14%
8%
Passenger
Train AC
Sub-small
10%
2%
Chiller
Medium
13%- 16%
2%
Large
14%- 16%
2%
20%
CR
Modern Rail
Transport
Sub-small
37%
19%
Vintage Rail
Transport
Sub-small
42%
15%
Condensing
Unit
Sub-small
22%
15%
Marine
Transport
Small
37%
10%
Medium
29% - 37%
10%
Large
29%
10%
Rack
Medium
27%
10%
Large
27%
10%
Cold Storage
Large
30% - 34%
10%
30%
IPR
IPR
Medium
43%-45%
7%
Large
43%-45%
7%
Source: EPA (2023f)
Leak Inspection
The final rule would result in incremental compliance costs to appliance owners and operators who
would need to conduct leak inspections when leaks are identified that exceed the annual threshold leak
rate (i.e., 10% for CC, 20% for CR, or 30% for IPR). For CR and IPR appliances with refrigerant charge
sizes between 15 and 500 pounds and for CC and other appliances with charge sizes at or above 15
pounds, leak inspections are annual, and for CR and IPR appliances with refrigerant charge sizes between
500 and 1,500 pounds, leak inspections are quarterly. As a baseline, the cost analysis conservatively
assumes that annual leak inspections are not currently performed. This assumption may overestimate
compliance costs since some owners and operators have indicated they conduct regular leak inspections to
ensure that systems continue to function properly, to avoid recurring refrigerant top-off costs, or they are
required to do so based on state regulations. Although the cost analysis assumes no annual leak
inspections in the baseline, when estimating baseline emissions, the real-world prevalence of ALD in each
subsector is empirically captured in the average leak rates in the Vintaging Model (i.e., unlike costs,
emissions are not conservatively estimated, nor are they overestimated due to this assumption). For CR
and IPR appliances with refrigerant charge sizes above 1,500 pounds, ALD monitoring is required, so no
88
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additional inspections are assumed for these appliances. The incorporation of ALD in the model partially
ameliorates the overestimation of costs for leak inspection but does not account for all overestimation due
to current leak inspection practices.
Unit Cost and Savings Assumptions
Leak inspection. Leak inspections were assumed to require, on average, four hours per system per
inspection for CR and IPR appliances, and two hours for CC appliances.
An hourly labor rate of $58.02 was assumed for leak repair and inspection, based on the mean hourly
wage of $27.63 for the Heating, Air-conditioning, and Refrigeration Mechanics and Installers
occupational group (49-9021) from the Bureau of Labor Statistics (BLS 2022), plus 110 percent to
account for overhead ($30.39).
ALD systems. Direct and indirect ALD system costs include the capital expenditure to purchase the
hardware (e.g., detector, sensors), plus installation costs and operations and maintenance (O&M) costs
associated with annual system maintenance, certification, and data tracking/storage. These costs are
assumed to vary by system size (e.g., number of zones and sensors) and are summarized in Table A-4,
with direct ALD systems requiring higher material and installation costs than indirect systems because a
separate monitoring device and zone sensors are required (see supplemental analysis 52 titled
Supplemental Information on Automatic Leak Detection Systems for more information). For the purposes
of this analysis, 50 percent of refrigerant-containing appliance owners were assumed to install direct ALD
systems and 50 percent of refrigerant-containing appliance owners are assumed to install indirect ALD
systems, which offer additional monitoring capabilities that automatically provide certain reporting and
recordkeeping requirements. For new CR and IPR refrigerant-containing appliances containing 1,500
pounds or more of refrigerant and installed on or after January 1, 2026, owners or operators are required
to purchase and install an ALD system upon installation or within 30 days of installation. By January 1,
2027 owners or operators with existing CR and IPR appliances containing 1,5000 pounds of refrigerant or
more that were installed on or after January 1, 2017, and before January 1, 2026, and before January 1,
2026, are required to purchase and install an ALD system. This analysis assumes 10-21 percent of
existing and new CR and IPR appliances would already have regularly calibrated ALD systems
installed53, which is assumed to last the full lifetime of the equipment. In subsequent years, new
52 Abt 2024. Available in the docket (EPA-HQ-OAR-2022-0606) for this rulemaking at https://www.regulations.gov.
53 This assumes that 10 percent of CR and IPR equipment under 1,500 pounds would have ALD already installed or would be
expected to install ALD in the absence of this rulemaking, 16 percent of appliances 1,500-2,000 pounds, and that 21 percent of
CR and IPR equipment have ALD as required in California (based on population of California relative to the United States) for
appliances greater than 2,000 lb. For more details on these assumptions, see section 3.2.
89
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refrigerant-containing appliances entering the market would also experience costs to purchase and install
an ALD system. The upfront costs to purchase and install a direct ALD system were annualized over a 5-
year period using a rate of 9.8 percent,54 whereas indirect ALD system owners are not assumed to finance
the material and installation costs. Owners and operators were also assumed to experience annual O&M
costs throughout the life of the ALD system (Abt, 2024).
Table A-4: Unit Cost Assumptions for ALD Systems
Annualized
System Size
Material
C ost
l.abor
Honrs
Installation
( ost
Equipment and
Installation ( ost
Equipment and
Installation ( ost
( Vcars 1-5)
Animal
OX M ( ost
Direct ALD System
1,500-2,000
$9,000
16
$928
$9,928
$2,606
$1,250
2,000+
$9,850
20
$1,160
$11,010
$2,890
$1,440
Indirect ALD System
1,500-2,000
$2,850
8
$464
$3,314
NA
$950
2,000+
$2,650
10
$580
$3,230
NA
$1,000
Source: (Abt, 2024)
Leak repair. Repair costs are calculated as the base cost of making the repair or retrofit, including
labor, parts, refrigerant recovery, and verification tests.55 These costs are assumed to vary by system size,
where leak repairs on a sub-small or small refrigerant-containing appliances are assumed to be relatively
simpler and less costly than repairs on medium and large refrigerant-containing appliances. The base
costs associated with each outcome were estimated as described below.
• Standard repair. Leak repair costs for a "standard repair" are based on assumptions in CARB
(2009). CARB surveyed RACHP service contractors and technicians to validate these cost
assumptions. Although the CARB estimates did not cover appliances with charge sizes less than
50 pounds, repair costs for these smaller appliances were extrapolated from the CARB estimates.
• Extension repair. An "extension repair" is assumed to involve the repair of a major component
such as a compressor and is based on costs presented in Stratus (2009).56
54 Businesses are expected to treat ALD systems as capital assets and therefore it is assumed that businesses would be able to
access financing for their purchase, if desired, for a loan tenure of five years. The discount rate used in this analysis is consistent
with the RIA to the Allocation Framework Rule, which identified a weighted average cost of capital in this sector of 9.8 percent
(EPA 2023a).
55 Industry input suggested that verification tests are already conducted as standard practice during servicing events. Moreover,
because initial and follow-up verification tests can both be conducted during the same service appointment, this requirement is
not expected to result in additional servicing events. Time required to conduct the verification tests is included in the estimated
time to conduct the repair.
56 Stratus (2009) obtained estimates of retail prices for typical replacement compressors from a supplier (ThermaCom Ltd.).
90
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• Retrofit. Retrofit costs were also based on Stratus (2009); this analysis assumed that the cost to
retrofit an entire appliance was between two to three times the cost of the compressor or major
component.
As noted above, lower leak rate thresholds will result in leaks being repaired sooner than under the
current approach. The analysis assumes that repairs are conducted six or ten weeks earlier as a result of
these requirements. Thus, the repair costs attributable to the rule are based on the time cost of conducting
those repairs six or ten weeks earlier. The interest cost (at 7 percent, 3 percent, and 2 percent per year) of
the base repair cost is attributed to the rule; this cost is referred to below as the "effective cost of repair."57
An "effective cost" approach was also taken for the cost of retrofitting. Refrigerant-containing
appliances that are retrofitted as a result of the regulation are assumed to be retrofitted five years earlier
than they would have been under current practices. Thus, the effective cost of retrofitting attributable to
the rule is the cost of borrowing the funds for retrofitting for five years at 7 percent, 3 percent, or 2
percent per year.
Table ,4 o be low presents the base and effective cost assumptions by repair, appliance charge size, and
whether the appliance is using ALD. For retrofit outcomes, the base costs presented do not include the
additional cost of replacing the entire refrigerant charge with virgin refrigerant. These costs can be sizable
considering, for instance, charge sizes can exceed 10,000 pounds in some systems. For the standard and
extension repair outcomes, the cost of refrigerant recharge is not included since it is assumed that the
owner or operator would have topped off the system in the absence of the regulatory requirements.
Table A-5: Unit Cost Assumptions for Leak Repairab,c
Appliance
Si:e
Tola
I
I.ab
Purls
Re/ri^eran
1 Recovery
lot til liase
( osl J or
Labor, Parts,
l:J/eclive ( osl of liurly
Repair ¦ Relro/il
(without ll.D)
li/Jcclive ( osl oj liarly
Repair / Retrofit
(with M.D)
or
J Ion
rs
and Recovery
-w
o
Discount
Rate
.> O
Hi scon
nl Hale
_ O
Discou
n! Hate
O
Discou
nt Rale
O
Discou
nt Rale
HI
_ o
Disco
mil
Rale
Standard Repair
Sub-small,
Small
8
$135
$269
$868
$7.6
$3.3
$2.2
-
-
-
Medium
12
$404
$471
$1,572
$13.8
$5.9
$3.9
$22.9
&
Vo
bo
$6.5
Large
16
$808
$876
$2,612
$22.9
&
VO
bo
$6.5
$38.1
$32.7
10.9
Extension Repair
Sub-small,
Small
20.2
5
$3,501
$269
$4,945
$43.3
$18.5
$12.4
-
-
-
Medium
20.2
5
$12,76
8
$471
$14,415
$126
$54.1
$36.0
$210
$90.1
$60.1
57 CARB used a similar approach—i.e., estimating the effective cost of repair—in developing its economic impact estimates for
its High-Global Warming Potential Stationary Source Refrigerant Management Program (CARB 2009).
91
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Large
20.2
5
$12,76
8
$876
$14,819
$130
$55.6
$37.0
$216
$92.6
$61.7
Retrofit0
Sub-small,
Small
20.2
5
$10,29
7
$269
$11,741
$2,616-
$2,774
$1,278-
$1,355
$881-
$935
-
-
-
Medium
20.2
5
$27,45
9
$471
$29,105
$6,684-
$7,837
$3,266-
$3,829
$2,252-
$2,641
$7,915-
$8,173
$3,867
$3,993
$2,667
$2,754
Large
20.2
5
$27,45
9
$876
$29,509
$8,322-
$9,214
$4,066-
$4,502
$2,804-
$3,104
$8,345-
$40,352
$4,077
$19,71
5
$2,812
$13,59
6
Source: for Standard Repair Labor Hours, Parts, and Recovery Costs: CARB (2009); for Extension Repair and
Retrofit: Stratus (2009).
a Assumptions for small appliances were proxied for sub-small equipment containing between 15 and 50 49 pounds
of refrigerant.
b Total base cost is calculated by multiplying the total labor hours by the labor rate ($58.02) and adding the
additional costs associated with parts and refrigerant recovery.
0 Effective costs for repair and retrofit of appliances varies based on the charge size of the appliance replaced.
Refrigerant savings. By causing leaks to be repaired earlier, the regulations would result in
refrigerant cost savings for system operators. Refrigerant cost savings are calculated based on the
difference between the baseline and post-repair leak rates, multiplied by the charge size, over the six
weeks earlier that each repair was conducted (or ten weeks earlier for appliances using an ALD system).
An average price of $4 per pound was assumed for all refrigerants, based on the average price of HFC-
134a, R-404A, R-407A and R-507 assumed in the RIA for Phasing Down Production and Consumption
of HFCs (EPA 2021).
On a per system basis, effective refrigerant savings range from $0.20 for sub-small school bus AC up
to $4,699 for large IPR systems.
Leak repair expected costs and savings. Expected costs and burden reductions per model appliance
were estimated on a weighted basis, taking into account the proportion of appliances assumed to reach
each leak repair outcome and the unit costs and savings associated with each outcome. Expected costs and
savings were estimated in the Vintaging Model in a disaggregated manner, distinguishing between
appliance sectors, types, sizes, and refrigerant type (EPA 2023f).
Abatement assumptions
Annual Benefits of Leak Repair and Inspection
Similar to the methodology for estimating costs and savings, benefits were estimated using a model
equipment approach. For equipment with 15 or more pounds of refrigerant containing an HFC or a
92
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substitute for an HFC that has a GWP above 53, benefits were scaled up industry-wide based on the total
number of affected equipment using EPA's Vintaging Model and the approach outlined in Section 3.2.
Benefits are calculated as the refrigerant emissions prevented by repairing or retrofitting a leaking
system earlier than would have been done if waiting for the system performance to decline. EPA
estimates this to be on average six weeks (or ten weeks if systems are using ALD monitoring). Avoided
refrigerant emissions are calculated based on the difference between the baseline and post-repair leak
rates (shown in Table A-3above), multiplied by the charge size, over the six weeks or ten weeks earlier
that each repair was conducted. The amount of avoided refrigerant emissions is weighted by an average
GWP. For all equipment types, weighted-average GWPs are based on average charge sizes, refrigerant
type, and stock of affected equipment modeled in the Vintaging Model (EPA 2023f).
Table A-6: Average 2026 GWP Assumptions by Equipment Type, Size, and Refrigerant Type
Sector
IJi/iiipmcnt lype
lu/nipnicnt Size
II eighted-. I ventre (ill P
School & Tour Bus AC
Sub-Small
1,430
CC
Transit Bus AC
Sub-small
1,430
Passenger Train AC
Sub-small
1,602
Chiller
Medium
1,279 - 1,794
Large
1,279- 1,388
Modern Rail Transport
Sub-small
2,676
Vintage Rail Transport
Sub-small
1,430
Condensing Unit
Sub-small
3,937
Small
3,482
Marine Transport
Medium
2,708 - 3,482
Large
2,708
Rack
Medium
2,701
Large
2,701
CR
Cold Storage
Large
3,937
IPR
IPR
Medium
Large
1,400 - 1,663
L400 - 3,157
Source: EPA (2023f)
The benefits for the extension repair are assumed to be equivalent to the benefits of a standard repair.
This analysis does not take into account the additional 30 days (or longer) that the system is leaking
between filing the extension and when the actual repair takes place, which could result in overestimating
the avoided emissions as a result of the extension request. However, because refrigerant-containing
appliances requiring an extension repair have typically more complicated or catastrophic leaks, an
extension repair as a result of the regulations would still be taking place earlier than it would under the
baseline scenario, and emissions would still be avoided.
Although emission benefits associated with retrofit are anticipated, none are calculated in this
analysis. The benefits associated with retrofit fall outside of the one-year timeframe of this analysis (i.e.,
93
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end users have 30 days to make the initial repair, 30 days to prepare and submit a retrofit plan, and then a
full year to complete the retrofit and repair all additional leaks), and thus are not included. Furthermore,
because this analysis only considers a one-year period, it does not include benefits from preventing a
chronically leaking appliance from continued operation over a longer time period than one year.
On a per appliance basis, effective benefits range from 0.03 metric tons of carbon dioxide (CO2)
equivalent (MTCC^eq) for sub-small school bus AC systems up to 2,503 MTCC^eq for very large cold
storage refrigeration systems (EPA 2023f).
Model Equipment Expected Benefits.
Expected benefits per model equipment were estimated on a weighted basis, taking into account the
proportion of appliances assumed to reach each leak repair outcome and the avoided refrigerant emissions
associated with each outcome. Expected benefits were estimated in the model in a disaggregated manner,
distinguishing between equipment sectors, types, sizes, and refrigerant type. The expected avoided
refrigerant emissions per model equipment type (as described above) were multiplied by the number of
each type of equipment assumed to experience leaks above the rule's threshold leak rates (see section
3.2). This yields aggregate benefits for the United States as a whole as shown in Table A-7below (EPA
2023f).
Table A-7: Expected Emissions Reductions in 2026 by Equipment Type and Size
Sector
lu/tiipiiicur Type
Hi/iiipmenr Si~e
(HKi Emissions. 1 voided (M I C
School & Tour Bus AC
Sub-small
3,100
Transit Bus AC
Sub-small
1,900
CC
Passenger Train AC
Sub-small
1,100
Chiller
Medium
724,200
Large
27,500
Modern Rail Transport
Sub-small
1,400
Vintage Rail Transport
Sub-small
1,900
Condensing Unit
Sub-small
77,800
Small
75,700
CR
Marine Transport
Medium
386,300
Large
8,300
Rack
Medium
876,000
Large
913,400
Cold Storage
Large
163,700
IPR
IPR
Medium
59,500
Large
2,065,800
Future Annual Benefits of Leak Repair and Inspection
The analysis described above estimates one-year benefits based on the current distribution of HFC
appliances in use. However, because the use of HFCs will change over the next decade due to the phase-
94
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down of HFCs in accordance with the AIM Act 2024 Allocation Rule, benefits for the requirements of
this rule will also change. Future benefits were estimated using a model equipment, facility, and entity
approach. Benefits were then scaled up industry-wide based on the total number of affected appliances
anticipated in 2030, 2040, and 2050.
Several assumptions were made to simplify the process of determining the number of affected
appliances and the benefits of leak repair in 2030, 2040, and 2050:
• Appliances used in later years are assumed to have the same leak rates and refrigerant charge
sizes as those in the 2026 baseline scenario.
• The same proportion of standard repairs, extension repairs, and retrofits are assumed for all years.
• The affected HFC appliances in 2026 are assumed to grow according to the growth rate, lifetime,
and transitions in EPA's Vintaging Model—with the adjustments described below.
The growth in stock of HFC appliances was adjusted to account for the Allocation Framework rule,
the 2024 Allocation Rule RIA addendum, and the 2023 Technology Transitions RIA addendum. Benefits
from the transition away from HFCs were quantified and recently presented in the RIA addendum for the
EPA final rulemaking, Regulatory Impact Analysis Addendum: Impact of the Technology Transitions
Rule (EPA 2023b). To avoid double-counting benefits, this analysis assumes that HFC CR, CC, and IPR
appliances begin transitioning away from HFCs in accordance with the transition scenario presented in
the 2023 Technology Transitions RIA Addendum.58
Appliance-specific average GWP values were also updated to reflect the specific mix of HFC
refrigerants assumed in 2030, 2040, and 2050, as shown in Table A-8. GWP values in 2030, 2040, and
2050 include HFCs and substitutes such as HFOs and HCFOs, but did not include other substitutes such
as CO2, ammonia, or hydrocarbons.59 Affected equipment modeled in EPA's Vintaging Model, which
was the basis for the RIA analysis for the AIM Allocation Framework Rule and the RIA Addendum for
the 2024 Allocation Rule, were distributed into three size categories (as discussed in section 3.2) and
therefore all size categories for some equipment types have the same weighted-average GWP.
Table A-8: Average GWP Assumptions by Equipment Type, Size, and Refrigerant Type for 2030, 2040,
and 2050
Sector
l:A\ui\nuciU
Type
liiiuipmcnl Size
Hek
hled-Avcravc (M l*
20.10
20-10
2050
58 Different types of appliances are assumed to transition in different years as presented in the 2023 Technology Transitions Rule
RIA Addendum (EPA 2023b).
59 Given the GWPs of HFOs, HCFOs, CO2, ammonia, and hydrocarbons are very low compared to regulated HFCs, the is not
expected to affect the weighted-average GWP significantly.
95
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School & Tour
Bus AC
Sub-small
1,430
1,430
1,430
Transit Bus
AC
Sub-small
1,430
1,430
1,430
cc
Passenger
Train AC
Sub-small
1,602
1,602
1,602
Unitary AC
Sub-small
1,717
836
730
Chiller
Medium
1,122- 1,832
716-1,887
0-698
Large
1,122-1,182
716-896
618-625
Modem Rail
Transport
Sub-small
2,676
2,676
2,676
Vintage Rail
Transport
Sub-small
1,430
-
-
CR
Condensing
Unit
Sub-small
3,937
3,937
-
Small
3,274
2,817
2,431
Marine
Medium
Transport
Large
2,554 - 3,274
2,242-2,817
1,957-
2,431
Rack
Medium
2,554
2,242
1,957
Large
2,510
2,417
-
Cold Storage
Large
2510
2417
-
IPR
IPR
Medium
3,937
3,937
-
Large
1,340- 1,639
1,078 - 1,442
485-517
Benefits on a per-appliance basis were then calculated in the same manner outlined in above and were
multiplied by the estimated affected appliances in 2030, 2040, and 2050 described above as shown in
Table A-9.
Table A-9: Expected Emissions Reductions by Equipment Type, Size, and Refrigerant Type for 2030,
2040, and 2050
See! iii-
lupiipnicnl Type
liipiipmenl Size
M IX <)2eu
2ojo
20-10
2050
LL
School l our LUii AC
Sub-small
\ MH)
^ SOI)
4,100
Transit Bus AC
Sub-small
2,000
2,300
2,500
Passenger Train AC
Sub-small
1,200
1,300
1,400
Chiller
Medium
678,200
324,200
197,700
Large
25,200
19,500
14,700
CR
Modern Rail Transport
Sub-small
1,500
1,600
1,700
Vintage Rail Transport
Sub-small
800
-
-
Condensing Unit
Sub-small
64,700
19,900
-
Marine Transport
Small
86,900
95,200
92,700
Medium
445,500
488,800
476,100
Large
12,400
14,900
14,600
Rack
Medium
752,200
174,000
-
Large
840,300
200,800
-
Cold Storage
Large
197,900
82,700
-
IPR
IPR
Medium
52,200
26,800
3,500
Large
2,463,100
1,559,000
111,100
Note: By 2040, there are no longer any HFC refrigerants assumed in vintage rail transport systems. By 2050,
there are no longer any HFC refrigerants assumed in condensing units, cold storage, and rack systems.
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Appendix B. Vintaging Model Leak Rate Distributions
The Vintaging Model simulates equipment emissions and consumption using average leak rates,
consistent with 2006IPCC Guidelines for National Greenhouse Gas Inventories (IPCC 2006). These
average leak rates represent the full spectrum of potential equipment leak events, in which equipment may
experience negligible or more significant and/or catastrophic leaks. In order to simulate a more real-world
distribution of leak rates, equipment stock was distributed into quintiles, each containing 20 percent of
units, where the leak rate distributions equal the weighted average leak rate modeled in the Vintaging
Model for each equipment type. The representative leak rate for each quintile was estimated such that
each subsector has at least 20 percent of its stock (i.e., one quintile) above the threshold leak rate.
Table B-l summarizes the leak rate distributions for equipment containing 15 or more pounds of
refrigerant considered in the analysis.
For most subsectors, the quintiles were established in increments of 25% percent above or below the
average leak rate (i.e., quintile 1 is 50 percent below, quintile 2 is 25 percent below, quintile 3 is the
average, quintile 4 is 25 percent above, and quintile 5 is 50 percent above). However, for some
subsectors, the average leak rate modeled in the Vintaging Model was significantly below the threshold
leak rate, such that the upper quintile leak rate did not exceed the threshold leak rate. In those cases, the
fifth quintile leak rate was set to be significantly higher than the average leak rate to ensure that each
subsector had some portion of equipment stock above the leak rate threshold and therefore was affected
by the final rulemaking. In those cases, the quintile 1 through 4 values were also manipulated such that
the weighted average leak rate across all five quintiles still equaled the average leak rate (i.e., quintile
3).60
Table B-l: Leak Rate Distributions for Refrigerant-Containing Appliances
Sector
Hquipmenl
Type
1 'inlux'mx Model Subsector '
< hiinlile
.¦ 1 venire
/.eiih Mule
1
.?
-1
5
Subsectors willi chsirgc si/cs "iv.iU'r 1 h;in 15 pounds
CC
Passenger
Train AC
Passenger Train
AC
% Relative to
Average
0.88
1.1
1.4
1.6
495
2.1
Assumed
Leak Rate
(%)
0.018
0.023
0.029
0.034
10b
60 Because the average Vintaging Model leak rate for certain subsectors (e.g., chillers, IPR) are significantly lower than the
threshold leak rates of 10% for comfort cooling and 30% for IPR, it is not possible for the weighted average leak rate across the
quintiles to equal the average leak rate using the percentages above.
97
-------
% Relative to
50
75
100
125
150
School &
School & Tour
Bus AC0
Average
cc
Tour Bus
Assumed
10
AC
Leak Rate
(%)
4.8
7.2
10
12
14
Rail
Transport
Vintage Rail
Transport
% Relative to
Average
25
50
100
150
175
CR
Assumed
Leak Rate
(%)
15
24
36
48
57
36
HCFC-22 Large
% Relative to
Average
50
75
100
125
150
Condensing
Unit
Condensing
Units (Medium
Retail Food)
CR
Assumed
Leak Rate
(%)
6.5
11
15
19
23
15
Transit Bus
AC
% Relative to
Average
50
75
100
125
150
CC
Transit Bus AC
Assumed
10
Leak Rate
(%)
5
7.5
10
12
15
Rail
Modern Rail
% Relative to
Average
50
75
100
125
150
CR
Assumed
Leak Rate
(%)
33
Transport
Transport
17
25
33
41
50
% Relative to
0
0
0
0
850
CFC-11
Average
CC
Chiller
Centrifugal
Assumed
3.2
Chillers'1
Leak Rate
(%)
0
0
0
0
16
% Relative to
0
0
0
0
700
CFC-12
Average
CC
Chiller
Centrifugal
Assumed
2.8
Chillers'1
Leak Rate
(%)
0
0
0
0
14
% Relative to
0
0
0
0
700
Average
CC
Chiller
R-500 Chillers'1
Assumed
2.8
Leak Rate
(%)
0
0
0
0
14
% Relative to
0
0
0
0
750
CFC-114
Chillers'1
Average
CC
Chiller
Assumed
3.0
Leak Rate
(%)
0
0
0
0
15
% Relative to
0
0
0
0
1300
Average
CC
Chiller
Screw Chillers'1
Assumed
2.6
Leak Rate
0
0
0
0
13
(%)
% Relative to
0
0
0
0
1300
Average
CC
Chiller
Scroll Chillers'1
Assumed
2.6
Leak Rate
0
0
0
0
13
(%)
98
-------
Reciprocating
Chillers'1
% Relative to
Average
0
0
0
0
850
cc
Chiller
Assumed
Leak Rate
(%)
0
0
0
0
13
2.6
CFC-11
Industrial
Process
Refrigeration"1
% Relative to
Average
0
0
0
0
850
IPR
IPR
Assumed
Leak Rate
(%)
0
0
0
0
43
8.5
CFC-12
Industrial
Process
Refrigeration"1
% Relative to
Average
0
0
0
0
1250
IPR
IPR
Assumed
Leak Rate
(%)
0
0
0
0
45
9.0
HCFC-22
Industrial
Process
Refrigeration
% Relative to
Average
0
0
0
0
500
IPR
IPR
Assumed
Leak Rate
(%)
0
0
0
0
43
8.6
CFC-12 Cold
Storage
% Relative to
Average
0
50
75
100
275
CR
Cold Storage
Assumed
Leak Rate
(%)
0
6.1
9.2
12
34
12
HCFC-22 Cold
Storage
% Relative to
Average
0
50
75
100
275
CR
Cold Storage
Assumed
Leak Rate
(%)
0
5.5
8.3
11
30
11
CR
Cold Storage
R-502 Cold
Storage
Assumed
Leak Rate
(%)
0
50
75
100
275
11
% Relative to
Average
0
5.6
8.4
11
31
CR
Rack
CFC-12 Large
Retail Food
Assumed
Leak Rate
(%)
50
75
100
125
150
22
% Relative to
Average
11
16
22
27
32
CR
Rack
R-502 Large
Assumed
Leak Rate
(%)
50
75
100
125
150
22
Retail Food
Assumed
Leak Rate
(%)
11
16
22
27
32
Marine
Transport
Merchant
% Relative to
Average
50
75
100
125
150
CR
Fishing
Transport
Assumed
Leak Rate
(%)
17
25
33
41
50
33
CR
Marine
Transport
Reefer Ships
% Relative to
Average
50
75
100
125
150
23
99
-------
Assumed
Leak Rate
(%)
12
17
23
29
35
Note: Values may not sum due to independent rounding
a Vintaging Model subsectors are often defined by the ODS that was original used, as that affects the transition
choices. This analysis does not consider the effects the final rule may have on ODS emissions.
bThe assumed leak rate percentages for this equipment type quintile exceeds the 10 percent threshold rate for
comfort cooling systems, but is shown as equal to 10 percent due to rounding.
0 33 percent of units in the School & Tour Bus AC sector are modeled with a charge size above 15 lbs.
d The average leak rate modeled does not equal the average leak rate for these subsectors in the Vintaging Model.
Althought the leak inspection and repair provisions only apply to refrigerant-containing
appliances with a charge size of 15 pounds or greater, the requirement to use reclaimed refrierant
applies to a few subsectors that have smaller charge sizes. The leak rate distribution for these
subsectors are shown in Table B-2.
Table B-2: Leak Rate Distributions for Additional Refrigerant-Containing Appliances
See! or
liquipmeiU type
1 "mlux'mx ModelSiibseclor
< hiinlile
.1 venire
Leak Utile
I
1
.i
7
5
s less ill mi 1S pound*
IPR
Ice Makers
Ice Makers3
% Relative to
Average
15
30
45
60
350
3.0
Assumed Leak
Rate (%)
0.4
5
0.9
0
1.4
1.8
11
CR
Road Transport
Road Transport
% Relative to
Average
50
75
100
125
150
33
Assumed Leak
Rate (%)
17
25
33
41
50
CR
Intermodal
Containers
Intermodal
Containers
% Relative to
Average
50
75
100
125
150
21
Assumed Leak
Rate (%)
10
16
21
26
31
a The average leak rate modeled does not equal the average leak rate for these subsectors in the Vintaging Model.
100
-------
Appendix C. Detailed Costs by Equipment - Leak Repair and Inspection
Table C-l: Total Annual Refrigerant Savings in 2030 (2022$) and Combined Annual Cost and Annual Savings with 7% and 3%
Discount Rate by Equipment Type
~"n Discount Utile
3"n Discount Utile
2"n Discount Utile
Sector
lA\ui\imciU type
.III IIHtll
lie/ri^erunl
Savings
Incremental
( oini'litince
( o.sf.s
( ombinetl
A nun til Savings
mill ('ompliniicc
( osl.s
Incrcmenltil
( om/i/iimce
( o.sl.s
('umbilici/
.(nun til
Savings mill
( oinpliuiuv
( o\l\
Incrcmcnliil
( omi'limicc
( o.sls
( (unbilled
.1 nun til
Savings mnl
('ompliunce
( o.sl.s
2030
2030
2030
2030
2030
2030
2030
Leak Repair
-$20,873,100
St 9,963,000
-$910,100
$9,509,100
-SI 1,364,000
$6,517,600
-SI4355500
School & Tour
Bus AC
Sub-Small
-$20,700
$2,400,800
$2,380,100
$1,139,800
$1,119,100
$780,600
$759,900
CC
Transit Bus AC
Sub-Small
-$12,400
$850,500
$838,100
$403,800
$391,400
$276,500
$264,100
Train AC
Sub-Small
-$6,500
$132,700
$126,200
$63,000
$56,500
$43,200
$36,700
Chiller
Medium
-$4,100,500
$7,985,200
$3,884,700
$3,817,700
-$282,800
$2,619,000
-$1,481,500
Chiller
Large
-$192,000
$140,900
-$51,100
$67,000
-$125,000
$45,900
-$146,100
Modern Rail
Transport3
Sub-Small
-$5,400
$108,000
$102,600
$51,300
$45,900
$35,100
$29,700
Condensing
Unit
Sub-Small
-$146,400
$2,903,400
$2,757,000
$1,378,700
$1,232,300
$944,300
$797,900
Vintage Rail
Transport3
Sub-Small
-$5,600
$40,300
$34,700
$19,200
$13,600
$13,100
$7,500
Rack3
Medium
-$2,936,100
$1,648,800
-$1,287,300
$782,300
-$2,153,800
$535,700
-$2,400,400
CR
Rack3
Large
-$3,280,300
$1,023,800
-$2,256,500
$483,900
-$2,796,400
$331,000
-$2,949,300
Marine
Transport3
Small
-$260,200
$318,800
$58,600
$151,500
-$108,700
$103,800
-$156,400
Marine
Transport3
Medium
-$1,342,500
$1,518,300
$175,800
$725,900
-$616,600
$498,000
-$844,500
Marine
Transport3
Large
-$47,600
$15,300
-$32,300
$7,200
-$40,400
$4,900
-$42,700
Cold Storage
Large
-$233,500
$39,500
-$194,000
$18,800
-$214,700
$12,900
-$220,600
IPR
IPR
Medium
-$284,900
$127,300
-$157,600
$60,900
-$224,000
$41,800
-$243,100
IPR
Large
-$7,998,500
$709,400
-$7,289,100
$338,100
-$7,660,400
$231,800
-$7,766,700
-------
Leak Inspection
$0
S73,942,500
$73,942,500
S73,942,500
S73,942,500
S73,942,500
$73,942,500
School & Tour
Bus AC
Sub-Small
$0
$8,195,200
$8,195,200
$8,195,200
$8,195,200
$8,195,200
$8,195,200
CC
Transit Bus AC
Sub-Small
$0
$2,903,400
$2,903,400
$2,903,400
$2,903,400
$2,903,400
$2,903,400
Train AC
Sub-Small
$0
$450,200
$450,200
$450,200
$450,200
$450,200
$450,200
Chiller
Medium
$0
$10,755,700
$10,755,700
$10,755,700
$10,755,700
$10,755,700
$10,755,700
Chiller
Large
$0
$147,900
$147,900
$147,900
$147,900
$147,900
$147,900
Modern Rail
Transport3
Sub-Small
$0
$736,900
$736,900
$736,900
$736,900
$736,900
$736,900
Condensing
Unit
Sub-Small
$0
$19,665,500
$19,665,500
$19,665,500
$19,665,500
$19,665,500
$19,665,500
Vintage Rail
Transport3
Sub-Small
$0
$273,900
$273,900
$273,900
$273,900
$273,900
$273,900
Rack3
Medium
$0
$10,881,300
$10,881,300
$10,881,300
$10,881,300
$10,881,300
$10,881,300
CR
Rack3
Large
$0
$3,545,700
$3,545,700
$3,545,700
$3,545,700
$3,545,700
$3,545,700
Marine
Transport3
Small
$0
$2,069,900
$2,069,900
$2,069,900
$2,069,900
$2,069,900
$2,069,900
Marine
Transport3
Medium
$0
$10,520,000
$10,520,000
$10,520,000
$10,520,000
$10,520,000
$10,520,000
Marine
Transport3
Large
$0
$50,500
$50,500
$50,500
$50,500
$50,500
$50,500
Cold Storage
Large
$0
$35,800
$35,800
$35,800
$35,800
$35,800
$35,800
IPR
IPR
Medium
$0
$1,338,300
$1,338,300
$1,338,300
$1,338,300
$1,338,300
$1,338,300
IPR
Large
$0
$2,372,300
$2,372,300
$2,372,300
$2,372,300
$2,372,300
$2,372,300
Automatic Leak Detection
$0
S26,491,300
$26,491,300
S26,491,300
S26,491,300
S26,491,300
$26,491,300
School & Tour
Bus AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CC
Transit Bus AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Train AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Chiller
Medium
$0
$0
$0
$0
$0
$0
$0
Chiller
Large
$0
$0
$0
$0
$0
$0
$0
Modern Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CR
Condensing
Unit
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Vintage Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
102
-------
Rack3
Medium
$0
$7,725,900
$7,725,900
$7,725,900
$7,725,900
$7,725,900
$7,725,900
Rack3
Large
$0
$7,725,900
$7,725,900
$7,725,900
$7,725,900
$7,725,900
$7,725,900
Marine
Transport3
Small
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Medium
$0
$172,800
$172,800
$172,800
$172,800
$172,800
$172,800
Marine
Transport3
Large
$0
$188,300
$188,300
$188,300
$188,300
$188,300
$188,300
Cold Storage
Large
$0
$447,700
$447,700
$447,700
$447,700
$447,700
$447,700
IPR
IPR
Medium
$0
$0
$0
$0
$0
$0
$0
IPR
Large
$0
$10,230,700
$10,230,700
$10,230,700
$10,230,700
$10,230,700
$10,230,700
Reporting & Recordkeeping
$0
SI 0,770,884
$10,770,884
SI 0,770,884
SI 0,770,884
S 10,770,884
S 10,770,884
CC,
CR,
and
IPR
CC and CR
15-50 lb.
15-50
$0
$6,115,317
$6,115,317
$6,115,317
$6,115,317
$6,115,317
$6,115,317
CC, CR, and
IPR >50 lb.
50+
$0
$4,655,567
$4,655,567
$4,655,567
$4,655,567
$4,655,567
$4,655,567
Total
-S20,873,100
S 131,167,684
SI 10,294,584
SI 20,713,784
S99,840,684
$117,722,284
S%,849,184
Totals may not sum due to independent rounding.
a The costs and savings for Modern Rail Transport, Vintage Rail Transport, Rack, and Marine Transport reflect the requirements to use reclaimed material starting in 2029.
Table C-2: Total Annual Refrigerant Savings in 2040 (2022$) and Combined Annual Cost and Annual Savings with 7% and 3%
Discount Rate by Equipment Type
~"n Discount Hate
.?"» Discount Hale
2"a Discount Hale
Sector
liquipmciU Type
¦I nnu at
liejrigeranl
Savings
Incremental
( 'om/iliance
( osls
( 'ombinetl
Animal
Savings anil
( om/i/iaiice
( osls
Incremental
( 'ompliance
( osls
( ombinetl
Animal
Savings ami
( omi'liance
( osls
Incremental
( t>in/>li
-------
~"n Discount Hate
.?"» Discount Hate
2"a Discount Hate
Sector
lit/nipinc/il type
¦liin mil
lie/rigeranl
Savings
Incremental
('ompliance
( o.st.s
( 'onibinetl
Ann mil
Savings and
( 'ompliance
( o\t\
Incremental
( 'ompliance
( o\t\
( onibinetl
Annual
Savings am!
( 'ompliance
C o\t\
Incremental
( ompliance
( o\t\
( onibinetl
Annual
Savings ami
('onipliance
( o\t\
211-11)
20-10
20-10
20-10
20-10
20-10
20-10
1 nun \(
"Mih-^mall
-S".2<)<)
M4\4oo
si ^x.: Uo
Transit Bus AC
Sub-Small
$0
$3,303,700
$3,303,700
$3,303,700
$3,303,700
$3,303,700
$3,303,700
Train AC
Sub-Small
$0
$493,300
$493,300
$493,300
$493,300
$493,300
$493,300
Chiller
Medium
$0
$6,949,600
$6,949,600
$6,949,600
$6,949,600
$6,949,600
$6,949,600
Chiller
Large
$0
$157,000
$157,000
$157,000
$157,000
$157,000
$157,000
CR
Modern Rail
Transport3
Sub-Small
$0
$788,700
$788,700
$788,700
$788,700
$788,700
$788,700
104
-------
"n Discount Hate 3"» Discount Hate 2"» Discount Hate
¦I mm til
( Ombinetl
( ombinetl
('ombinetl
Sector
Hqnipmcnl Type
lie/rigerant
Savings
Incremental
( 'ompliance
Ann mil
Savings and
Incremental
( ompliance
Animal
Savings ami
Incremental
('ompliance
Animal
Savings ami
( OS Is
( 'ompliance
( osts
( osts
( ompliance
( osts
( osts
('ompliance
( osts
20-10
20-10
20-10
20-10
20-10
20-10
20-10
Condensing
Unit
Sub-Small
$0
$6,054,800
$6,054,800
$6,054,800
$6,054,800
$6,054,800
$6,054,800
Vintage Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Rack3
Medium
$0
$1,992,300
$1,992,300
$1,992,300
$1,992,300
$1,992,300
$1,992,300
Rack3
Large
$0
$398,500
$398,500
$398,500
$398,500
$398,500
$398,500
Marine
Transport3
Small
$0
$2,634,200
$2,634,200
$2,634,200
$2,634,200
$2,634,200
$2,634,200
Marine
Transport3
Medium
$0
$13,365,200
$13,365,200
$13,365,200
$13,365,200
$13,365,200
$13,365,200
Marine
Transport3
Large
$0
$41,900
$41,900
$41,900
$41,900
$41,900
$41,900
Cold Storage
Large
$0
$13,100
$13,100
$13,100
$13,100
$13,100
$13,100
IPR
IPR
Medium
$0
$785,700
$785,700
$785,700
$785,700
$785,700
$785,700
IPR
Large
$0
$911.200
$911,200
$911,200
$911,200
$911,200
$911,200
Automatic Leak Detection
so
SI 7,473,700
SI 7,473,700
SI 7,473,700
SI 7,473,700
SI 7,473,700
SI 7,473,700
School & Tour
Bus
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CC
Transit Bus AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Train AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Chiller
Medium
$0
$0
$0
$0
$0
$0
$0
Chiller
Large
$0
$0
$0
$0
$0
$0
$0
Modern Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CR
Condensing
Unit
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Vintage Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Rack3
Medium
$0
$2,764,700
$2,764,700
$2,764,700
$2,764,700
$2,764,700
$2,764,700
Rack3
Large
$0
$2,764,700
$2,764,700
$2,764,700
$2,764,700
$2,764,700
$2,764,700
105
-------
Sector liquipment Type
¦I mm ul
Refrigerant
Savings
20-10
Incremental
( ompliance
( osts
"n Discount Rate
( 'ombined
Annual
Savings and
( 'ompliance
(osts
2040
2040
3"a Discount Hale
( ombined
Annual
Savings and
( ompliance
Costs
2040
Incremental
( ompliance
( osts
2040
2"n Discount Hate
( ombined
Annual
Savings and
( ompliance
Costs _
2040
Incremental
('ompliance
( osts
2040
Marine
Transport3
Small
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Medium
$0
$261,500
$261,500
$261,500
$261,500
$261,500
$261,500
Marine
Transport3
Large
$0
$290,700
$290,700
$290,700
$290,700
$290,700
$290,700
Cold Storage
Large
$0
$202,300
$202,300
$202,300
$202,300
$202,300
$202,300
IPR
¦Ipr
Medium
$0
$0
$0
$0
$0
$0
$o'
IPR
Large
$0
$11.189.800
$11.189.800
$11.189.800
$11.189.800
$11.189.800
$11.189.800
Reporting & Record keeping
so
S7,860,124
S7,860,124
S7,860,124
S7,860,124
S7,860,124
S7,860,124
CC.
CR,
CC and CR
15-50 lb.
15-50
$0
$4,629,656
$4,629,656
$4,629,656
$4,629,656
$4,629,656
$4,629,656
and
IPR
Total
50+
$0
CC, CR, and
IPR >50 lb.
-M 2,790,700
Totals may not sum due to independent rounding.
3 The costs and savings for Modern Rail Transport, Vintage Rail Transport, Rack, and Marine Transport reflect the requirements to use reclaimed material starting in 2029.
$3,230,469
S86,256,<)24
$3,230,469 1 $3,230,469 1 $3,230,469 1 $3,230,469 1 $3,230,469
S73,466,224 S79,079,624 S66,288,924 S77,024,924 S64,234,224
Table C-3: Total Annual Refrigerant Savings in 2050 (2022$) and Combined Annual Cost and Annual Savings with 7% and 3%
Discount Rate by Equipment Type
~"n Discount Hate
3"n Discount Hate
2",i Discount Rate
Sector l:
-------
Discount Utile
Sector l'.t]uipment type
¦Inn mil
lie/ri^ertiiil
Savings
2050
Incremental
( onipliance
( ost.s
2050
( oinbined
An until Savings
anil ( onipliance
( o\l\
2050
3"a Discount Utile
( oinbined
Annual
Savings and
('ompliance
Costs
2050
Incremental
( ompliance
( o.sl.s
2050
2"n Discount Hale j
(oinbined j
Incremental Annual j
( 'ompliance Savings and \
( osls ( oinpliance J
(o\t\ j
2050 2050
School & Tour
Bus AC
Sub-Small
-$25,600
$2,959,500
$2,933,900
$1,405,000
$1,379,400
$962,200
$936,600
cc
Transit Bus AC
Sub-Small
-$15,300
$1,048,400
$1,033,100
$497,700
$482,400
$340,900
$325,600
Train AC
Sub-Small
-$7,800
$157,500
$149,700
$74,800
$67,000
$51,200
$43,400
Chiller
Medium
-$2,709,700
$4,629,300
$1,919,600
$2,212,700
-$497,000
$1,517,900
-$1,191,800
Chiller
Large
-$210,800
$154,700
-$56,100
$73,600
-$137,200
$50,400
-$160,400
Modern Rail
Transport3
Sub-Small
-$6,200
$125,200
$119,000
$59,400
$53,200
$40,700
$34,500
Condensing
Unit
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Vintage Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Rack3
Medium
$0
$0
$0
$0
$0
$0
$0
CR
Rack3
Large
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Small
-$373,600
$457,700
$84,100
$217,600
-$156,000
$149,100
-$224,500
Marine
Transport3
Medium
-$1,931,300
$2,178,900
$247,600
$1,041,800
-$889,500
$714,700
-$1,216,600
Marine
Transport3
Large
-$72,900
$21,700
-$51,200
$10,200
-$62,700
$7,000
-$65,900
Cold Storage
Large
$0
$0
$0
$0
$0
$0
$0
IPR
¦Ipr
Medium
-$59,800
$26,800
-$33,000
$12,800
-$47,000
$8,800
-$51,000
IPR
Large
-$1,655,700
$137,200
-$1,518,500
$65,100
-$1,590,600
$44,500
-$1.611.200
Leak Inspection
SO
S39,939,3(K)
S39,93«)^(M)
S39,939,300
S39,939,3(M)
S39,939,3(K)
S39,939,3(M)
School & Tour
Bus AC
Sub-Small
$0
$10,102,300
$10,102,300
$10,102,300
$10,102,300
$10,102,300
$10,102,300
CC
Transit Bus AC
Sub-Small
$0
$3,579,100
$3,579,100
$3,579,100
$3,579,100
$3,579,100
$3,579,100
Train AC
Sub-Small
$0
$534,200
$534,200
$534,200
$534,200
$534,200
$534,200
Chiller
Medium
$0
$6,161,900
$6,161,900
$6,161,900
$6,161,900
$6,161,900
$6,161,900
Chiller
Large
$0
$162,500
$162,500
$162,500
$162,500
$162,500
$162,500
107
-------
",i Discount Utile 3"» Discount Utile 2"n Discount Utile
Sector
Equipment type
¦In until
lie/ri^ertinl
Savings
/ncreinenltil
( 'oinplitince
( osls
( 'oinbinetl
¦hi until Suviiifi.s
tint/ ( oinplitince
( osls
Incremental
('oinplitince
( osls
( oinbinetl
¦hi until
Savings tint!
('oinplitince
( osls
Increnienlul
('oinplitince
( osls
('oinbinetl
¦I n until
Savings tintl
( oinpliunce
( osls
2050
2050
2050
2050
2050
2050
2050
Modern Rail
Transport3
Sub-Small
$0
$854,100
$854,100
$854,100
$854,100
$854,100
$854,100
Condensing
Unit
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Vintage Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Rack3
Medium
$0
$0
$0
$0
$0
$0
$0
CR
Rack3
Large
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Small
$0
$2,971,800
$2,971,800
$2,971,800
$2,971,800
$2,971,800
$2,971,800
Marine
Transport3
Medium
$0
$15,054,600
$15,054,600
$15,054,600
$15,054,600
$15,054,600
$15,054,600
Marine
Transport3
Large
$0
$39,200
$39,200
$39,200
$39,200
$39,200
$39,200
Cold Storage
Large
$0
$0
$0
$0
$0
$0
$0
TPR
IPR
Medium
$0
$281,900
$281,900
$281,900
$281,900
$281,900
$281,900
IPR
Large
$0
$197,700
$197,700
$197,700
$197,700
$197,700
$197,700
Automatic Leak Detection
so
S5,713,900
S5,713,900
S5,713,900
S5,713,900
S5,713,900
S5,713,900
School & Tour
AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CC
Transit Bus AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Train AC
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Chiller
Medium
$0
$0
$0
$0
$0
$0
$0
Chiller
Large
$0
$0
$0
$0
$0
$0
$0
Modern Rail
Transport3
Sub-Small
$0
$0
$0
$0
$0
$0
$0
CR
Condensing
Unit
Sub-Small
$0
$0
$0
$0
$0
$0
$0
Vintage Rail
Sub-Small
$0
$0
$0
$0
$0
$0
$0
108
-------
~"n Discount Utile
J"o Discount Hale
2"n Discount Hate
Sector
Equipment type
.1 till Hill
lie/rigerant
Savings
Incremental
( 'onipliance
( o\t\
( 'oinbinetl
Annual Savings
and ( onipliance
( o\t\
Incremental
( onipliance
( o\t\
( oinbinetl
Animal
Savings am!
('onipliance
( o\l\
Incremental
('onipliance
( o\t\
( oinbinetl
Animal
Savings anil
('onipliance
( o\t\
2050
2050
2050
2050
2050
2050
2050
Rack
Medium
so
SO
SO
SO
SO
so
SO
Rack3
Large
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Small
$0
$0
$0
$0
$0
$0
$0
Marine
Transport3
Medium
$0
$327,100
$327,100
$327,100
$327,100
$327,100
$327,100
Marine
Transport3
Large
$0
$335,900
$335,900
$335,900
$335,900
$335,900
$335,900
Cold Storage
Large
$0
$0
$0
$0
$0
$0
$0
TPR
IPR
Medium
$0
$0
$0
$0
$0
$0
$0
IPR
Large
$0
$5,050,900
$5,050,900
$5,050,900
$5,050,900
$5,050,900
$5,050,900
Reporting & Recordkeeping
so
S7,361,138
S7,361,138
S7,361,138
S7,361,138
S7,361,138
S7,361,138
CC,
CR,
CC and CR 15-
50 lbs.3
15-50
$0
$4,097,624
$4,097,624
$4,097,624
$4,097,624
$4,097,624
$4,097,624
and
IPR
CC. CR. and
IPR >50 lbs.
50+
$0
$3,263,514
$3,263,514
$3,263,514
$3,263,514
$3,263,514
$3,263,514
Total
-S7,068,700
S64,911,238
S57,842,538
S58,685,038
S51,616,338
S56,901,738
S49,833,038
Totals may not sum due to independent rounding.
3 The costs and savings for Modern Rail Transport, Vintage Rail Transport, Rack, and Marine Transport reflect the requirements to use reclaimed material starting in 2029.
109
-------
Appendix D. Modeled Servicing Demand for Equipment Affected
by Reclamation Provisions, by HFC Gas
Projected reclaimed refrigerant demand, accounting for the leak repair provisions in the final rule, is
shown by species and equipment type in the Table D-l below. In 2029, when the requirement for
servicing and/or repair of certain refrigerant-containing equipment with reclaimed HFCs take effect, the
required reclaimed refrigerants for service in the subsectors specified are estimated to be 1,417 MT HFC-
32, 5,110 MT HFC-125, 3,381 MT HFC-134a, and 2,259 MT HFC-143a.61
Table D-l: Service Demand of HFCs for Applicable Subsectors in 2029a
Sector Refrigerant- Service Demand (M l )
C ontaininx
lu/tii/tnienr Type
///( -32
///'(-125
lll ( -LUa
UK -1-/.vi
Supermarket Systems
1,265
3,561
2,621
1,213
Road
82
730
191
402
Vintage
0
0
10
0
Refrigerated Modern Rail
0
2
5
2
Transport Intermodal
0
3
298
3
Containers
Marine
58
789
236
622
Automatic Commercial Ice Makers
11
25
22
16
Total
1,417
5,110
3,381
2,259
a Results by gas represent demand for HFCs both as neat gases and as constituent gases within specific blends.
For example, a significant driver of demand for HFC-32, HFC-125, and HFC-134a in the above table is driven
by estimated servicing demand for R-407A, a blend of these three gases.
From 2029 through 2050, the amount of reclaimed HFCs needed to service the applicable refrigerant-
containing equipment types is expected to decrease, in both mass and CC^e terms, as more refrigerant-
containing equipment transitions to alternatives. Further, as refrigerant-containing equipment using
higher-GWPs comes offline, the model assumes some of that can be recovered and reused, alleviating the
need for reclaimed material. Tables D-2 and D-3 show the projected demand for servicing the designated
refrigerant-containing equipment types in metric tons and MMTCChe.
61These values represent the full demand and do not incorporate the rule's allowance that up to 15 percent of the
amount may be from virgin material.
-------
Table D-2: Service Demand of HFCs for Applicable Subsectors, 2029-2050 (Metric Tons)
Year
!1K -32
UK -125
UK -IJ-la
UK -1-13,1
Total
2029
1,417
5,110
3,381
2,259
12,168
2030
1,389
4,889
3,274
1,978
11,530
2031
1,348
4,685
3,147
1,747
10,927
2032
1,292
4,477
2,988
1,546
10,303
2033
1,223
4,292
2,808
1,402
9,725
2034
1,148
4,095
2,621
1,254
9,119
2035
1,077
3,915
2,440
1,117
8,548
2036
1,005
3,730
2,255
976
7,967
2037
919
3,524
2,072
897
7,411
2038
831
3,313
1,884
816
6,844
2039
742
3,097
1,693
733
6,266
2040
651
2,878
1,498
650
5,677
2041
558
2,653
1,300
565
5,076
2042
464
2,436
1,098
495
4,494
2043
404
2,300
964
439
4,106
2044
415
2,318
971
398
4,101
2045
425
2,349
978
372
4,124
2046
436
2,380
985
346
4,147
2047
446
2,411
992
319
4,168
2048
457
2,442
999
291
4,189
2049
468
2,472
1,006
263
4,209
2050
472
2,495
1,014
266
4,247
111
-------
Table D-3: Service Demand of HFCs for Applicable Subsectors, 2029-2050 (MMTCOie)
Year
!1K -32
UK -125
UK -IJ-la
UK -1-13,1
Tolul
2029
1.0
17.9
4.8
10.1
33.8
2030
0.9
17.1
4.7
8.8
3 1.6
2031
0.9
16.4
4.5
7.8
29.6
2032
0.9
15.7
4.3
6.9
27.7
2033
0.8
15.0
4.0
6.3
26.1
2034
0.8
14.3
3.7
5.6
24.5
2035
0.7
13.7
3.5
5.0
22.9
2036
0.7
13.1
3.2
4.4
21.3
2037
0.6
12.3
3.0
4.0
19.9
2038
0.6
11.6
2.7
3.6
18.5
2039
0.5
10.8
2.4
3.3
17.0
2040
0.4
10.1
2.1
2.9
15.6
2041
0.4
9.3
2.5
14.0
2042
0.3
8.5
2.2
12.6
2043
0.3
8.0
2.0
11.7
2044
0.3
8.1
1.8
11.6
2045
0.3
8.2
1.7
11.6
2046
0.3
8.3
1.5
11.6
2047
0.3
8.4
1.4
11.6
2048
0.3
8.5
1.3
11.6
2049
0.3
8.7
1.4
1.2
11.6
2050
0.3
8.7
1.5
1.2
11.7
112
-------
Appendix E. Detailed Description of Mitigation Actions Modeled
Specific to the ER&R Rule
For the MACC analysis used as the primary methodological tool, updated abatement options were
calculated for leak repair, ALD, reclaimed refrigerant requirements, and fire suppression-related
provisions contained in the final rule for each year of the analysis period (2026-2050). For calculating
break-even costs, abatement potential was calculated on a consumption basis (i.e., cost per ton of carbon
dioxide equivalent consumption abated), to be comparable to the abatement options presented in the
Allocation Rules and 2023 Technology Transitions Rules analyses.
Leak repair of appliances
Abatement options for leak repair were calculated for the equipment types and sizes analyzed in this RIA
Addendum, using the same approach for estimating costs and benefits. In these options, because
equipment owners would eventually add refrigerant to maintain that equipment in working order, it was
assumed that emission benefits are equivalent to consumption benefits (i.e., that all avoided refrigerant
emissions associated with repairing leaks translate into avoided consumption).
Table E-l: Leak Repair abatement options added to MACC model for the ER&R Rule analysis in
2026
Mnilcmcnl Option
\o.
Type
liipiipmcnl Type
liipiipmcnl Size
lliciilicvcn ( osl
(S niK f)_-c)
1
Leak repair
School & Tour Bus AC
Sub-small
$2,798.13
2
Leak repair
Transit Bus AC
Sub-small
$1,651.70
3
Leak repair
Passenger Train AC
Sub-small
$431.23
4
Leak repair
Chiller
Medium
$14.69
5
Leak repair
Large
$0.81
6
Leak repair
Modern Rail Transport
Sub-small
$534.15
7
Leak repair
Vintage Rail Transport
Sub-small
$349.47
8
Leak repair
Condensing Unit
Sub-small
$322.98
9
Leak repair
Marine Transport
Small
$21.46
10
Leak repair
Medium
$21.41
113
-------
11
Leak repair
Large
$10.41
12
Leak repair
Rack
Medium
$21.56
13
Leak repair
Large
$9.24
14
Leak repair
Cold Storage
Large
-$0.22
15
Leak repair
[PR
Medium
$21.03
16
Leak repair
Large
-$0.62
Automatic leak detection systems
Abatement options for requiring ALD systems in existing and new systems were calculated for the
equipment types and sizes shown in table A-4. The approach for estimating capital, installation, and
O&M costs of ALD systems was based on the assumptions detailed in Appendix A of this RIA
Addendum. The leak repair and inspection costs, refrigerant savings, and benefits of the ALD options
were associated with repairs being conducted four weeks earlier (i.e., the incremental difference between
the assumed six weeks earlier that repairs will be conducted without ALD and the 10 weeks earlier
assumed for systems using ALD monitoring, as detailed in the draft RIA Addendum) and/or systems
requiring fewer leak inspections (e.g., CR and IPR systems containing more than 1,500 pounds of
refrigerant will switch from quarterly to annual inspections).
As with the added leak repair abatement options, it was assumed that emission benefits are equivalent to
consumption benefits (i.e., that all avoided refrigerant emissions associated with repairing leaks translate
into avoided consumption).
Table E-2: ALD abatement options added to MACC model for the ER&R Rule analysis in 2026
Op!ion So.
Type
l'A\ui\nvcitf Type
liqiiipmenl Size
lireukeven ( osl
(S ml( ().-e)
17
ALD
Marine Transport
Medium
-$2.13
18
ALD
Large
-$4.89
19
ALD
Rack
Medium
-$22.01
114
-------
Op!ion So.
Type
l'A\ui\nvcitf Type
liqiiipmenl Size
lireukeven ( osl
(S 'niK Ox)
20
ALD
Large
-$15.78
21
ALD
Cold Storage
Large
-$2.09
22
ALD
IPR
Large
-$4.47
Servicing and/or repair of equipment with reclaimed HFCs starting January 1, 2029
To quantify costs and benefits, a baseline for the use of reclaimed HFCs in business-as-usual was first
established. This baseline was derived from HFC reclamation totals modeled in the Vintaging Model62
relative to modeled consumption for the RACHP and fire suppression sectors (i.e., new chemical demand
and servicing demand) across the analysis period (2026-2050). The assumed percentage of demand met
by reclaimed refrigerant in the baseline is 26.5 percent per year.
The costs and/or cost savings estimated for this activity included the refrigerant price difference in
reclaimed refrigerant vs. virgin refrigerant. For the purposes of this analysis, it was assumed that the price
of reclaimed refrigerant is 10 percent higher than virgin manufacture.63 We provide a sensitivity analysis
of this assumption in Appendix L.
The consumption benefits of this regulatory action needed to account for the proportion of virgin
manufacture that the use of reclaimed refrigerant can offset. As discussed above, in our base case we
assume there some recovery activity in the BAU model. In addition to accounting the BAU activity, we
assume an additional offset stems from the final rule, which allows up to 15 percent virgin HFC material
in reclaimed refrigerant.
This requirement was modeled as a series of abatement options that account for whether the equipment
types for which reclaimed refrigerant must be used are covered or not covered by the leak repair
requirements. For those equipment types covered by the leak repair requirements, the abatement options
62 The Vintaging Model assumes disposal recovery from equipment reaching end-of-life in a particular year is used to meet
consumption demand for the same subsector and substance (i.e., new chemical demand plus servicing demand) in the same year
(i.e., reclamation). If disposal recovery is not sufficient to meet consumption demand, the remainder is assumed to be produced as
virgin manufacture.
63 This baseline amount of reclaim is not accounted for in the costs/benefits of the leak repair options above (e.g., the average
refrigerant price is assumed to represent the cost of virgin refrigerant).
115
-------
further distinguish between: a) leak repair above the leak threshold; and b) additional servicing and/or
repair that would be conducted that is below the leak rate threshold.
• Leak repair above the leak threshold, using reclaimed refrigerant, for marine transport, modern
rail transport, vintage rail transport, and supermarket rack systems.
o To avoid double counting, these options supplant their equivalent, non-reclaim options
listed above in Leak Repair and ALD (i.e., option numbers 6-7, 9-13, and 17-20), starting
in 2029, when the requirement to use reclaim in servicing for the affected subsectors take
effect. Costs and consumption benefits of leak repair using reclaimed refrigerant are
calculated using the leak repair methods described in this RIA Addendum—but
substituting the price of reclaimed refrigerant and applying the offsets for reclaim
described above. EPA conservatively assumed that these measures would not result in an
additional reduction in emissions beyond the emissions reductions from recovery of
HFCs and avoided venting at disposal and servicing already included in the baseline.
Table E-3: Combined leak repair, ALD, and reclaim abatement options added toMACC model
for the ER&R Rule analysis in 2029
Option So.
Type
liquipmciU Type
liquipmenl
Si:e
Hreukeven
( OS/
(S ml( (>:e)
23
Leak repair - reclaim
Modern Rail Transport
Sub-small
$912.53
24
Leak repair - reclaim
Vintage Rail Transport
Sub-small
$596.35
25
Leak repair - reclaim
Marine Transport
Small
$38.02
26
Leak repair - reclaim
Medium
$37.94
27
Leak repair - reclaim
Large
$18.06
28
Leak repair - reclaim
Rack
Medium
$38.43
29
Leak repair - reclaim
Large
$16.15
30
ALD - reclaim
Marine Transport
Medium
$36.72
31
ALD - reclaim
Large
$24.71
32
ALD - reclaim
Rack
Medium
$29.67
33
ALD - reclaim
Large
$17.59
• Servicing and/or repair below the leak threshold using reclaimed refrigerant, for marine
transport, modern rail transport, vintage rail transport, and supermarket rack systems.
o For these abatement options, the amount of servicing was based on the difference
between the amount of refrigerant replaced in each year (2029-2050) in equipment
leaking above the leak threshold and the baseline amount of servicing demand modeled
for these equipment types in the Vintaging Model. As for other reclaim options, the
assumed costs reflect the price of reclaimed refrigerant, and the consumption benefits
apply offset factors for the continued use of virgin material (i.e., up to 15%) and the
116
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baseline percentage of demand met by reclaim (i.e., 26.5%). There are no emission
benefits associated with these options.
Table E-4: Servicing reclaim abatement options added to MACC model for the ER&R Rule
analysis in 2029
Option So.
Type
liipiipmenl type
liipiipmenl Si-e
Hreukeven ( o.\t
(\ml( Ox-)
34
Servicing - reclaim
Modern Rail Transport
Sub-small
$0.33
35
Servicing - reclaim
Vintage Rail Transport
Sub-small
$0.62
36
Servicing - reclaim
Marine Transport
Small
$0.27
37
Servicing - reclaim
Medium
$0.27
38
Servicing - reclaim
Large
$0.34
39
Servicing - reclaim
Rack
Medium
$0.34
40
Servicing - reclaim
Large
$0.34
• All servicing and/or repair for equipment types covered by the reclaimed refrigerant requirement
but not covered by the leak repair requirement.
o For these abatement options, servicing demand was derived from EPA's Vintaging
Model. As with other reclaim options, the assumed costs reflect the price of reclaimed
refrigerant and the consumption benefits apply offset factors for the continued use of
virgin material (i.e., up to 15%) and the baseline percentage of demand met by reclaim
(i.e., 26.5%). There are no emission benefits associated with these options.
Table E-5: Additional servicing reclaim abatement options added to MACC model for the ER&R
Rule analysis in 2029
Option So.
Type
liipiipmenl type
Hreukeven ( os/
(\ml( Ox)
41
Servicing other equipment types -
reclaim
Road Transport
$0.30
42
Servicing other equipment types -
reclaim
Intermodal Containers
$0.60
43
Servicing other equipment types -
reclaim
Automatic Commercial Ice Makers
$0.38
117
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Fire suppression equipment
An additional set of abatement options was run for rule provisions associated with restricting intentional
releases (e.g., during installation, servicing, repairing, or disposal) of fire suppression equipment.
Abatement options for total flooding fire suppression systems were calculated assuming a proportion of
the annual leakage amount (assumed to be 0.5 percent) for total flooding systems estimated in the
Vintaging Model is avoided through the venting restriction. Cost savings are assumed because losses
during testing of new or existing systems would have been replaced before the unit enters or reenters
64
service.
Additionally, fire suppression equipment is required to use recycled fire suppression agent for both
servicing existing equipment (beginning in 2026) and to install new equipment (beginning in 2030).
Because the venting restriction and recycled agent requirement for servicing/repair of fire suppression
equipment start in the same year (2026), the venting prohibition option assumes that intentional venting
during testing would have been replaced with recycled agent, and therefore, as for other reclaim options
in the RACHP sector, the assumed costs reflect the price of recycled agent and the benefits apply the
offset factors for the continued use of virgin material (i.e., up to 15%) and the baseline percentage of
demand met by reclaim (i.e., 26.5%).
In addition, options associated with the requirement to use recycled agent in servicing (i.e., for normal
operating leaks and servicing) for total flooding systems and filling of new fire suppression equipment for
total flooding and streaming were considered. Costs and benefits for these options were calculated using
the same approach as that used for refrigeration and AC equipment. The venting prohibition option is
estimated to have emission benefits analogous to 0.5 percent of leak emissions for total flooding fire
suppression systems. There are no associated emission benefits for the use of recycled agent for servicing
and initial installation in fire suppression equipment.
Table E-6: Fire suppression abatement options added toMACC model for the ER&R Rule
analysis in 2026 or 2030
Option \o.
Type
liipiipmenl type
Hreukeveii ( osl
(S iiiK (>:e)
44
Venting prohibition -
recycled
Fire Extinguishing: Flooding Agents
$0.26
64 An abatement option for the venting prohibition requirement is only applied to total flooding systems because streaming
systems are not assumed to be serviced and therefore have no consumption benefits associated with avoiding leaks (i.e., losses
from intentional venting are not replaced over the lifetime of the equipment). The potential emission benefits for streaming
systems due to the venting prohibition are not calculated in this RIA addendum. Similarly, an abatement option for the servicing
reclaim requirement is only applied to total flooding systems because streaming systems are not assumed to be serviced.
118
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45
Servicing- recycled
Fire Extinguishing: Flooding Agents
$0.26
46
Initial installation - recycled
Fire Extinguishing: Streaming Agents
$0.09
47
Initial installation - recycled
Fire Extinguishing: Flooding Agents
$0.26
Appendix F. Analysis of Alternative Reference Case
As discussed in section 3.1 of this document, the incremental costs and benefits of the final ER&R Rule
depend in part on the degree to which industry would have otherwise undertaken measures such as
improved leak repair and recovery even in the absence of this regulation. Prior analyses conducted by
EPA have illustrated multiple potential compliance pathways in response to existing AIM Act
regulations, some of which included measures that would partially fulfill the requirements of the ER&R
Rule. These include actions taken in the fire protection subsector, improved leak repair, and additional
recovery at disposal.
As discussed in the 2023 Technology Transitions Rule RIA Addendum, these measures are not required
to meet compliance with prior AIM Act regulations, and the degree to which industry would undertake
them in the absence of explicit requirements is uncertain. Since these fire protection, leak repair, and
enhanced recovery measures were not found to be required to meet compliance with the Allocation and
2023 Technology Transitions Rules, they are not included in the primary reference case for this analysis.
However, as a bounding exercise, this appendix provides the resulting incremental benefits of the final
ER&R Rule with an alternative reference case in which these measures are included. In other words, these
measures are assumed to occur even in the absence of the ER&R Rule, thus illustrating a lower bound of
the incremental climate benefits of the rule.
Table F-1 below provides a summary of the specific measures previously assumed as compliance options
for the Allocation and 2023 Technology Transitions Rules RIA and RIA Addenda which are included in
the reference case in the alternative scenario provided in this appendix. Transitions to lower-GWP options
as assumed in the 2023 Technology Transitions Rule RIA remain as part of the reference case under this
alternative scenario as they do in the primary reference case.
119
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Table F-1: Reference Case Assumptions in ER&R Rule Base Case vs. Alternative Reference Case
Scenario
. Ihutement ICR&R. Mternutive Reference ('use
Measure Assumption
UR&R liuse ('use. \ssuniprion
No improvement in average leak rate for large
RefAC equipment included in reference case beyond
Vintaging Model BAU assumptions.
Leak Repair Average leak rate for large RefAC
equipment improves (i.e., is reduced) by
40% assumed in reference case. ER&R
Rule reclaim requirements only result in
incremental emission reductions insofar
as they require additional or earlier leak
repairs beyond these levels.
Disposal Improvement in end-of-life emissions
Recovery and rate to 3-4% of remaining equipment
Emissions charge for large and small RACHP
equipment assumed in reference case.
ER&R Rule reclaim requirements do not
result in incremental emissions
reductions and recovery rates beyond
these levels.
No improvement in end-of-life emissions rate
assumed in reference case beyond Vintaging Model
BAU assumptions.
Fire Fire suppression sector makes transitions
Suppression away from HFCs to low-GWP
alternatives in reference case. ER&R
measures therefore affect smaller
universe of fire suppression equipment.
Fire suppression sector does not make transitions
away from HFCs to low-GWP alternatives in
reference case. ER&R measures affect larger
universe of fire suppression equipment still using
HFCs.
RACHP,
Foams, and
Aerosol
Transitions
All transitions in the 2023 Technology
Transitions RIA Addendum Base Case
are assumed in the reference case.
All transitions in the 2023 Technology Transitions
RIA Addendum Base Case are assumed in the
reference case.
Table F-2 and Table F-3 below provide the total MAC costs and emissions reductions in the ER&R
Alternative Reference Case and Base Case Scenarios.
Table F-2: Incremental Annual Compliance Costs of MAC Abatement Measures under ER&R Alternative
Reference Case and Base Case Scenarios (Millions 2022$)
ilRAR. Mternutive Reference C use
Scenario
KRAR Jiase ( use
Year
Leak Repair
Reclamation
1 ire
Leak Repair
Reclamation
lire
Suppression
Suppression
2026
$69.5
$-
$0.1
$79.5
$-
$0.2
2030
$91.5
•>2 2
$0.3
X88.3
$3.9
$0.8
2035
$78.8
SI 4
$0.2
$75.0
$3.1
$0.9
2040
$61.8
SI 0
$0.3
$57.5
$2.3
$0.9
2045
$45.2
SI 0
$0.4
$43.4
$1.8
SI o
2050
S44 O
S2 1
SO O
S43 3
SI <)
SI o
PY (3V-i.
d.r.)
S1. i x3
S23
S5
SI.140
S3S
SI 3
120
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Table F-3: Incremental Annual Emissions Reductions from MAC Abatement Measures under ER&R
Alternative Reference Case and Base Case Scenarios (MMTC02e)
HRX R. Mter native Reference Case
Scenario
HR&R liase Case
Year
Leak Repair
keclanialion
lire
Suppression
Leak Repair
keclanialion
lire
Suppression
202(>
()i)
O O |
5 »
0 0 |
2030
3.41
-
0.01
5.63
-
0.01
2035
2.97
-
0.00
4.62
-
0.01
2040
2.16
-
0.00
3.01
-
0.01
2045
1.23
-
0.00
1 53
-
0.01
2050
0.83
-
0.00
0.92
-
0.01
Tolsil
5X i)5
-
1) 12
SS4M
-
1) 21
*Reclaim requirements may lead to additional emissions reductions by inducing increased recovery of refrigerant at
servicing and disposal that may otherwise be released or vented. As described elsewhere in this RIA Addendum,
EPA has conservatively assumed that these measures do not yield incremental HFC emissions reductions beyond
model BAU levels.
Overall, these results indicate that there would be approximately 34% less reductions in emissions under
the alternative reference case assumptions, while the present value of total costs would be approximately
1% higher than those of the ER&R base case.
For abatement measures corresponding to leak repair and ALD provisions, overall avoided emissions
reductions decrease under the alternative reference case scenario, since average reference case equipment
leak rates are lower (thus yielding lower "available" emissions reductions from repairs). However,
because in most cases the overall scope of equipment with leak rates above the ER&R Rule leak rate
threshold remains the same under either scenario, costs remain similar, albeit with small changes due to
cases where additional equipment exceed the leak rate threshold or where the measure results in
additional refrigerant savings attributable to the rule as a result of the alternative assumptions.
For abatement measures corresponding to Fire Suppression, the inclusion of transitions away from HFCs
for the broader sector in the alternative the reference case results in a smaller universe of equipment
affected by the rule's venting and recycled HFCs provisions. As a result, both emissions reductions and
costs decrease under the alternative reference case scenario, relative to the base case.
Table F-4 below provides the benefits, costs, and net benefits under the alternative reference case
scenario.
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Table F-4: Summary of Annual Values, Present Values, and Equivalent Annualized Values select years
for the 2026-2050 Timeframe for Estimated Compliance Costs, Benefits, and Net Benefits for this Rule
(millions of2022$, discounted to 2024) - Alternative Reference Case Scenario a-b-cAe
Year
( limiili-
Cosls (2"-i..3':-i..
7v-;.)
V'( lU'iuThs (2"n liciiiTils: 2Vii.
lionollls
3"
it or C(ts(s)
(3"'ii)
2026
$246
$82
$164
2030
$481
SI 03
$379
2035
$448
$88
$360
2040
$370
$70
s;nn
2045
$278
S52
S220
2050
S24l)
S53
S1 w
Discouni
I'illO
3"'ii
2"i.
3"
7%
2"/i>
3"»
7%
PY
S(v2<)5
SI.5D7
SI. 342
SXXft
S4.M7
S4.S03
S5.3N
EAV
$356
$77
$77
$76
$279
$279
$280
a Benefits include only those related to climate. Climate benefits are based on changes (reductions) in HFC
emissions and are calculated using four different estimates of the social cost of HFCs (SC-HFCs): model average at
2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate. For the presentational
purposes of this table, we show the benefits associated with the average SC-HFC at a 3 percent discount rate. See
Chapter 5 for more discussion of the SC-HFC methodology.
bRows may not appear to add correctly due to rounding.
0 Present values are calculated using end of year discounting.
d The annualized present value of costs and benefits are calculated as if they occur over a 25-year period.
e The PV for the net benefits column is found by taking the difference between the PV of climate benefits at 3
percent and the PV of costs discounted at 7 percent, 3 percent or 2 percent. Because the SC-HFC estimates reflect
net climate change damages in terms of reduced consumption (or monetary consumption equivalents), the use of the
social rate of return on capital (7 percent under OMB Circular A-4 (2003)) to discount damages estimated in terms
of reduced consumption would inappropriately underestimate the impacts of climate change for the purposes of
estimating the SC-HFC. See Chapter 5 for more discussion.
Appendix G. SBREFA Assumptions and Methodology
This screening analysis finds that the rulemaking can be presumed not to have a significant economic
impact on a substantial number of small entities (SISNOSE).
This section describes the approach and assumptions used to estimate the economic impact on small
entities (businesses and governments) associated with the regulatory requirements for leak repair and use
of automatic leak detection (ALD) systems for certain equipment using refrigerants containing HFCs with
a GWP greater than 53 and certain substitutes; the servicing and/or repair of refrigerant-containing
equipment in certain sectors or subsectors to be done with reclaimed HFCs; the servicing, repair, disposal,
or installation of fire suppression equipment that contains HFCs, as well as requirements related to
technician training in the fire suppression sector; recovery of HFCs from cylinders; and reporting and
recordkeeping; the decision matrix used to make the SISNOSE determination; and the aggregated small
122
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entities impacts.65 The rulemaking applies to equipment used across a wide variety of businesses and
government entities,66 including school districts and cities. This analysis first assesses the economic
impact to small businesses and small governments separately and then aggregates the impact across both
types of entities to make a SISNOSE determination for the rulemaking.
Approach for Estimating the Economic Impact on Small Businesses
The analysis uses a model entity approach to estimate impacts on small businesses for the
requirements for leak repair and use ALD; the servicing and/or repair of refrigerant-containing equipment
in certain sectors or subsectors to be done with reclaimed HFCs; the servicing, repair, disposal, or
installation of fire suppression equipment that contains HFCs, requirements related to technician training
in the fire suppression sector; and recovery of HFCs from cylinders. To estimate costs per small business,
assumptions were developed for each industry category affected by the regulatory changes (i.e., the
proportion of facilities that have appliances with refrigerant charges of 15 or more pounds) and the type
and number of appliances per affected facility and business. Costs per model facility were developed to
accurately reflect the range of compliance costs that a given small business owner or operator could
experience from leak repair, leak inspection, ALD installation, and reporting and recordkeeping costs.
Costs per model facility were then scaled to a model business on both an industry-specific and equipment-
specific basis. Therefore, each model business reflects information about the average number of facilities
a business has in a given industry category and equipment type (i.e., smaller businesses typically have
fewer facilities per business than larger businesses).
The regulation also includes a requirement to recover refrigerant heels from disposable cylinders prior
to disposal. Companies that sell and distribute HFCs, in particular refrigerant, will be impacted.
Model Facility and Small Business Cost Assumptions for Leak Repair and ALD Provisions
The model business approach is built up from the model equipment analysis described in Chapter 3
and model facility assumptions developed for the average number of refrigeration and air conditioning
appliances and transit buses67 per facility or business, for each industry category, as summarized in Table
G-l. These assumptions were based on analysis of 2013 data reported under California's RMP, cross-
65 Costs associated with certain several mobile end-uses (i.e., Modern Rail Transport, Passenger Train AC, Vintage Rail
Transport, and Marine Transport) were not considered in this analysis, as it was determined that these equipment types are
wholly owned and operated by large entities.
66 The Regulatory Flexibility Act (1980) defines small governments as the government of a city, county, town, township, village,
school district, or special district with a population less than 50,000.
67 Approximately 10% of transit buses are assumed to be operated by private industry (e.g., charter buses) (APTA 2023).
123
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walked with assumptions made by similar analyses (CARB 2009; Stratus 2009) about equipment use by
industry and reconciled with expert judgment.68
Table G-l: Average Number of Systems per Facility in Industries Containing Appliances with 15 or
More Pounds of HFC Refrigerant
Industry ( tilc^ory
.1 rtSystems per
i'ticilily
((
Hi
nm
Agnail lure and Crop Support Sen ices
1
-
Arts, Entertainment, and Recreation
1
~
Beverage and Ice Manufacturing
1
~
l
Charter Bus Industry
1
Durable Goods Wholesalers and Dealers
2
~
-
Educational Services
4
1
-
Food Manufacturing
1
2
-
General Merchandise Stores
1
2
Grocery and Specialty Food Stores
1
2
-
Hospitals
2
-
-
Ice Rinks
1
-
2
Non-durable Goods Wholesalers and Dealers
1
2
-
Non-food Manufacturing
2
-
3
Office Buildings
3
-
-
Other Warehousing, Storage, and Transportation
4
-
-
Refrigerated Warehousing and Storage
1
2
-
68 Within each industry category, it was assumed that small businesses with annual revenue less than $200,000 do not utilize
equipment with more than 15 pounds of refrigerant, given that these equipment typically cool larger spaces and equipment costs
be cost prohibitive for these businesses (e.g., a typical commercial unitary air conditioning system can cost between $20,000 to
$25,000, which would represent up to 25% of total annual revenue for a business with 2 CC units and an annual revenue of
$200,000). Similarly, it was assumed that small businesses with revenue less than $500,000 would not utilize equipment with
more than 1,500 pounds of refrigerant (i.e., would not have systems that require installation of ALD systems). Thus, these
businesses would not have installed equipment affected by leak repair and inspection and ALD provisions of the rulemaking,
respectively.
124
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Industry ( Hickory
Avcrni^c Systems per
I'ticilily
((
Hi
inn
keieui'di and De\ elopnieiil
-
-
Utilities
2
-
-
Warehouse Clubs and Supercenters
1
3
Potential compliance costs for each model facility were developed to accurately reflect the range of
compliance costs that a given small business owner or operator could experience from leak repair, leak
inspection, ALD installation, and reporting and recordkeeping requirements. For each business, there are
many potential configurations of equipment types, equipment sizes, and repair outcomes that determine
compliance costs for stock above the leak rate threshold. Considering these multiple possibilities, "worst
case" model facility assumptions were adopted for standard leak repair and extension leak repair
outcomes. The "worst case" reflects the possibility that appliances with leak rates above the threshold
leak rate are clustered in individual facilities, such that all of the eligible appliances in a single model
facility might trigger inspection and repair. Within each facility, it is assumed that multiple units of the
same appliance type are maintained in the same way (e.g., if a facility has two CR systems, both
appliances are assumed to have similar leak rates), and thus experience the same leak repair outcomes.
Model facility scenarios were developed for each industry category based on how many different
sizes of appliances the industry is assumed to use within each sector and the expected number of leak
repair outcomes. Retrofit outcomes were determined to only occur to a maximum of one piece of
equipment per model facility. Each scenario features a different combination of appliance sizes and leak
repair outcomes, with likelihood of each leak repair outcome based on estimates in Appendix A.
Economic impacts to small businesses associated with ALD installation and maintenance were also
developed using the model facility approach. Although the number of potential configurations of
equipment are lower because CC equipment are exempt from ALD requirements and only CR and IPR
equipment with charge sizes greater than 1,500 pounds are impacted, a larger number of facilities are
impacted because ALD requirements apply to new and existing CR and IPR equipment installed on or
after January 1, 2017 with charge sizes greater than 1,500 pounds.69
69 For the purposes of this screening analysis, facilities experiencing leak repair and inspection costs are separate from facilities
experiencing ALD costs.
125
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Expected compliance costs per model facility were estimated by multiplying the (a) unit cost
assumptions described in Appendix A averaged across all equipment within a given size category for each
sector plus the expected reporting and recordkeeping costs per facility, by the (b) model facility
configurations for each industry sector. Costs to small businesses were then scaled based on the
proportion of facilities-to-businesses for small businesses in each size category of each NAICS code in
each industry category.
Some small businesses within each NAICS code and industry category, that operate appliances that
are subject to the rule (i.e., CC, CR, and IPR equipment containing more than 15 pounds of refrigerant),
are not expected to experience any compliance costs. This is because not all systems will leak above the
threshold leak rates, and therefore do not require leak repair or inspection or the installation of ALD
systems. However, these businesses may be subject to increased costs associated with the requirement to
use reclaimed refrigerant for the servicing and/or repair of appliances, as discussed further below.
Small Business Cost Assumptions for Reclamation and Recycling Provisions
The final rulemaking institutes several requirements related to the reclamation and recycling of HFCs.
A review of reporting under the AIM Act indicates that there are 37 EPA-certified reclaimers, of which
32 are small businesses. Under the final rule, HFC refrigerant sold as reclaimed can contain no more than
15 percent virgin HFC refrigerant, by weight. It is not known how much virgin refrigerant is currently
used for blending with reclaimed refrigerant, and therefore it is assumed that reclaimers will experience
negligible cost impacts associated with this requirement.
Reclaimers are subject to labeling and recordkeeping requirements. Costs for labeling and
recordkeeping are based on the estimated burden time to prepare each reporting element and are discussed
in further detail in the Information Collection Request associated with this rulemaking.
The rulemaking requires the servicing and/or repair of refrigerant-containing appliances in certain
subsectors and applications in the RACHP sector to be done with reclaimed HFCs, including supermarket
systems, refrigerated transport, and automatic commercial ice makers, and the servicing and/or repair of
fire suppression equipment, including both total flooding systems and streaming applications, to be done
with recycled HFCs. Many of the businesses subject to the leak repair and ALD requirements of the
rulemaking would also be impacted by the requirement to use reclaimed or recycled HFCs for
servicing/repair of certain refrigeration appliances and fire suppression equipment. Additional industries
using equipment not covered by the leak repair and ALD provisions (e.g., road transport, intermodal
containers, automatic commercial ice machines, and fire suppression equipment) were also identified.
Small businesses are anticipated to experience costs associated with the requirement to use reclaim
refrigerant for servicing/repair of supermarket systems, refrigerated transport, and automatic commercial
126
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ice makers and recycled agent for servicing/repair of fire suppression equipment.70 Servicing demand for
these appliances and systems estimated by EPA's Vintaging Model was distributed across businesses in
proportion to their annual sales (U.S. Census Bureau 2020) and it was assumed that businesses would
incur a 10 percent price increase per pound of reclaimed or recycled HFCs (i.e., $0.40 per pound based on
an assumed cost of $4 per pound for virgin material).
Small Business Cost Assumptions for Fire Suppression Provisions
The final rulemaking also institutes several additional requirements for fire suppression equipment
containing HFCs. Specifically, fire suppression equipment containing a regulated substance may not
release into the environment, such as by intentional venting during testing and EPA is requiring that all
entities that employ fire suppression technicians who maintain, service, repair, install, or dispose of fire
suppression equipment containing HFCs must provide training. EPA does not anticipate economic
impacts associated with the restriction on intentional releases. Costs associated with technician training
are discussed in further detail in the Information Collection Request associated with this rulemaking.
Furthermore, EPA is requiring that for the fire suppression sector where HFCs are used, the initial
installation of fire suppression equipment, including both total flooding systems and streaming
applications, must be with recycled HFCs, starting on January 1, 2030. A review of HFC fire suppression
manufacturers indicates that 8 are small businesses. Manufacturers are anticipated to experience costs
associated with the requirement to use recycled agent for the initial installation of fire suppression
equipment. Demand for charging new fire suppression equipment estimated by EPA's Vintaging Model
was distributed across businesses in proportion to their annual sales (U.S. Census Bureau 2020) and it
was assumed that businesses would incur a 10 percent price increase per pound of recycled HFCs (i.e.,
$0.40 per pound).
Owners and operators of fire suppression equipment containing HFCs (including an HFC blend)
dispose of this equipment by recovering the HFCs themselves or by arranging for HFC recovery by a fire
suppression equipment manufacturer, distributor, or a fire suppressant recycler. EPA anticipates
negligible to beneficial economic impacts associated with the requirement to recover HFCs from fire
suppression equipment prior to disposal due to already established industry-wide practice to recover fire
suppression agent and the resale value of recovered HFCs.
70 EPA's Vintaging Model does not assume streaming systems are serviced.
127
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Small Business Cost Assumptions for Requiring Heel Recovery from Disposable Cylinders
The regulation also institutes a requirement to recover refrigerant heels from disposable cylinders
(i.e., non-refillable cylinders), which are primarily used to charge and service stationary refrigeration and
air-conditioning systems and fire suppression equipment. Disposable cylinders are specifically
manufactured to be single use. These cylinders are charged with refrigerant, sold for use to fill or service
equipment, and disposed (EIA 2018). Disposable cylinders are typically discarded with amounts of
refrigerants still in the cylinders that will be emitted over time including from amounts commonly
referred to as heels.
EPA is requiring that disposable cylinders that have been used for the servicing, repair, or installation
of refrigerant-containing equipment or fire suppression equipment must be sent to a reclaimer, fire
suppressant recycler, or a final processor for recovery of the heel. EPA is requiring that the recovered heel
must be sent to a reclaimer for further processing.
Small Entities Potentially Subject to Refrigerant Heel Recovery Requirements
The requirement to remove heels from cylinders before disposal would directly impact those
companies that sell or distribute or repackage refrigerant in such cylinders, as these companies would be
required to return their used cylinder to a reclaimer or a final processor for heel recovery prior to disposal.
For this analysis, potentially affected entities are assumed to be producers, importers, exporters,
reclaimers, and companies that sell and distribute HFCs (e.g., blenders, repackagers, and wholesalers or
distributors of refrigerants) and disposal facilities (i.e., landfills or recycling facilities).71 Table G-2 lists
the potentially affected industries by NAICS code and the estimated number of small businesses affected.
Table G-2: List of Industries Potentially Affected by the Provisions on Disposable Cylinders by NAICS
Code
\ (/(\
( ode
Y I/( S Industry Description
She Standard
in Millions oj Dollars
Si:.c Standard in
Sumbcr oj
limployccs
Ustimatcd Snmbcr oj
Small linsincsscs
.\JJ eded
325120
Industrial Gas Manufacturing
1,200
0a
562920
Materials Recovery Facilities
25
964a
71 For the purposes of this analysis, it is conservatively assumed that producers transport refrigerant primarily in containers larger
than 30-lbs. cylinders and therefore the total inventory of 4.45 million disposable refrigerant cylinders, adjusted to account for the
proportion of cylinders containing HFC or HFC blends with a GWP > 53, was distributed across importers, exporters, reclaimers,
and companies that sell and distribute HFCs (e.g., blenders, repackagers, and wholesalers or distributors of refrigerants) defined
by the NAICS codes in Table G-2.
128
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V I/( .V
( ode
V I/( \ Industry Description
Size Standard
in Millions of Dollars
Si:.c Standard in
Sumbcr oj
Umployccs
Ustimatcd X umber oj
Small liusincsscs
AJJcctcd
423740
Refrigeration Equipment and
Supplies Merchant Wholesalers
125
288b
423730
Warm Air Heating and Air-
Conditioning Equipment and
Supplies Merchant Wholesalers
175
l,017b
424690
Other Chemical and Allied
Products Merchant Wholesalers
175
2,755b
562212
Solid Waste Landfill
47
609
238220
Plumbing, Heating, and Air-
Conditioning Contractors
19
49,964
Source: Small Business Size Regulations, 3 CFRPart 121.201 (2023)
a Includes 32 known small business HFC reclaimers in addition to recycling facilities where disposable cylinders may be
sent.
b It was assumed that 50 percent of businesses within these NAICS codes are refrigerant wholesalers and would be directly
affected by the requirement to recover refrigerant heels from cylinders prior to disposal. It is also assumed that the
remaining 50 percent of businesses could be affected by the provisions on disposable cylinders such that they are
considered within the universe of potentially affected entities but are expected to experience minimal economic impacts.
0 It was assumed that 50 percent of businesses within this NAICS code are refrigerant contractors and would be directly
affected by the requirement to provide a certification statement if technicians evacuate a cylinder prior to disposal. It is
assumed that the remaining 50 percent of businesses are other types of contractors (i.e., plumbing) that are not impacted by
the rulemaking.
Estimated Economic Impacts of Requiring Refrigerant Heel Removal from Cylinders prior to
Disposal
For the purposes of quantifying direct compliance costs for this analysis, it was assumed that
producers, importers, exporters, reclaimers, and companies that sell and distribute refrigerant currently
sell refrigerant using 4.455 million disposable cylinders,72 adjusted to the proportion of cylinders
containing HFC and blends containing HFCs versus other non-regulated substances such as
hydrofluoroolefins (HFOs) estimated by EPA's Vintaging Model (EPA 2023f),73 as shown in Table G-3.
72 EPA estimates that there are 4.5 million refrigerant cylinders in circulation per year. Industry estimates that refillable cylinders
account for between less than 1 percent and 10 percent of all 30-pound cylinders used, with a general assumption that the
quantity of refillable cylinders as a percentage of all 30-pound cylinders used is closer to 1 percent (EPA 2024a). For the
purposes of this analysis, it is assumed that 1 percent of all 30-pound cylinders sold in the United States are refillable (i.e.,
45,000) and are therefore excluded from the heel recovery requirement.
73 As explained in the RIA to the Allocation Framework Rule and associated addenda to that RIA, the Vintaging Model estimates
the consumption and emissions from end-uses that traditionally relied on ODS and are transitioning to ElFCs and other
alternatives. The EPA (2023f) version of the model (VMIO file_v4.4_02.04.16_Final TT Rule 2023.xls) incorporates the
transitions and practices anticipated to occur under the 2023 Technology Transitions RIA Base Case, which in turn incorporates
provisions of that rule.
129
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Table (7-3: Assumed Cylinder Refrigerant Mix. 2028-2050
Year
Percent age of
( ylinthrs conluiniii'fi
UK and UK blends
2028
76%
2029
75%
2030
73%
2031
72%
2032
71%
2033
70%
2034
69%
2035
69%
2036
68%
2037
67%
2038
67%
2039
66%
2040
66%
2041
66%
2042
65%
2043
65%
2044
65%
2045
65%
2046
65%
2047
65%
2048
64%
2049
64%
2050
64%
All direct compliance costs are calculated as the difference between costs and savings currently
incurred under the current business-as-usual (BAU) scenario and those estimated to be incurred under the
provisions of the rulemaking.
Cost of transport. In the BAU scenario, disposable cylinders are assumed to travel from gas
producer/filler to the wholesale distributor; wholesale distributor to end user/technician; and end
user/technician to a disposal facility (e.g., landfill or steel recycler).
Transportation costs were updated to account for the distance traveled for each trip and the use of
company fleets to transport cylinders based on a CARB (2011) analysis. It is assumed that companies
already own or lease the proper vehicle fleet to transport cylinders.
Table G-4 summarizes distances per shipment for disposable cylinders. Based on the location of
chemical production facilities around the United States, located primarily along the East Coast, Midwest,
Southern United States, and California, it is assumed that a cylinder would travel an average of 1,000
130
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miles from producer to the wholesale distributor. As assumed in CARB (2011), the distance between
wholesale distributor and end-user/technician is assumed to be 25 miles. Other distances—75 miles from
an end-user or wholesaler to a disposal facility and 50 miles from a distributor to a reclaimer— were also
based on CARB (2011).
In the recovery scenario, it was assumed that approximately one-third of non-refillable cylinders
would take one of three potential transportation scenarios: 1) cylinders would be returned directly to a
reclaimer for heel recovery; 2) cylinders would be returned to the distributor and then to a disposal
facility for heel recovery; or 3) cylinders would be sent directly to a disposal facility for heel recovery.
Upon recovery of the heel, the disposal facility would store recovered refrigerant heels until the facility
has accumulated enough refrigerant to send to a reclaimer. Based on an average heel of 0.96 pounds, it is
assumed that a disposal facility would recover refrigerant from 25 cylinders in order to accumulate
enough to fill one 30-pound cylinder (i.e., 24 pounds of refrigerant).
Table G-4: Travel Distances for Disposable Cylinders Before Disposal
Trip
BAU
Recovery Scenario
Disposable-1"
Disposable-2 "
Disposable-3 "
End-user to
Reclaimer to
Disposal
Facility
End-user to
Distributor to
Disposal
Disposal
Facility to
Reclaimer
End-user to
Disposal
Facility
Disposal
Facility to
Reclaimer
Gas producer/filler
to wholesale
distributor
1,000
1,000
1,000
NA
1,000
NA
Wholesale
distributor to end
user/technician
25
25
25
NA
25
NA
End user/technician
to disposal facility
75
NA
NA
NA
75
NA
End user/technician
to reclaimer
NA
50
NA
NA
NA
NA
End user/technician
to distributor
NA
NA
25
NA
NA
NA
Wholesale
distributor or
reclaimer to
disposal facility
NA
75
75
NA
NA
NA
Disposal facility to
Reclaimer
NA
NA
NA
75b
NA
75b
Total Miles
1,100
1,150
1,125
75
1,110
75
a Assumed for one-third of shipped HFC cylinders.
b Disposal facilities are assumed to recover refrigerant from 25 cylinders before sending one 30-lb cylinder
(containing 24 pounds of refrigerant) to a reclaimer.
Table G-5 provides additional assumptions related to fuel use and labor associated with transporting
cylinders.
131
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Table G-5: Additional Transportation Assumptions
Parameter
.1 ssmnplioii
Average Fuel Efficiency
6.1 miles per gallon3
Diesel Fuel Cost
$4.034/gallonb
Average Truck Speed
50 miles per hour0
Labor Rate (Truck Transport)
$53.59d
a Geotab (2017)
b U.S. EIA (2024)
0 CARB (2011)
d Labor rate for Heavy and Tractor-Trailer Truck Drivers from Bureau of Labor Statistic's Employer
Costs for Employee Compensation - May 2022. Mean hourly wages rates were multiplied by a factor of
2.1 to reflect the estimated additional costs for overhead (BLS 2022).
Transportation costs were then calculated on a per cylinder basis. This analysis conservatively
estimates transportation costs on a per cylinder basis assuming a truck could fit approximately 1,120
disposable cylinders (CARB 2011). Table G-6 summarizes the transport cost per cylinder based on the
assumptions presented above.
To calculate annual transport costs per small business, it was assumed that a total of 4.445 million
disposable cylinders are transported per year (adjusted for the proportion HFC and HFC blends in use per
year, according to Table G- 3) under both the BAU scenario and the provisions of the rulemaking. The
number of cylinders transported before disposal per small business was distributed across businesses in
proportion to their annual sales (U.S. Census Bureau 2020).
Table G-6: Transportation Assumptions before Disposal per Cylinder
Scenario
i'ncl ( osls
l.abor
lot a!
BAU
Disposable
$0.65
$1.05
$1.70
Recovery
Scenario
Disposable-1a
$0.68
$1.10
$1.78
Disposable-2a
$0.66
$1.08
$1.74
Disposable-2
(Disposal Facility )b
$0,002
$0,003
$0,005
Disposable-3a
(End-user)
$0.65
$1.05
$1.70
Disposable-3
(Disposal Facility )b
$0,002
$0,003
$0,005
a Assumed for one-third of HFC cylinders sold per year.
b Disposal facilities are assumed to recover refrigerant from 25 cylinders before sending one
30-lb cylinder (containing 24 pounds of refrigerant) to a reclaimer.
Recovered heel. Under the recovery scenario, disposable cylinders are returned to a reclaimer prior
to disposal containing a refrigerant heel that is recovered and sold back into the market. It was assumed
that cylinders contain a heel of approximately 0.96 pounds based on CARB (2011) and expert judgment.
Recovered refrigerant is assumed to be resold at approximately $4 per pound based on average refrigerant
132
-------
costs applied in EPA (2021a). The total annual savings associated with recovered heel was distributed
across businesses in proportion to their assumed number of cylinders (as estimated under previous steps).
Reporting and Recordkeeping. Under the recovery scenario, companies that sell or distribute or
repackage refrigerant in disposable cylinders, final processors, and refrigerant reclaimers and fire
suppressant recyclers are also subject to reporting and recordkeeping requirements. Specifically, if a
certified technician evacuates a disposable cylinder prior to discarding the cylinder, they must provide a
certification statement certifying that the cylinder was evacuated to a level of 15 in-Hg for each
disposable cylinder handled and discarded to the final processor. The final processor must keep this
record for a period of 3 years. In addition, reclaimers and refrigerant distributors who supply reclaimed
HFCs are subject to a discrete reporting requirement in 2027 and 2028 on the volume of reclaimed HFCs
intended for servicing and/or repair of appliances in use in certain subsectors.
These reporting and recordkeeping costs are based on the estimated burden time to prepare each
reporting element and are discussed in further detail in the Information Collection Request associated
with this rulemaking.
Table G-l summarizes the cost assumptions associated with the requirement to recover the refrigerant
heel from disposable cylinders prior to disposal. Because the proportion of disposable cylinders changes
per year as equipment is assumed to transition towards lower-GWP substitutes that are not regulated by
this rulemaking, the sales test was performed for 2028 for which the highest proportion of HFC cylinders
are assumed in circulation, as shown in Table G-3 (i.e., 76 percent), and therefore the highest potential
cost impacts.
Table G-l: Cost Assumptions for BAU and Rulemaking from Cylinder Heel Recovery Requirement
Assumption
HA I
liulcnuiliiii'fi
Reclaimer
II liolcsalcr or
Distributor
Disposal
i'acilily
licjrixcriml
technician
Number of Disposable Cylinders Disposed (2028)
3,370,585
1,123,528
2,247,057
337,059a
133
-------
.1 SSHIIiplioll
mi
liiilcmuliiii'fi
Reclaimer
H liolesaler or
Distributor
Disposal
i'uciHty
Refrigerant
Technician
Average Transport Cost per Cylinder
$1.70
$1.78
$1.72b
$0.005b
NA
Cylinder Heel Amount (lbs.) and Percent of
Cylinder
0.96 (4%)
0.96 (4%)
0.96 (4%)
0.96 (4%)
0.96 (4%)
Average Refrigerant Price ($/lbs.)
$4
$4
$4
NA
NA
Reporting and
Recordkeeping
Certification of Evacuation to 15-
in Hg (per cylinder)3
NA
NA
NA
NA
$28.93
Recordkeeping of Certification
Statement (per cylinder)3
NA
NA
NA
$1.79
NA
Reclaim Use Volume Reportd
NA
$646.46
$530.21
NA
NA
Labeling and Recordkeeping6
NA
$4,391
NA
NA
NA
a Approximately 10 percent of cylinders are assumed to be emptied directly by the end-user (i.e., refrigerant technician) and
require a certification statement.
b Represents an average of the per-cylinder cost for wholesalers or distributors under disposable scenario 2 ($1.74 per cylinder)
and disposable scenario 3 ($1.70 per cylinder) as shown in Table G-6.
0 Disposal facilities are assumed to recover refrigerant from 25 cylinders before sending one 30-lb cylinder (containing 24
pounds of refrigerant) to a reclaimer.
d Two-time report submitted by reclaimers and refrigerant distributors in 2027 and 2028 only.
e Represents one-time label redesign and recordkeeping costs for reclaimers noted in Section "Small Business Cost
Assumptions for Reclamation and Recycling Provisions."
Summary of Economic Impacts. To inform the sales test, economic data about each affected
industry—including number of firms by employment and receipts size—was obtained from the U.S.
Census Bureau's Statistics of U.S. Businesses. Annualized compliance costs for 2028 for small
businesses in each affected industry were compared to annual sales by firm size, as shown in Table G-8.
As shown, small businesses are expected to experience a positive economic impact (i.e., cost savings) or
impact less than 1 percent of annual sales associated with the requirement to recover heels prior to
cylinder disposal.
134
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Table G- 8: Summary of Annual Economic Impacts from Cylinder Heel Recovery Requirement on Small Businesses by NAICS Code, 2028
\ timber of
Small
liusinesses
Af/ected
Assumed
Annual ( o.st per Small linsiness
Total Annual
( os t per
Small
liusiness
Fmployee Si~e or
Annual Revenue"
¦ 1 venire
Animal Sales
per Firm
( ylinder Fleet
per Firm or
( ylinders
Returned''
¦ 1 venire
Incremental
Annual Transport
Costs
Heel
Savings
Reporting it-
Recordkeeping
Impact as
Percent oj
Annual Sales
l acililies (Reel
timers)
<5
13
$954,057
21
$1
-$81
$5,044
$4,964
0.52%
5-9
10
$2,727,975
60
$2
-$231
$5,044
$4,816
0.18%
10-19
6
$4,487,174
99
$4
-$380
$5,044
$4,668
0.10%
20-99
12
$11,410,450
251
$10
-$966
$5,044
$4,088
0.04%
100-499
1
$22,630,407
499
$19
-$1,915
$5,044
$3,148
0.01%
Ki'lViui'iMiion l-'ipii
imeiil ami Supplies Merchanl NMmleoalero
<5
133
$835,730
18
$1
-$68
$621
$554
0.07%
5-9
63
$4,405,621
97
$4
-$359
$621
$266
0.006%
10-19
42
$7,287,619
161
$6
-$594
$621
$33
<-0.001%
20-99
42
$27,967,987
616
$24
-$2,280
$621
-$1,635
-0.006%
100-149
23
$52,375,136
1,154
$45
-$4,269
$621
-$3,603
-0.007%
011 111 J*1 E(| 111 |)I11 C111
and Supplies Mereliaul Wholesalers
<5
391
$1,435,428
32
$1
-$120
$621
$502
0.03%
5-9
206
$4,027,378
89
$3
-$337
$621
$288
0.007%
10-19
170
$8,824,460
194
$8
-$738
$621
-$109
-0.001%
20-99
214
$28,135,080
620
$24
-$2,352
$621
-$1,707
-0.01%
100-199
36
$74,021,716
1,631
$63
-$6,187
$621
-$5,503
-0.01%
Oilier! Ih-iiik.iI and \lliedI'riiiliK
\ Merchant \\ 1ml
esalers
<5
1,526
$2,142,742
47
$2
-$180
$621
$442
0.02%
5-9
504
$6,251,162
138
$5
-$526
$621
$99.93
0.0016%
10-19
345
$15,508,336
342
$13
-$1,306
$621
-$672
-0.004%
20-99
341
$35,522,558
783
$30
-$2,991
$621
-$2,340
-0.01%
100-149
39
$143,599,156
3,165
$122
-$12,091
$621
-$11,347
-0.01%
135
-------
A umber of
Small
liusinesses
AJ/ected
Assumed
Annual ( ost per Small liusiness
Total Annual
( ost per
Small
liusiness
lunployee Size or
Annual Revenue'
.¦ 1 vernal'
Annual Sales
per i'irm
( y Under i'leel
per i'irm or
( ylinders
lie/timed'
¦ 1 rerage
Incremental
Annual transport
Costs
Heel
Savings
Reporting A!
Recordkeeping
Impact as
Percent oj
Annual Sales
Materials Uccn\on liIios (Rccjclcrs)
<5
380
$954,057
4
$0.02
-
$177
$177
0.02%
5-9
178
$2,727,975
10
$0.05
-
$505
$505
0.02%
10-19
151
$4,487,174
17
$0.08
-
$831
$831
0.02%
20-99
174
$11,410,450
43
$0.20
-
$2,114
$2,114
0.02%
100-499
49
$22,630,407
86
$0.40
-
$4,192
$4,193
0.02%
Solid \\ iistc Landfill
<$100
31
$67,016
1
$0.00
-
$12
$12
0.02%
$100-499
167
$342,772
1
$0.00
-
$63
$64
0.02%
$500-999
114
$898,137
3
$0.01
-
$166
$166
0.02%
$1,000-2,499
132
$1,998,150
8
$0.04
-
$370
$370
0.02%
$2,500-4,999
74
$4,132,387
16
$0.07
-
$766
$766
0.02%
$5,000-7,499
32
$6,717,014
26
$0.12
-
$1,244
$1,244
0.02%
$7,500-9,999
11
$9,181,946
35
$0.16
-
$1,701
$1,701
0.02%
$10,000-14,999
16
$13,290,027
51
$0.24
-
$2,462
$2,462
0.02%
$15,000-19,999
8
$18,042,643
69
$0.32
-
$3,342
$3,343
0.02%
$20,000-24,999
9
$18,842,779
72
$0.33
-
$3,491
$3,491
0.02%
$25,000-29,999
8
$23,202,340
88
$0.41
-
$4,298
$4,299
0.02%
$35,000-39,999
3
$37,499,500°
143
$0.66
-
$6,947
$6,947
0.02%
$40,000-49,999
4
$28,208,524
107
$0.50
-
$5,226
$5,226
0.02%
Refrigerant Technicians'1
<$100
10,648
$59,313
7
-
-
$203
$203
0.34%
$100-499
16,969
$284,372
7
-
-
$203
$203
0.07%
$500-999
8,208
$846,409
7
-
-
$203
$203
0.02%
$1,000-2,499
8,098
$1,836,287
7
-
-
$203
$203
0.01%
136
-------
Employee Si-e or
Annual Revenue'
S umber of
Small
Hu sin esses
Affected
¦ 1 verage
Annual Stiles
per i'irm
Assumed
( y Under i'leel
per I 'irm or
( ylinders
Returned''
Annual
¦ 1 verag e
Ineremenlal
Annual transport
Costs
ost per Small
Heel
Savings
liusiness
Reporting A-
Recordkeeping
Total Annual
( ost per
Small
liusiness
Impact as
Percent of
Annual Sales
$2,500-4,999
3,327
$4,083,819
1
-
-
$203
$203
0.005%
$5,000-7,499
1,209
$7,105,073
1
-
-
$203
$203
0.003%
$7,500-9,999
576
$10,040,971
1
-
-
$203
$203
0.002%
$10,000-14,999
605
$14,071,905
1
-
-
$203
$203
0.001%
$15,000-19,999
326
$19,865,787
1
-
-
$203
$203
0.001%
a In thousands of dollars.
b Disposal facilities are assumed to recover refrigerant from 25 cylinders before sending one 30-lb cylinder (containing 24 pounds of refrigerant) to a reclaimer.
0 Revenue data was not available for businesses in the $35,000-39,999 revenue category. For purposes of the sales test, revenue was estimated as the midpoint of the $35,000-
39,999 revenue range (i.e., $37,499).
d Approximately 10 percent of cylinders are assumed to be emptied directly by the end-user (i.e., refrigerant technician) and require a certification statement. Cylinders were
equally distributed across refrigerant technician businesses under the assumption that the size of the business would not be relevant in the decision-making for a technician to
choose to empty a cylinder directly. Distributing cylinders equally is a more conservative assumption as it assumes a larger number of cylinders are handled by small
businesses than if cylinders were distributed proportional to sales.
137
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Approach for Estimating the Economic Impact on Small Governments
This analysis also uses a model entity approach to estimate impacts on small school districts and small
governments for the leak repair, leak inspection, and recordkeeping and reporting requirements for school
buses and transit buses, respectively.74
In the United States, there are approximately 13,08575 school districts with a total enrollment of 33.1
million students as of 2018 (Urban Institute 2022) and 482,714 yellow school buses76 (EPA 2023f). There
are approximately 57,006 public transit buses in the United States serving over 174 million people in
3,030 cities as of 2017 (GFOA N.d.). This analysis assumes that each school district utilizes school buses
for student transportation, and each city utilizes transit buses for public transportation. Furthermore,
although approximately 40% of school buses and 28% of transit buses are contracted, it is assumed that
costs associated with the rulemaking would be passed down to the individual school districts and cities
(APTA 2023). Therefore, this analysis assumes that every school district and city is potentially impacted
by the rulemaking.
Model Facility and Small Government Cost Assumptions
To analyze and estimate the economic impact of the leak repair and inspection provisions on school and
transit buses, school districts were grouped into ten groups based on enrollment and transit buses were
grouped into thirteen groups based on population. For school districts, the average enrollment, population
within the school district, and revenue for the associated local government of each school district were
determined for each enrollment size. For cities, the average population and revenue for the associated
local government of each city were determined for each population size. Of the ten school enrollment
groups, four were defined as small government with an average population of 50,000 or less and represent
12,187 school districts. Of the thirteen city population groups, four were defined as a small government
with populations less than 50,000 and represent 2,276 cities.
As noted above, there are approximately 482,714 yellow school buses in use in the United States across
13,085 school districts. Approximately 33% of students ride a school bus as their primary means of
transportation (FHWA 2017), which equates to an average of 23students per school bus. With
approximately 51,305 public-owned transit buses, about 5% of the total population utilizes bus transit
74 Approximately 90% of transit buses are assumed to be operated by transit agencies (APTA 2023).
75 56 school districts have an enrollment of 0 students and were therefore not included in this analysis.
76 While federal law does not require school buses to be yellow, the National Highway Traffic Safety Administration
(NHTSA) provides recommendations to states on transportation safety and operational aspects of school buses.
Along with other matters and uniform identifying characteristics, NHTSA recommends that school buses be painted
"National School Bus Glossy Yellow."
-------
(based on commuting patterns from Burrows et al. 2021), which equates to an average of 180 people per
bus.
Table G-9 summarizes the average enrollment, population, revenue, and number of school buses per
school district within the four small government enrollment groups and the average population, revenue,
and number of transit buses per city within the four small government population groups.
Table G-9: School District and City Government Population and Revenue by Enrollment and Population
Size
linrollmcnl
(iroup
\ umber of
Districts
¦ 1 rcra^c
linrollmcnl
ncr District
¦ 1 rcragc
Population
per District
Average Revenue
per District
¦ 1 venire
School liuscs
per District
School Hum's
u-^uu
5,524
1,8 "5
S4 1'X ()(|'J
j
501-999
2,538
712
5,458
$11,246,957
10
1,000-4,999
3,726
2,244
17,058
$37,866,965
33
5,000-9,999
399a
6,930
52,355
$112,226,575
101
Population < iroup
S umber oj
( ities
¦ 1 rcragc
Population
per ( ity
¦I verufie lievenue
per ( ity
¦ 1 venire
Transit liuscs
per ( ity
run sit Muses
lU,000-19,999
1,235
14,128
S29,805,843
4
20,000-29,999
542
24,465
$51,459,646
7
30,000-39,999
314
34,642
$72,953,140
10
40,000-49,999
185
44,702
$99,530,151
13
Bolded rows represent a small government school district.
Source: Urban Institute (2022) and Government Finance Officers Association (n.d.).
a Approximately 59% of the school districts within the 5,000-9,999 enrollment group are below the small government
threshold.
Based on the analysis outlined in Appendix A, 68,158 school buses with charge sizes greater than 15
pounds and 24,147 transit buses are anticipated to exceed the threshold leak rate in 2028, and both are
assumed to experience the leak repair outcomes outlined in Table G-10. Total standard leak repairs are
distributed to every school district and city in proportion to the number of buses each school district and
city uses. Because there are significantly fewer extension and retrofit repairs than standard leak repairs,
extension and retrofit repairs are distributed within each group based on total number of buses within each
group such that some districts and cities within each enrollment and population size will experience
extension and/or retrofit repairs. This analysis therefore assumes that every school district and city
experiences at least one standard leak repair, but not every school district and city is assumed to
experience an extension or retrofit repair.
139
-------
Table G-10: Leak Repair Outcomes per School District or City
¦ 1 verity e
Total School
Standard
Extension
Retrofit
Enrollment
School
School
Hhscs per
Repairs per
Repair per
Repair per
< il'OUp
Districts
Hu m's per
linrollmcnl
School
Enrollment
Enrollment
District
(iron/)
District
< iroup
(iroup
School Buses
0-500
5,524
3
16,572
1
20
23
501-999
2,538
10
25,380
1
30
35
1,000-4,999
3,726
33
122,958
4
147
168
W
|o|
40. :w
14
4X
;v
Population
(iroup
( ities
¦ 1 vera^C
Transit
Hu m's per
(77 r
Total Transit
Hnscs per
Population
< iroup
Standard
Repairs per
City
Extension
Repair per
( ill
Retrofit
Repair per
( ill
Transit Buses
10,000-19,999
1,235
4
4,940
2
20
23
20,000-29,999
542
7
3,794
3
15
17
30,000-39,999
314
10
3,140
4
13
14
40,000-49,999
185
13
2,405
6
10
11
To estimate the economic impact of the leak repair and inspection provisions on school buses, four model
government scenarios were established to represent various combinations of leak repair outcomes for
each school district: standard repair only, standard repair + extension repair, standard repair + retrofit
repair, and standard repair + extension repair + retrofit repair.
The four model governments are established based on the lowest number of repair type instances (in this
case, extension repairs). It was therefore assumed that 50% of extension and retrofit repairs are
experienced by a school district and city in addition to the assumed standard repair(s) for each group (i.e.,
standard repair + extension repair or standard repair + retrofit) and 50% of extension and retrofit repairs
are experienced together by a school district and city in addition to the assumed standard repair(s) for
each group (i.e., standard leak repair + extension repair + retrofit repair). The number of school districts
and cities affected by each leak repair scenario is summarized in Table G-l 1.
Table G-l 1: Number of School Districts and Cities Affected by Leak Repair Scenarios
Enrollment < iroup
School
Districts
Average
School
Huses per
District
\umiter oj School Districts Impacted
Standard
Repair
Only
Standard
+
Extension
Repair
Standard
+ Retrofit
Repair
Standard +
Extension +
Retrofit
Repair
School Buses
0-500
5,524
3
5,491
10
13
10
501-999
2,538
10
2,488
15
20
15
1,000-4,999
3,726
33
3,485
74
95
74
140
-------
5,000-9,999
399
101
320
24
31
24
Population < iroup
( ities
Average
Transit
Buses per
( ity
S umber oj ( ities Impacted
Slant/aril
Repair
Only
Slantlartl
+
Extension
Repair
Standard
+ Retrofit
Repair
Standard +
Hxtension +
Retrofit
Repair
Transit Buses
10,000-19,999
1,235
4
1,204
10
13
10
20,000-29,999
542
7
518
8
10
8
30,000-39,999
314
10
294
7
8
7
40,000-49,999
185
13
169
5
6
5
Cost estimates for each leak repair scenario were applied to each school district and city to evaluate the
burden compared to their average revenue (see Appendix A for discussion of leak repair, leak inspection,
and reporting and recordkeeping cost estimates).
Decision Matrix for Determining Significant Economic Impact on a Substantial
Number of Small Entities
This analysis uses the matrix shown in Table G-12 to determine whether this rulemaking would impose a
SISNOSE. The economic threshold levels are set conservatively at 1% and 3% of sales, consistent with
similar analyses of other Clean Air Act Title VI rules. These thresholds are set conservatively because the
rulemaking affects small businesses in a range of different industries, which may have significantly
different profit margins and abilities to pass compliance costs along to customers, and a range of small
governments with significantly different revenue. Based on this decision matrix, this screening analysis
finds that the rulemaking can be presumed to have no SISNOSE.
Table G-12: Decision Matrix for Certifying SISNOSE
Economic Impact
S umber oj Small Untities
Subject to the Rule untl
Experiencing (iiven
Economic Impact
Percent oj AII Small
Utilities Subject to the Rule
That . Ire Experiencing
< iiven /Economic Impact
( ertijication ( ategory
Less than 1% for all
affected small entities
Any number
Any percent
Presumed No SISNOSE
Fewer than 100
Less than 20%
Presumed No SISNOSE
Fewer than 100
20% or more
Uncertain-No
Presumption
1% or more for one or
more affected small
Between 100 and 999
Less than 20%
Presumed No SISNOSE
entities
Between 100 and 999
20% or more
Uncertain-No
Presumption
1000 or more
Any percent
Uncertain-No
Presumption
141
-------
A umber of Small Entities
Percent of AII Small
Economic Impact
Subject to the little and
Experiencing (iiren
Economic Impact
Entities Subject to the Utile
That Are Experiencing
< iiren Economic Impact
( eiii/ication ( ategory
l ow or than 100
Loss ihaiiJ'0"u
Presumed \o s|s\( )s|;
Fewer than 100
20% or more
Uncertain-No
Presumption
Greater than 3% for one
or more affected small
Between 100 and 999
Less than 20%
Uncertain-No
Presumption
entities
Between 100 and 999
20% or more
Presumed Ineligible for
Certification
1000 or more
Any percent
Presumed Ineligible for
Certification
Aggregate Small Entities Impacts of Regulatory Changes
As shown in Table G-13, an estimated 753,105 small businesses and 14,463 small governments may be
subject to the regulatory actions.
Table (7-13: Summary of the Small Em Hies Impact
.. . Estimated Xumber of Small I
Entities Affected by the liule i
Small Business Industry Type
Accommodations 8.522
Agriculture and Crop Support Services 3.015
Arts. Entertainment, and Recreation 183
Beverage and Ice Manufacturing 424
Charter Bus Industry 920
Disposal and Recycling Facilities 1.541
Durable Goods Wholesalers and Dealers 867
Educational Services 175
Electronics Manufacturing 1.563
Fire Suppression Manufacturers 8
Fitness and Recreational Sports 387
Food manufacturing 3.788
Grocery and Specialty Food Stores 48.556
Hospitals 354
Materials Recovery Facilities (Reclaimers) 32
Non-durable Goods Wholesalers and Dealers 2.364
Non-food Manufacturing 43.271
142
-------
/: n lily
lislimuletl Xmiiber of Small
Untitles [fleeted by the Rule
Office Buildings
9,594
Other Chemical and Allied Products Merchant
Wholesalers
2,755
Other Warehousing, Storage, and Transportation
50.882
Petrochemical Manufacturing
6
Refrigerant Technicians
49,964
Refrigerated Warehousing and Storage
399
Refrigeration Equipment and Supplies Merchant
Wholesalers
280
Restaurants and Food Services
488,180
Support Activities for Transportation
218
Telecommunications and Information Services
29,695
Utilities
4,146
Warm Air Heating and Air-Conditioning Equipment and
Supplies Merchant Wholesalers
1,017
Small Government Type
School Districts
12.187
City Government
2,276
Total
767,568
Totals may not sum due to independent rounding.
To analyze the economic impacts on small entities against the SISNOSE decision matrix, a "sales test"
was applied, which calculates annualized compliance costs as a percentage of annual sales for businesses
in each NAICS code by size category and annual revenue for governments. Total economic impact
includes incremental compliance costs for leak repair and inspection and ALD installation, as well as
compliance costs for reporting and recordkeeping. For industries for which annual sales data were not
available through the Economic Census, annual receipts or annual value of shipments77 was used as a
proxy.
Table G-14 aggregates the estimated economic impacts on small entities, according to the categories set
out in the SISNOSE decision matrix and using a 3% discount rate. Using the decision criteria established
77 Total value of shipments includes the received or receivable net selling values of all products shipped (excluding
freight and taxes).
143
-------
in Table G-14, this screening analysis suggests that this rulemaking can be presumed to have no
SISNOSE for the following reasons:
• About 75,167 small entities (9.8%) are not expected to incur compliance costs.
• About 691,866 small entities (90.1%) are estimated to incur compliance costs that will be less than
1% of annual sales/revenue.
• About 493 of the approximately 767,568 affected small entities (<0.06%) could incur costs in excess
of 1% of annual sales/revenue. Approximately 12 small entities (<0.002%) could incur costs in excess
of 3% of annual sales/revenue. These estimates are below the thresholds for a substantial number
determination (i.e., between 100 and 999 entities and less than 20% of affected entities).
Table G-14: Aggregated Economic Impacts on Small Entities with 3% Discount Rate
Economic Impact
Less than 1% for
all affected small
entitiesa
1: illily Type
S umber oj Small
Untities Subject to the
liule and
/Experiencing (Hvcn
ICconomic Imjuicl
Percent of AII Small
Utilities Subject to the
liule
Accommodations
8.522
Agriculture and Crop Support
Services
3,008
Arts, Entertainment, and
Recreation
181
Beverage & Tcc Manufacturing
417
Charier Bus Industry
83
City Government
2,276
Disposal and Recycling Facilities
1.541
Durable Goods Wholesalers and
Dealers
230
Educational Services
163
Electronics Manufacturing
1.563
Fire Suppression Manufacturers
8
Fitness and Recreational Sports
5
Food Manufacturing
:.i -o
Grocery & Specialty Food Stores
48.338
Hospitals
Materials Recovery Facilities
(Reclaimers)
32
Non-durable Goods Wholesalers
and Dealers
2,327
Non-Food Manufacturing
20.462
Office Buildings
Other Chemical and Allied
Products Merchant Wholesalers
1.778
2,030
Other Warehousing, Storage, and
Transportation
13,721
Petrochemical Manufacturing
6
144
-------
Economic Impact
Utility type
\umber oj Small
Untities Subject to the
liuli• and
lixperienciiifi (iiven
Hconomic Impact
Percent of AII Small
Untities Subject to the
Rule
Refrigerant Technicians
49,964
Refrigerated Warehousing and
Storage
397
Refrigeration Equipment and
Supplies Merchant Wholesalers
238
Restaurants and Food Services
488.180
School Districts
12.187
Support Activities for
Transportation
218
Telecommunications and
Information Services
29,695
Utilities
Warm Air Heating and Air-
Conditioning Equipment and
Supplies Merchant Wholesalers
597
Total
691,908
90.1 "i,
Agriculture and Crop Support
Services
7
Arts, Entertainment, and
Recreation
<5
Beverage & Ice Manufacturing
7
Charter Bus Industry
5
Durable Goods
7
Educational Services
12
1% or more for
one or more
affected small
entities b
Food manufacturing
Grocery & Specially Food Stores
49
T
Non-durable Goods
37
Non-food Manufacturing
72
Office Buildings
17
Other Warehousing, Storage, and
Transportation
38
Refrigerated Warehousing and
Storage
<5
Utilities
25
Total
493
0.06%
Durable Goods
<5
3% or more for
Non-durable Goods
<5
one or more
affected small
entities b
Office Buildings
<5
1 lililies
9
Total
i:
0.01"..
Totals may not sum due to independent rounding.
145
-------
Economic Impact
Utility type
\umber oj Small
Untities Subject to the
liuli• a ntl
lixperienciiifi (iiven
Hconomic Impact
Percent of AII Small
Untities Subject to the
Rule
a Represents small entities affected with an economic impact equal to or less than 1 % but greater than 0%.
Approximately 75,167 affected small businesses—or 9.8 percent—w ould be expected to experience negligible
to net positive (i.e., cost-saving) impacts.
b This category aggregates the number of small entities that would be expected to experience an impact of 1%
to 3% with the number of small entities that would be expected to experience an impact of 3% or greater.
Appendix H. Industries Affected by This Rule
Table H-l: NAICS Classifications of Potentially Affected Entities
NAICS
Code
NAICS Industry Description
236118
Residential Remodelers
236220
Commercial and Institutional Building Construction
238220
Plumbing, Heating, and Air-Conditioning Contractors
238990
All Other Specialty Trade Contractors
146
-------
NAICS
Code
NAICS Industry Description
311812
Commercial Bakeries
321999
All Other Miscellaneous Wood Product Manufacturing
322299
All Other Converted Paper Product Manufacturing
324191
Petroleum Lubricating Oil and Grease Manufacturing
324199
All Other Petroleum and Coal Products Manufacturing
325199
All Other Basic Organic Chemical Manufacturing
325211
Plastics Material and Resin Manufacturing
325412
Pharmaceutical Preparation Manufacturing
325414
Biological Product (except Diagnostic) Manufacturing
325998
All Other Miscellaneous Chemical Product and Preparation Manufacturing
326299
All Other Rubber Product Manufacturing
327999
All Other Miscellaneous Nonmetallic Mineral Product Manufacturing
332812
Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to
Manufacturers
332999
All Other Miscellaneous Fabricated Metal Product Manufacturing
333415
Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
333511
Industrial Mold Manufacturing
333912
Air and Gas Compressor Manufacturing
333999
All Other Miscellaneous General Purpose Machinery Manufacturing
334413
Semiconductor and Related Device Manufacturing
334419
Other Electronic Component Manufacturing
334516
Analytical Laboratory Instrument Manufacturing
335220
Major Household Appliance Manufacturing
336120
Heavy Duty Truck Manufacturing
336212
Truck Trailer Manufacturing
336214
Travel Trailer and Camper Manufacturing
3363
Motor Vehicle Parts Manufacturing
3364
Aerospace Product and Parts Manufacturing
147
-------
NAICS
Code
NAICS Industry Description
336411
Aircraft Manufacturing
336611
Ship Building and Repairing
336612
Boat Building
339112
Surgical and Medical Instrument Manufacturing
339113
Surgical Appliance and Supplies Manufacturing
339999
All Other Miscellaneous Manufacturing
423120
Motor Vehicle Supplies and New Parts Merchant Wholesalers
423450
Medical, Dental, and Hospital Equipment and Supplies Merchant Wholesalers
423610
Electrical Apparatus and Equipment, Wiring Supplies, and Related Equipment Merchant
Wholesalers
423620
Household Appliances, Electric Housewares, and Consumer Electronics Merchant
Wholesalers
423690
Other Electronic Parts and Equipment Merchant Wholesalers
423720
Plumbing and Heating Equipment and Supplies (Hydronics) Merchant Wholesalers
423730
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers
423740
Refrigeration Equipment and Supplies Merchant Wholesalers
423830
Industrial Machinery and Equipment Merchant Wholesalers
423840
Industrial Supplies Merchant Wholesalers
423850
Service Establishment Equipment and Supplies Merchant Wholesalers
423860
Transportation Equipment and Supplies (except Motor Vehicle) Merchant Wholesalers
423990
Other Miscellaneous Durable Goods Merchant Wholesalers
424690
Other Chemical and Allied Products Merchant Wholesalers
424820
Wine and Distilled Alcoholic Beverage Merchant Wholesalers
441310
Automotive Parts and Accessories Stores
443141
Household Appliance Stores
444190
Other Building Material Dealers
445110
Supermarkets and Other Grocery (except Convenience) Stores
445131
Convenience Retailers
445298
All Other Specialty Food Retailers
148
-------
NAICS
Code
NAICS Industry Description
446191
Food (Health) Supplement Stores
449210
Electronics and Appliance Retailers
452311
Warehouse Clubs and Supercenters
453998
All Other Miscellaneous Store Retailers (except Tobacco Stores)
45711
Gasoline Stations With Convenience Stores
481111
Scheduled Passenger Air Transportation
488510
Freight Transportation Arrangement
493110
General Warehousing and Storage
531120
Lessors of Nonresidential Buildings (except Mini warehouses)
541330
Engineering Services
541380
Testing Laboratories
541512
Computer Systems Design Services
541519
Other Computer Related Services
541620
Environmental Consulting Services
561210
Facilities Support Services
561910
Packaging and Labeling Services
561990
All Other Support Services
562111
Solid Waste Collection
562211
Hazardous Waste Treatment and Disposal
562920
Materials Recovery Facilities
621498
All Other Outpatient Care Centers
621999
All Other Miscellaneous Ambulatory Health Care Services
72111
Hotels (Except Casino Hotels) and Motels
72112
Casino Hotels
72241
Drinking Places (Alcoholic Beverages)
722511
Full-service Restaurants
722513
Limited-Service Restaurants
722514
Cafeterias, Grill Buffets, and Buffets
722515
Snack and Nonalcoholic Beverage Bars
149
-------
NAICS
Code
NAICS Industry Description
81119
Other Automotive Repair and Maintenance
811219
Other Electronic and Precision Equipment Repair and Maintenance
811412
Appliance Repair and Maintenance
922160
Fire Protection
Appendix I. Interim SC-HFC Estimates
Note that the tables in this appendix are replicated from Appendix E in the Allocation Framework Rule
RIA updated to 2022$. The SC-HFC estimates are presented in 2022 dollars per metric ton of
HFC emitted by year.
Table 1-1: SC-HFC-32 (2022$)
Discomil mil' iiiul sliilislic
Ye.ir
2.5%
3%
3% «)5lh
Pmvniik'
5%
2020
55,733.93
42,967.93
113,616.38
20,544.57
2021
57554.74
44512.12
117879.01
21468.90
2022
59375.56
46056.31
122141.64
22393.22
2023
61196.37
47600.50
126404.27
23317.55
2024
63017.18
49144.69
130666.89
24241.87
2025
64838.00
50688.88
134929.52
25166.20
2026
66796.16
52358.05
139406.71
26178.20
2027
68754.32
54027.22
143883.90
27190.20
2028
70712.48
55696.40
148361.09
28202.20
2029
72670.64
57365.57
152838.28
29214.19
2030
74628.80
59034.75
157315.47
30226.19
2031
76911.39
61011.37
163114.11
31479.78
2032
79193.98
62987.99
168912.75
32733.37
2033
81476.57
64964.61
174711.39
33986.96
2034
83759.15
66941.23
180510.03
35240.55
2035
86041.74
68917.85
186308.67
36494.13
2036
88481.38
71033.62
192381.37
37843.42
2037
90921.01
73149.39
198454.07
39192.72
2038
93360.65
75265.16
204526.77
40542.01
2039
95800.28
77380.93
210599.47
41891.30
150
-------
2040
98239.92
79496.70
216672.18
43240.59
2041
100811.58
81776.70
223487.96
44792.58
2042
103383.24
84056.70
230303.75
46344.57
2043
105954.90
86336.70
237119.54
47896.57
2044
108526.56
88616.70
243935.33
49448.56
2045
111098.22
90896.70
250751.12
51000.55
2046
113832.31
93321.26
257460.90
52652.80
2047
116566.41
95745.83
264170.69
54305.04
2048
119300.51
98170.39
270880.48
55957.29
2049
122034.61
100594.96
277590.26
57609.53
2050
124768.70
103019.52
284300.05
59261.78
Table 1-2: SC-HFC-125 (2022$)
Discount I'iiic iiiul sliilislic
Ye.ir
2.5%
3%
3% y5"'
Pmvnlik'
5%
2020
321682.24
236106.62
617916.46
92801.00
2021
330113.81
243017.79
637636.30
96408.17
2022
338545.38
249928.97
657356.14
100015.33
2023
346976.95
256840.15
677075.98
103622.49
2024
355408.52
263751.32
696795.82
107229.66
2025
363840.09
270662.50
716515.66
110836.82
2026
372882.44
278100.74
736313.10
114761.22
2027
381924.78
285538.98
756110.54
118685.62
2028
390967.13
292977.21
775907.98
122610.03
2029
400009.48
300415.45
795705.42
126534.43
2030
409051.83
307853.69
815502.85
130458.83
2031
418587.19
315870.10
837880.27
134988.53
2032
428122.56
323886.51
860257.68
139518.24
2033
437657.92
331902.92
882635.10
144047.94
2034
447193.29
339919.33
905012.51
148577.64
2035
456728.65
347935.74
927389.93
153107.34
2036
467095.25
356619.18
951131.37
157996.87
2037
477461.84
365302.62
974872.80
162886.40
2038
487828.43
373986.06
998614.24
167775.93
2039
498195.02
382669.49
1022355.68
172665.46
2040
508561.61
391352.93
1046097.11
177554.99
2041
518723.97
400057.80
1069610.97
182831.16
2042
528886.32
408762.68
1093124.83
188107.32
151
-------
2043 539048.67 417467.55 1116638.70 193383.49
2044
549211.02
426172.42
1140152.56
198659.65
2045
559373.38
434877.30
1163666.42
203935.82
2046
570017.73
444056.32
1186714.87
209553.62
2047
580662.09
453235.35
1209763.32
215171.42
2048
591306.44
462414.37
1232811.77
220789.21
2049
601950.79
471593.40
1255860.21
226407.01
2050
612595.15
480772.42
1278908.66
232024.81
Table 1-3: SC-HFC-134a (2022$)
Discount rule iiiul statistic
Yesir
2.5%
3%
3% <>5"'
I'crcoiilile
5%
2020
128956.54
97527.02
255715.50
42820.40
2021
132802.52
100735.17
264718.10
44616.78
2022
136648.50
103943.32
273720.70
46413.16
2023
140494.48
107151.47
282723.30
48209.55
2024
144340.47
110359.62
291725.90
50005.93
2025
148186.45
113567.77
300728.50
51802.32
2026
152352.92
117050.87
310239.57
53767.99
2027
156519.39
120533.97
319750.63
55733.67
2028
160685.86
124017.07
329261.69
57699.34
2029
164852.34
127500.17
338772.75
59665.02
2030
169018.81
130983.27
348283.82
61630.70
2031
173522.07
134824.42
359243.95
63935.01
2032
178025.34
138665.57
370204.08
66239.33
2033
182528.60
142506.72
381164.21
68543.65
2034
187031.87
146347.87
392124.34
70847.96
2035
191535.13
150189.02
403084.47
73152.28
2036
196341.40
154302.19
414341.34
75637.90
2037
201147.68
158415.37
425598.22
78123.51
2038
205953.95
162528.54
436855.09
80609.13
2039
210760.22
166641.71
448111.96
83094.75
2040
215566.49
170754.89
459368.83
85580.37
2041
220151.85
174773.25
469978.32
88194.69
2042
224737.21
178791.61
480587.82
90809.02
2043
229322.57
182809.97
491197.31
93423.34
2044
233907.93
186828.33
501806.80
96037.67
2045
238493.29
190846.69
512416.29
98651.99
2046 243358.39 195121.15 523311.11 101444.82
152
-------
2047
248223.48
199395.61
534205.92
104237.65
2048
253088.58
203670.07
545100.73
107030.49
2049
257953.68
207944.54
555995.54
109823.32
2050
262818.78
212219.00
566890.36
112616.15
Table 1-4: SC-HFC-143a (2022$)
Discount rsile iiiul statistic
Yesir
2.5%
3%
3% 95"'
Percentile
5%
2020
421132.12
299173.31
783238.95
106080.33
2021
431142.84
307198.96
806745.77
110005.01
2022
441153.56
315224.60
830252.59
113929.69
2023
451164.29
323250.25
853759.41
117854.37
2024
461175.01
331275.89
877266.23
121779.05
2025
471185.74
339301.54
900773.05
125703.73
2026
481799.68
347864.64
923395.31
129951.27
2027
492413.63
356427.74
946017.57
134198.81
2028
503027.57
364990.84
968639.82
138446.35
2029
513641.52
373553.94
991262.08
142693.89
2030
524255.46
382117.03
1013884.34
146941.43
2031
535361.32
391278.26
1038533.32
151839.09
2032
546467.18
400439.49
1063182.30
156736.75
2033
557573.04
409600.72
1087831.27
161634.40
2034
568678.90
418761.95
1112480.25
166532.06
2035
579784.75
427923.18
1137129.23
171429.72
2036
591602.07
437692.16
1162875.92
176677.98
2037
603419.40
447461.14
1188622.60
181926.23
2038
615236.72
457230.12
1214369.29
187174.49
2039
627054.04
466999.10
1240115.98
192422.75
2040
638871.36
476768.08
1265862.66
197671.01
2041
650640.86
486712.46
1293311.44
203452.05
2042
662410.35
496656.84
1320760.22
209233.09
2043
674179.85
506601.23
1348209.00
215014.13
2044
685949.35
516545.61
1375657.78
220795.17
2045
697718.84
526489.99
1403106.56
226576.21
2046
710175.88
537037.69
1431859.80
232726.23
2047
722632.92
547585.38
1460613.04
238876.25
2048
735089.95
558133.08
1489366.29
245026.27
2049
747546.99
568680.77
1518119.53
251176.30
2050
760004.02
579228.46
1546872.77
257326.32
153
-------
Table 1-5: SC-HFC-152a (2022$)
Discount I'iiic iind sliilislic
3V » «>5"'
Ye.ir
2.5'Vi.
JV-'ii
IVrcenlilc
5"i.
2020
7756.57
6000.16
15853.35
2938.14
2021
8011.03
6217.38
16457.20
3071.55
2022
8265.50
6434.60
17061.05
3204.96
2023
8519.96
6651.82
17664.91
3338.38
2024
8774.42
6869.04
18268.76
3471.79
2025
9028.88
7086.26
18872.61
3605.21
2026
9304.30
7322.12
19493.32
3751.50
2027
9579.73
7557.99
20114.03
3897.79
2028
9855.15
7793.86
20734.74
4044.08
2029
10130.57
8029.73
21355.45
4190.38
2030
10406.00
8265.59
21976.16
4336.67
2031
10731.00
8548.40
22805.88
4519.51
2032
11056.01
8831.21
23635.59
4702.35
2033
11381.01
9114.02
24465.31
4885.19
2034
11706.01
9396.83
25295.02
5068.03
2035
12031.02
9679.64
26124.74
5250.87
2036
12378.80
9982.48
26985.45
5447.56
2037
12726.58
10285.31
27846.17
5644.26
2038
13074.37
10588.15
28706.88
5840.95
2039
13422.15
10890.99
29567.60
6037.65
2040
13769.93
11193.83
30428.32
6234.34
2041
14184.53
11559.71
31588.17
6482.08
2042
14599.12
11925.58
32748.03
6729.82
2043
15013.71
12291.46
33907.88
6977.56
2044
15428.31
12657.33
35067.74
7225.30
2045
15842.90
13023.21
36227.59
7473.03
2046
16279.77
13409.45
37375.91
7735.42
2047
16716.64
13795.69
38524.22
7997.81
2048
17153.51
14181.93
39672.54
8260.20
2049
17590.38
14568.18
40820.85
8522.59
2050
18027.25
14954.42
41969.17
8784.98
154
-------
Table 1-6: SC-HFC-227ea (2022$)
Discount rule iiiul statistic
Yesir
2.5"/,
3%
3% 95"'
I'crconlile
5%
2020
297055.07
216155.46
566455.49
82545.11
2021
304615.60
222319.00
583582.24
85705.12
2022
312176.14
228482.54
600708.99
88865.14
2023
319736.68
234646.07
617835.74
92025.15
2024
327297.22
240809.61
634962.49
95185.17
2025
334857.75
246973.15
652089.25
98345.18
2026
342938.85
253590.74
669863.24
101778.56
2027
351019.95
260208.32
687637.24
105211.95
2028
359101.05
266825.91
705411.23
108645.33
2029
367182.15
273443.50
723185.23
112078.72
2030
375263.25
280061.09
740959.23
115512.10
2031
383757.34
287172.74
760683.78
119472.00
2032
392251.43
294284.39
780408.34
123431.90
2033
400745.53
301396.05
800132.90
127391.81
2034
409239.62
308507.70
819857.46
131351.71
2035
417733.71
315619.36
839582.01
135311.61
2036
426854.89
323251.93
860042.27
139569.23
2037
435976.06
330884.50
880502.52
143826.85
2038
445097.23
338517.07
900962.77
148084.47
2039
454218.40
346149.64
921423.03
152342.09
2040
463339.57
353782.21
941883.28
156599.71
2041
472317.41
361466.19
961555.81
161220.41
2042
481295.25
369150.17
981228.35
165841.11
2043
490273.09
376834.15
1000900.88
170461.81
2044
499250.93
384518.13
1020573.42
175082.51
2045
508228.77
392202.11
1040245.95
179703.20
2046
517791.18
400395.42
1061935.84
184636.50
2047
527353.59
408588.73
1083625.74
189569.80
2048
536916.00
416782.04
1105315.63
194503.10
2049
546478.41
424975.35
1127005.53
199436.40
2050
556040.82
433168.66
1148695.42
204369.70
155
-------
Table 1-7: SC-HFC-236fa (2022$)
Discuunl I'iilc iind sliilislic
Ye.ir
2.5";.
yv»
JV'i, ,)5lh
Perccnlik'
5"i.
2020
1088012.51
711629.23
1871276.22
204546.68
2021
1109343.77
727899.70
1917560.99
211581.34
2022
1130675.03
744170.17
1963845.75
218616.00
2023
1152006.30
760440.64
2010130.52
225650.66
2024
1173337.56
776711.11
2056415.29
232685.32
2025
1194668.83
792981.57
2102700.05
239719.98
2026
1217267.97
810303.11
2149615.48
247294.82
2027
1239867.12
827624.64
2196530.90
254869.67
2028
1262466.26
844946.17
2243446.33
262444.51
2029
1285065.40
862267.70
2290361.76
270019.35
2030
1307664.55
879589.24
2337277.18
277594.19
2031
1331403.16
898146.01
2391611.16
286386.37
2032
1355141.77
916702.79
2445945.13
295178.55
2033
1378880.39
935259.56
2500279.11
303970.72
2034
1402619.00
953816.34
2554613.08
312762.90
2035
1426357.61
972373.12
2608947.06
321555.08
2036
1451306.91
991960.75
2665502.72
330905.26
2037
1476256.21
1011548.39
2722058.39
340255.44
2038
1501205.50
1031136.02
2778614.05
349605.62
2039
1526154.80
1050723.66
2835169.72
358955.81
2040
1551104.10
1070311.29
2891725.38
368305.99
2041
1576689.31
1090753.23
2950311.80
378894.63
2042
1602274.52
1111195.18
3008898.23
389483.28
2043
1627859.73
1131637.12
3067484.65
400071.93
2044
1653444.95
1152079.06
3126071.07
410660.57
2045
1679030.16
1172521.00
3184657.49
421249.22
2046
1705768.95
1193986.92
3244613.16
432431.27
2047
1732507.75
1215452.83
3304568.83
443613.32
2048
1759246.54
1236918.74
3364524.50
454795.37
2049
1785985.34
1258384.65
3424480.18
465977.43
2050
1812724.13
1279850.56
3484435.85
477159.48
156
-------
Table 1-8: SC-HFC-245fa (2022$)
Discount I'iilc iiiul sliilislic
3'!'!. 95"'
Ye.ir
2.5'r;,
3 "¦;>
I'mvnlile
5"'i.
2020
89468.00
68623.70
180669.87
32002.52
2021
92309.89
71025.77
187355.76
33413.51
2022
95151.78
73427.84
194041.64
34824.49
2023
97993.67
75829.91
200727.53
36235.47
2024
100835.57
78231.98
207413.41
37646.46
2025
103677.46
80634.05
214099.30
39057.44
2026
106746.93
83237.14
221092.99
40601.70
2027
109816.41
85840.24
228086.68
42145.96
2028
112885.88
88443.34
235080.38
43690.22
2029
115955.36
91046.44
242074.07
45234.48
2030
119024.84
93649.54
249067.76
46778.74
2031
122498.30
96647.08
257844.49
48651.65
2032
125971.76
99644.61
266621.22
50524.56
2033
129445.22
102642.15
275397.95
52397.47
2034
132918.68
105639.69
284174.67
54270.39
2035
136392.14
108637.22
292951.40
56143.30
2036
140152.58
111877.65
302104.63
58168.31
2037
143913.02
115118.08
311257.87
60193.32
2038
147673.45
118358.51
320411.10
62218.32
2039
151433.89
121598.93
329564.33
64243.33
2040
155194.33
124839.36
338717.56
66268.34
2041
158869.74
128085.15
347843.81
68456.07
2042
162545.16
131330.93
356970.05
70643.79
2043
166220.58
134576.72
366096.30
72831.52
2044
169895.99
137822.50
375222.54
75019.24
2045
173571.41
141068.29
384348.79
77206.96
2046
177533.63
144563.42
393792.21
79557.03
2047
181495.86
148058.56
403235.62
81907.09
2048
185458.08
151553.70
412679.04
84257.16
2049
189420.31
155048.84
422122.46
86607.23
2050
193382.53
158543.98
431565.88
88957.29
157
-------
Table 1-9: SC-HFC-43-10mee (2022$)
Discount rule iind sliitislic
3% <)5"'
Year
2.5"/,,
3"»
IVrccnlik'
5"i.
2020
148861.07
112098.04
293905.01
48396.89
2021
153189.60
115704.38
303937.05
50397.59
2022
157518.13
119310.71
313969.08
52398.29
2023
161846.66
122917.04
324001.11
54399.00
2024
166175.18
126523.38
334033.15
56399.70
2025
170503.71
130129.71
344065.18
58400.40
2026
175209.52
134052.62
354910.00
60589.73
2027
179915.33
137975.52
365754.83
62779.05
2028
184621.14
141898.43
376599.65
64968.38
2029
189326.94
145821.33
387444.47
67157.71
2030
194032.75
149744.24
398289.30
69347.03
2031
199086.33
154044.72
410454.48
71902.31
2032
204139.91
158345.21
422619.66
74457.59
2033
209193.49
162645.69
434784.85
77012.87
2034
214247.07
166946.18
446950.03
79568.15
2035
219300.64
171246.66
459115.21
82123.42
2036
224676.69
175840.53
471633.00
84877.15
2037
230052.73
180434.41
484150.78
87630.88
2038
235428.77
185028.28
496668.56
90384.61
2039
240804.81
189622.15
509186.34
93138.33
2040
246180.86
194216.03
521704.12
95892.06
2041
251333.77
198722.44
533472.51
98795.21
2042
256486.69
203228.85
545240.89
101698.35
2043
261639.61
207735.27
557009.28
104601.49
2044
266792.53
212241.68
568777.66
107504.64
2045
271945.45
216748.09
580546.05
110407.78
2046
277436.76
221555.48
592857.92
113511.21
2047
282928.07
226362.87
605169.80
116614.65
2048
288419.39
231170.26
617481.67
119718.08
2049
293910.70
235977.65
629793.55
122821.51
2050
299402.01
240785.04
642105.42
125924.94
158
-------
Table I-10: SC-HFC-23 (2022$)
Discount rule iind sliilislic
Ye.ir
2.5'Vii
JV-ii
i"/„ y?"'
Pormilik'
5%
2020
1660692.00
1081400.12
2873037.41
307668.79
2021
1693043.33
1106002.65
2942537.52
318230.46
2022
1725394.67
1130605.18
3012037.62
328792.13
2023
1757746.01
1155207.71
3081537.72
339353.80
2024
1790097.35
1179810.24
3151037.83
349915.47
2025
1822448.69
1204412.77
3220537.93
360477.14
2026
1856630.60
1230554.11
3292420.73
371844.71
2027
1890812.51
1256695.46
3364303.54
383212.29
2028
1924994.42
1282836.81
3436186.35
394579.86
2029
1959176.32
1308978.15
3508069.15
405947.44
2030
1993358.23
1335119.50
3579951.96
417315.01
2031
2029297.80
1363149.94
3662535.07
430524.12
2032
2065237.36
1391180.39
3745118.17
443733.22
2033
2101176.93
1419210.84
3827701.28
456942.33
2034
2137116.49
1447241.28
3910284.39
470151.43
2035
2173056.06
1475271.73
3992867.50
483360.54
2036
2210881.02
1504905.18
4077606.29
497436.61
2037
2248705.98
1534538.63
4162345.07
511512.68
2038
2286530.94
1564172.08
4247083.86
525588.75
2039
2324355.91
1593805.53
4331822.65
539664.81
2040
2362180.87
1623438.98
4416561.43
553740.88
2041
2400988.05
1654369.62
4507297.75
569678.01
2042
2439795.23
1685300.26
4598034.07
585615.13
2043
2478602.40
1716230.90
4688770.38
601552.25
2044
2517409.58
1747161.54
4779506.70
617489.38
2045
2556216.76
1778092.18
4870243.01
633426.50
2046
2596764.24
1810549.89
4963028.17
650233.41
2047
2637311.71
1843007.60
5055813.32
667040.33
2048
2677859.19
1875465.31
5148598.47
683847.25
2049
2718406.67
1907923.02
5241383.62
700654.16
2050
2758954.14
1940380.73
5334168.77
717461.08
159
-------
Appendix J. Updated SC-GHG Estimates
EPA calculated updated estimates of the SC-HFCs consistent with the methodology set forth in the EPA
Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances
(EPA, 2023c). See EPA (2023c) for a full explanation of the updated methodology and how the updated
SC-GHG estimates differ from those produced under the IWG-SCGHG (2021) methods. To recover
updated estimates of the SC-HFCs for this rule consistent with EPA (2023c), several modifications were
necessary. First, background emissions trajectories for HFC-236fa were added to the climate module
(FaIRl.6.2) using the SSP2-4.5 storyline scenario; the other 7 HFCs affected by this rule were already
contained within the climate module and are also drawn from SSP2-4.5. Second, the sea-level rise module
underlying the DSCIM damage module (FACTS) has been updated to directly estimate changes in sea-
level rise from probabilistic socioeconomics and emissions scenarios (i.e., RFF-SPs), as opposed to the
use of an emulator as was done in EPA (2023c). Additional documentation and full replication of the
models and their estimates are available at www.github.com/USEPA/schfc as well as in the docket.78
Table J-l presents the climate benefits from the final ER&R Rule using the updated SC-HFC estimates
for each gas in 2022$.
Table J-l: UndiscountedMonetized Climate Benefits (2022$)a-h-c
Husc ( use
Incremental ( linuilc Hcnc/hs (million* 2022S)
Scar-Term Htnnscy Discount Hate
Year
- o
:.5"„
2024
$0.00
$0.00
$0.00
2025
$0.00
$0.00
$0.00
2026
$1,000.00
$710.00
$530.00
2027
$1,200.00
$830.00
$620.00
2028
$1,600.00
$1,100.00
$850.00
2029
$1,600.00
$1,100.00
$850.00
2030
$1,500.00
$1,100.00
$840.00
2031
$1,500.00
$1,100.00
$840.00
2032
$1,500.00
$1,100.00
$830.00
2033
$1,500.00
$1,100.00
$830.00
2034
$1,400.00
$1,100.00
$810.00
2035
$1,400.00
$1,000.00
$780.00
2036
$1,300.00
$970.00
$750.00
2037
$1,200.00
$920.00
$710.00
2038
$1,200.00
$870.00
$680.00
2039
$1,100.00
$820.00
$640.00
78 GLOBAL 2023 AIM.xlsx
160
-------
2040
$1,000.00
$770.00
$600.00
2041
$960.00
$720.00
$570.00
2042
$870.00
$660.00
$520.00
2043
$790.00
$600.00
$470.00
2044
$720.00
$550.00
$440.00
2045
$670.00
$510.00
$410.00
2046
$620.00
$480.00
$380.00
2047
$580.00
$450.00
$360.00
2048
$550.00
$430.00
$350.00
2049
$530.00
$410.00
$340.00
2050
$520.00
$410.00
$340.00
PV
$22,000.00
$15,000.00
$11,000.00
EAV
$1,100.00
$790.00
$610.00
a Rows may not appear to add correctly due to rounding.
b Present values are calculated using end of year discounting.
c The equivalent annual values of benefits are calculated over a 25-year period.
Appendix K. Cost of Reclaim/Recycled HFCs Sensitivity Results
In the base case scenario, EPA assumed reclaimed/recycled HFCs to be 10% more expensive than virgin
HFCs. This was chosen as a conservative measure to prevent underestimating the total cost. However, as
pointed out by comments received under the Notice of Proposed Rulemaking (NPRM), the cost of reclaim
may be closer to parity with virgin manufacture. Thus, EPA ran an additional analysis where
reclaimed/recycled HFCs cost were equivalent to virgin HFCs. The results for this analysis are shown in
Table K-l.
Table K-l: Difference in annual incremental cost for all MAC options for different reclaim costs
(millions of2022$, discounted to 2024)a-b-c
( ost of Reclaim
Sensitivity. \n a lysis
Year
Reclaim > Virgin (liase Case)
Reclaim = Virgin
% Change
2026
$79.71
$79.52
-0.2%
2027
$111.60
$111.40
-0.2%
2028
$93.49
$93.28
-0.2%
2029
$95.06
$91.42
-3.8%
2030
$93.05
$88.95
-4.4%
2031
$90.45
$86.49
-4.4%
2032
$87.51
$83.69
-4.4%
2033
$84.71
$81.01
-4.4%
2034
$83.03
$79.46
-4.3%
161
-------
2035
$79.05
$75.58
-4.4%
2036
$75.15
$71.79
-4.5%
2037
$71.65
$68.41
-4.5%
2038
$68.09
$64.95
-4.6%
2039
$64.46
$61.44
-4.7%
2040
$60.77
$57.87
-4.8%
2041
$57.99
$55.22
-4.8%
2042
$53.45
$50.79
-5.0%
2043
$49.80
$47.22
-5.2%
2044
$47.86
$45.26
-5.4%
2045
$46.22
$43.60
-5.7%
2046
$46.01
$43.37
-5.7%
2047
$45.90
$43.24
-5.8%
2048
$45.91
$43.22
-5.9%
2049
$46.02
$43.31
-5.9%
2050
$46.24
$43.51
-5.9%
DR
/
M* /
/7& '
2% /
3%
7% /
3%
f
PV
$1,343
$1,196
$790
$1,292
$1,151
$764
-3.8%
-3.7%
-3.4%
EAV
$68.80
$68.69
$67.80
$66.17
$66.13
$65.52
-3.8%
-3.7%
-3.4%
a The first scenario represents the base case which assumes a 10% markup on the cost of reclaim. The second
scenario assumes the reclaim and virgin HFCs are equivalent in cost.
b Present values are calculated using end of year discounting.
c The equivalent annual values of benefits are calculated over a 25-year period.
When assuming reclaim parity with virgin, annual incremental costs fall by $0.11 M to $2.44 M (0% to
5% decrease). However, when compared to the total cost of the rule this represents only a marginal
decrease of -2%.
162
-------
Appendix L. Alternative Equipment Age Requirements for ALD
The EPA considered different equipment age cutoffs for the ALD requirement in this rule beyond new CR and IPR refrigerant-containing
appliances, which are required to install the ALD system within 30 days of installation. Additional analyses were with equipment age thresholds of
5 years and all existing equipment in addition to the base case (10 years before the January 1, 2027 compliance date). Results are summarized in
Table L-l.
Table L-l: Difference in annual incremental cost for all MAC options for different equipment age cutoffs for the ALD requirement
(millions of2022$, discounted to 2024)
. \/tentative l^iiii/micnt. Ii/e Requirements for A/J)
Sensitivity. \nalysis
( ost (2022S)
"» C 'hange from fiase ( ase
) ear
2d r+
(Base Case)
2021+
. Ml Llxistin'f;
2021+
. Ml Llxistin'f;
2026
$80
$80
$80
0.0%
0.0%
2027
$112
$92
$148
-17.4%
32.9%
2028
$93
$84
$144
-9.6%
54.0%
2029
$95
$86
$142
-9.4%
49.8%
2030
$93
$84
$137
-9.6%
47.5%
2031
$90
$82
$131
-9.8%
45.4%
2032
$88
$79
$125
-10.1%
43.2%
2033
$85
$76
$119
-10.4%
40.7%
2034
$83
$73
$113
-11.8%
35.9%
2035
$79
$70
$106
-10.8%
34.5%
2036
$75
$68
$100
-9.9%
32.7%
2037
$72
$65
$94
-8.7%
30.5%
2038
$68
$63
$87
-7.4%
28.0%
2039
$64
$61
$81
-6.0%
25.2%
2040
$61
$57
$74
-6.3%
22.0%
-------
2041
$58
$53
$67
-8.3%
16.2%
2042
$53
$50
$61
-7.2%
13.9%
2043
$50
$47
$56
-5.6%
11.7%
2044
$48
$46
$53
-3.7%
10.5%
2045
$46
$45
$51
-1.8%
9.5%
2046
$46
$46
$50
0.0%
8.3%
2047
$46
$46
$49
0.0%
7.4%
2048
$46
$46
$49
0.0%
6.6%
2049
$46
$46
$49
0.0%
6.0%
2050
$46
$46
$49
0.0%
5.7%
DR
2% /
M* /
/Tfaf
2%
3%
7%*/
2%
3%
f
AW/
3%
2%
3%
PV
$1,343
$1,196
$790
$1,235
$1,098
$721
$1,746
$1,563
$1,048
-8%
-18%
-46%
30%
16%
-22%
EAV
$69
$69
$68
$63
$63
$62
$89
$90
$90
-8%
-8%
-10%
30%
30%
31%
164
-------
Appendix M. Disposable Cylinder Management
Introduction
Most HFCs, including those used as refrigerants, are gases at room temperature and are typically
transported and stored as compressed liquids in pressurized metal containers called cylinders. There are
two primary types of cylinders. Disposable (also known as non-refillable or single-use or DOT-39)
cylinders are used once before disposal, whereas refillable cylinders can be used multiple times
throughout the cylinder lifetime. Disposable cylinders today are typically discarded with refrigerants still
in the cylinders, including from amounts commonly referred to as heels (i.e., the small amount of
refrigerant that remains in an "empty" cylinder). These residual refrigerants are emitted over time as they
leak out or are expelled when the cylinder is crushed for disposal or metal recycling. So-called "30-
pound" metal cylinders are most often disposable but may come in refillable designs as well and are used
primarily in the stationary air-conditioning and refrigeration system servicing industry and, to a lesser
extent, in motor vehicle air conditioning.
The provisions of this rule include requirements to remove the heel from used disposable cylinders before
the cylinders are discarded; the requirement covers disposable cylinders used for servicing, repair,
disposal, or installation of equipment. Both disposable and refillable cylinders will be available for
transporting refrigerant; however, it is expected that refillable cylinders are returned and refilled several
times in the baseline, and that no additional costs or benefits from refillable cylinders result based on this
rule. For analytical purposes, the Agency focused on anticipated additional reductions in HFC
consumption and emissions as well as industry costs and the potential savings from avoided refrigerant
loss from disposable cylinders.
EPA has prepared a report, Refrigerant Cylinders: Analysis of Use, Disposal, and Distribution of
Refrigerants (EPA 2024a), analyzing the costs and benefits of the requirement that disposable cylinders
that have been used for the servicing, repair, or installation of refrigerant-containing equipment be
transported to an EPA-certified reclaimer, and that reclaimers or another final processor within the supply
and disposal chain remove all HFCs (i.e., heel) from disposable cylinders prior to discarding the cylinder.
If the heel is removed by a final processor or otherwise in the supply chain, the removed heels may be
consolidated, but must be sent to an EPA-certified reclaimer or fire suppressant recycler. This appendix
presents a summary of some of the results from this report and provides further analysis.
Emission Estimates for Recovery of Disposable Cylinder Heels
-------
The report assesses the typical distribution of refrigerants in cylinders, including refrigerant changes
expected under the Base Case for this rule. Heels remaining in disposable cylinders were determined
through both a theoretical and empirical study. Based on the wide range of disposal practices currently
employed and expected to continue in absence of this final rule, three scenarios were developed to
estimate the emissions avoided: a central scenario, a low scenario (i.e., a lower heel left in the cylinder),
and a high scenario.
The emissions avoided by removing such heels are dependent on the number of disposable cylinders in
circulation and the average heel that would otherwise be emitted in absence of this rule. Based on the
report cited above, we assume in the central scenario that there are approximately 4.5 million cylinders in
circulation, of which 99% are disposable. Further, we estimate that the average heel is approximately 4%
by weight of the nominal capacity (e.g. 0.96 pounds for a 24-pound cylinder).79 We use a heel of 0.288
pounds (1.2 percent) and 1.65 pounds (6.875 percent) for the low and high scenarios, respectively.
Because of the other regulations in place, it is expected that the average GWP of the refrigerant in such
cylinders will decrease. Other emissions associated with cylinders—for example, during transport and
storage—are not expected to change based on this rule. Based on the expected transitions from these
regulations, Table M-l, below, presents the avoided emissions for the years 2028 through 2050.
Table M-l: Estimated Annual Emission Changes Compared with BAU, 2028-2050
Year
Average HFC
GWP
Emission Reductions Relative to BAU (MMTC():e)
Central
Low
High
2028
1,547
2.27
0.68
3.90
2029
1,498
2.17
0.65
3.73
2030
1,445
2.06
0.62
3.54
2031
1,390
1.95
0.59
3.35
2032
1,332
1.84
0.55
3.17
2033
1,274
1.74
0.52
2.99
2034
1,210
1.63
0.49
2.80
2035
1,142
1.52
0.46
2.61
2036
1,071
1.41
0.42
2.42
2037
1,002
1.31
0.39
2.25
2038
945
1.22
0.37
2.10
2039
900
1.16
0.35
1.99
2040
872
1.12
0.33
1.92
2041
843
1.07
0.32
1.84
2042
814
1.03
0.31
1.11
2043
788
0.99
0.30
1.71
2044
769
0.97
0.29
1.66
79 R-404A is typically sold in a 24-pound cylinder. Cylinders for other HFC refrigerants are typically larger, from 25 to 50
pounds. We use 24 pounds as a conservative estimate here.
166
-------
Year
Average HFC
GWP
Emission Reductions Relative to BAU (MMTCOze)
Central
Low
High
2045
753
0.94
0.28
1.62
2046
742
0.93
0.28
1.60
2047
733
0.92
0.28
1.58
2048
726
0.91
0.27
1.56
2049
720
0.90
0.27
1.55
2050
111
0.90
0.27
1.54
Total
30.96
9.29
53.21
Cost Estimates for Recovery of Disposable Cylinder Heels
The report also assesses the cost implications for the requirement for heel removal, accounting for the
costs associated with the change in procedure handling of cylinders (i.e., returning the cylinders for heels
to be removed) and the potential savings from avoided refrigerant loss from heel emissions. There are
multiple paths that the cylinder may take before the heel is removed and the truly-empty cylinder is
landfilled or recycled. This analysis assumes that some cylinders will be: (a) sent directly to the reclaimer;
(b) returned to a wholesaler or distributor,80 who will ship disposable cylinders to a landfill or steel
recycling facility, which would combine heels for shipment to a reclaimer; and (c) shipped directly from
the end-user or technician to a landfill or steel recycling facility, which would combine heels for shipment
to a reclaimer. For paths (b) and (c) above, we assume the landfill or steel recycling facility would reduce
costs by combining 25 refrigerant heels (at 0.96 pounds as discussed above) of each HFC or HFC
substitutes containing an HFC (e.g., HFC/HFO blends) they receive into individual 24-pound cylinders
before sending those to a reclaimer. After recovering heels, reclaimers are assumed to send disposable
cylinders to a landfill or steel recycler.
Neat HFOs, which are not regulated substances under this rulemaking but are used in some RACHP
equipment, are not accounted for in the analysis. For HFCs and HFC/HFO blends, we divide cylinders
equally amongst the transportation paths described above. Thus, we assume one-third follow path (a),
one-third follow path (b), and one-third follow patch (c). Table M-2 displays the estimated mileage for
each leg of the paths taken compared to the business-as-usual (BAU) route.
80 Wholesalers and distributors could also perform the heel recovery, and likewise amass heels into a single cylinder
to be shipped to a reclaimer. Based on comments to the NPRM that indicate an economic disincentive to doing that
at a wholesaler/distributor facility, we assume cylinders with heels received by these entities are shipped directly to
the landfill or steel recycler.
167
-------
Table M-2: Estimated Distances for Disposable Cylinder Transportation Compared with BA U
(Miles)"
Transportation Leg
BAU
(a) End-user
to Reclaimer
to Landfill
(b) End-user
to
Distributor
to Reclaimer
End-user
to Landfill
Producer/Filler to Wholesale Distributor
1,000
1,000
1,000
1,000
Wholesale Distributor to End User/Technician
25
25
25
25
End User/Technical to Steel Recycler/Landfill
75
NA
NA
75
End User/Technical to Reclaimer
NA
50
NA
NA
End User/Technical to Wholesale Distributor
NA
NA
25
NA
Reclaimer to Steel Recycler/Landfill
NA
75
75
NA
landfill scndinu Rea»\ eivd RclYiucniil In Rcchima'
X\
X\
~s
~s
Tohil Miles per ( \Under
1.100
1.150
I.I2X
1.103
a CARB (2011)
bEach cylinder sent represents 25 cylinders received with heels (Central scenario).
The additional travel costs are influenced by how many cylinders fit on a truck, the fuel to drive the extra
distances, and the incremental labor for such. By removing heels that would have otherwise been emitted,
an additional supply is provided that would offset virgin production providing additional benefits based
on the cost of refrigerant. These assumptions are shown in Table M-3 below.
Table M-3: Additional Disposable Cylinder Cost Assumptions
Factor (units)
Value
Source
Notes
Cylinders per Truck
1,120
CARB (2011)
Average Truck Speed (miles per hour)
50
CARB (2011)
Truck Transport Labor Rate ($/hour)
$53.59
U.S. Bureau of Labor
Statistics (2023)
May 2022 mean, including
110% overhead
Average Fuel Consumption (miles per gallon)
6.1
Geotab (2017)
Average across all states
Fuel cost ($/gallon)
$4,034
U.S. EIA (2024)
Price of diesel as of March
25, 2024
Cost of HFC refrigerant ($/pound)
$4
Consistent with past AIM
Act analyses
Accounting for the fuel and labor associated with the additional shipment of cylinders and the cost of
refrigerants, we estimate costs and benefits, and hence the net benefits, as shown in Table M-4 for the
Central scenario.
168
-------
Table M-4: Costs, Benefits, and Net Benefits of Cylinder Management (Central Scenario)
(Millions 2022$)a-b
Year
Benefits
Costs
Net Benefits
2028
$12.94
$0.14
$12.80
2029
$12.76
$0.14
$12.62
2030
$12.57
$0.14
$12.43
2031
$12.37
$0.13
$12.24
2032
$12.19
$0.13
$12.06
2033
$12.03
$0.13
$11.90
2034
$11.88
$0.13
$11.75
2035
$11.74
$0.13
$11.61
2036
$11.62
$0.13
$11.49
2037
$11.52
$0.13
$11.39
2038
$11.43
$0.12
$11.30
2039
$11.35
$0.12
$11.22
2040
$11.28
$0.12
$11.16
2041
$11.22
$0.12
$11.10
2042
$11.16
$0.12
$11.04
2043
$11.12
$0.12
$10.99
2044
$11.09
$0.12
$10.97
2045
$11.06
$0.12
$10.94
2046
$11.05
$0.12
$10.93
2047
$11.04
$0.12
$10.92
2048
$11.03
$0.12
$10.91
2049
$11.02
$0.12
$10.90
2050
PV
$11.02
$197.1 $170.9 $101.9
$2.1
$0.12
$1.9 $11
$10.90
$194.9 $169.1 $100.8
EAV
$10.09 $9.82 $8.74
$0.11
$0.11 $0,095
$9.98 $9.71 $8.65
a Present values are calculated using end of year discounting.
b The equivalent annual values of benefits are calculated over a 25-year period.
Climate Benefits from Recovery of Disposable Cylinder Heels
As discussed above, as the market transitions to lower-GWP refrigerants based on the 2023 Technology
Transitions Rule, the mix of regulated refrigerants will change. In general, the transition would lead to
higher use of refrigerants not covered by the disposable cylinder management provision (e.g., ammonia,
carbon dioxide, hydrocarbons, HFOs) and less use of regulated substances (HFCs, HFC/HFO blends).
The social cost implications are determined as discussed in Section 3.5 and added to the net benefits from
the above table. Table M-5 presents the emission reductions by gas, the social cost attributed to that mix
of gases, and the net benefits inclusive of the social costs.
169
-------
Table M-5: Emission Reductions, Social Cost Benefits, and Net Benefits of Cylinder Management
(Central Scenario)
Emission Reductions (Metric Tons)
Benefits (millions 2022$)
HFC-32
HFC-125
HFC-13-la
HFC-143a
HFC-245fa
SC Benefits
Net
2028
680
332
203
81
0.44
$190
$202
2029
686
312
191
76
0.44
$186
$198
2030
693
292
176
71
0.45
$181
$193
2031
700
271
161
67
0.45
$176
$188
2032
706
249
148
63
0.45
$171
$183
2033
713
227
136
59
0.46
$166
$177
2034
720
204
126
55
0.46
$159
$171
2035
728
180
118
51
0.47
$152
$164
2036
736
156
112
46
0.47
$145
$157
2037
743
131
109
43
0.47
$139
$150
2038
749
112
105
39
0.48
$133
$145
2039
755
99
100
36
0.48
$130
$141
2040
759
93
95
32
0.48
$128
$139
2041
764
86
90
28
0.48
$126
$137
2042
769
80
85
24
0.48
$125
$136
2043
113
75
81
20
0.43
$123
$134
2044
776
73
79
17
0.34
$123
$134
2045
778
70
78
13
0.22
$123
$134
2046
780
69
76
11
0.12
$125
$135
2047
781
68
75
10
0.05
$126
$137
2048
783
67
74
8.2
0.01
$128
$139
2049
783
67
73
6.9
0
$129
$140
2050
784
67
73
6.5
0
$132
$143
Present Value (2% discount rate)
N/A
$2,360
Present Value (3% discount rate)
$2,165
$2,335
Present Value (7% discount rate)
N/A
$2,266
Equivalent Annual Value (2% discount rate)
N/A
$134
Equivalent Annual Value (3% discount rate)
$124
$134
Equivalent Annual Value (7% discount rate)
N/A
$133
Sensitivity Analyses for Recovery of Disposable Cylinder Heels
Several entities provided comments on the assumptions found in the report relied upon above (e.g.,
Worthington, 2023). One commenter indicates the assumed number of cylinders of 4,500,000 is too low,
that the heel remaining in a cylinder upon disposal of 4 percent is too high, and that the assumption that
all or nearly all of such cylinders will emit the totality of the heel rather than be removed is not the case.
Below we summarize the potential effects on the costs and emission reductions under alternate
assumptions based on these comments.
170
-------
The commenter says that their own sale of disposable cylinders is nearly 50% greater than EPA's
estimate, that records indicate 3,941,577 cylinders were imported from China, and that other countries
also supply an unspecified number of cylinders. Although it is not clear what percentage of these
cylinders would be used for refrigerants covered by this rule, for this sensitivity analysis, we add to our
central estimate a full 50% increase, plus the full number of reported cylinders from China, and we
assume that the other countries contribute 1 million cylinders, for a total of 11,691,577 cylinders.
Comments also discussed the expected heel within a cylinder. One commenter indicated an estimated heel
of 1.2 percent of the charged weight, while also citing various other estimates including 1.85 percent from
CARB, noting this was also corroborated by the Heating, Air-conditioning and Refrigeration Distributers,
International (HARDI), and 0.2 percent to 4.4 percent from Chemours, an HFC producer. Below we
examine the lowest of these estimates, a 0.2 percent heel in lieu of our central estimate of 4 percent.
In addition, commenters took issue with the assumption that all cylinders will fully emit those heels.
Instead, they argued that service technicians fully evacuate cylinders so that very little if any heel
remains. The commenter above cited National Refrigerants, a reclaimer, stating that 90 percent of
cylinders have a remaining heel of 0.5 pounds (about 2 percent) or less and that 60 percent have no
discernible heel, an indication that cylinder heel removal is occurring in the field already. The commenter
also pointed to CARB, which estimated that 70 percent of disposable cylinders are recycled or disposed
without heel evacuation. The commenter held that it would be reasonable to assume between 10 percent
and 70 percent are not properly evacuated before disposition. For this sensitivity analysis, we use the
extreme conservative end of this range, i.e., 10 percent.
Table M-6 below presents the present value of the costs and the emissions avoided using the above
discussed variables. Note these costs are based on handling and transportation alone, and do not include
climate benefits.
Table M-6: Costs and Emission Reductions of Cylinder Management under Different
Assumptions (Millions 2022$)
Number of
Cylinders
Heel
Not Vented
Benefits; NPV in 2022$ (3%
discount rate, discounted to
2024)
Emission
Reductions
(MMTC(he)
Central Scenario
4,500,000
4%
0%
$169.1 million
30.96
Higher Cylinders
11,691,577
4%
0%
$439.3 million
80.43
Lower Heel
4,500,000
0.2%
0%
$6.69 million
1.548
Low Vented
4,500,000
4%
90%
$16.91 million
3.096
Combined
11,691,577
0.2%
90%
$1.74 million
0.402
Regulatory Option
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EPA proposed that requirements for disposable cylinder management begin in 2025. For reasons stated in
the final rule, EPA has removed some of those requirements and delayed the date upon which they begin
to January 1, 2028. The draft RIA Addendum included with the proposed rule examined the costs and
benefits of the proposed action. Table M-7 below provides the costs and emission reductions that would
have been achieved under the finalized requirements with the proposed start date of 2025. The delay
results in lower emission reductions and lower costs for the final rule compared to an earlier effective date
as proposed.
Table M-7: Net Benefits and Emission Reductions of Cylinder Management under Different Start
Years flVUVlTCOie, Millions 2022$)
Effective in 2028
(final rule)
Eff ective in 2025
(proposed rule)
Difference
Percentage
change from
proposed rule
start date
Emission
Reductions
(MMTC02e)
30.96
38.49
-7.53
-19.6%
Net Benefits3
(millions 2022$)
$169.1
$205.3
-$36.2
-17.6%
aNet benefits represent the present value at a 3% discount rate discounted to 2024.
172
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