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California Kicks Off HFC Rulemakings Ahead of Bonn Climate Talks

By Christina Starr, Climate Policy Analyst

At UN climate talks in Bonn this week, U.S. states are helping fill the void left in American leadership. Through initiatives like the U.S. Climate Alliance and America’s Pledge, sub-national actors are driving the conversation about how the Unites States can remain on track to meet emission reduction targets.

As the leadership role for U.S. states on the global stage takes shape, super-pollutant hydrofluorocarbons (HFCs) should be near the top of the list as the low-hanging fruit for these actors to address. HFCs, used mainly as coolants in the refrigeration and air conditioning sectors, have thousands of times the climate impact per unit as carbon dioxide. Reducing HFC emissions has very significant near-term climate benefits and is an absolute necessity for following through on the pre-2020 ambition needed to keep alive the possibility of limiting global temperature rise below 1.5°C.

The Kigali Amendment to the Montreal Protocol, a global agreement reached last year to phase-down HFCs, could help avoid up to half a degree Celsius of warming by the end of this century. However, successful implementation of the Kigali Amendment will require early and effective policy measures in developed countries. Regulations to begin phasing out some of the most climate damaging HFCs in certain uses were finalized in 2015 and 2016 by the Environmental Protection Agency (EPA) in 2015 and 2016. These rules are still in place for now, but may be substantially weakened or overturned completely depending upon the outcome of the appeal process to a recent DC Circuit Court decision.

California announced plans this month to begin a series of HFC rulemakings in the next two years. The first stage rulemaking will put controls in place to mirror the existing EPA regulations that may be weakened or overturned. This is a good start and an example other states in the US Climate Alliance should quickly follow in order to ensure that current momentum for a market shift away from the most climate damaging HFCs is maintained. It is the second stage rulemaking however, where CARB’s promise to lead the way forward and deliver on substantial emission reductions in the next decade will face the test of reality.

In order to meet ambitious 2030 HFC emission goals mandated by California law, the rulemakings will have to achieve rapid emission reductions much sooner than those expected under the Kigali Amendment. EIA recommends that CARB rapidly pass additional measures including bans on using HFCs above a GWP of 150 in many new kinds of refrigeration and air conditioning equipment beginning in 2021. This should be accompanied by funding for incentives that would accelerate the uptake of climate-friendly alternatives. Additionally, EIA urges CARB to examine additional policy options for addressing emissions from existing equipment and potential stockpiles of superpollutant refrigerants, together termed ‘refrigerant banks’. Strategies to address refrigerant banks require increasing rates of refrigerant recovery and destruction. This promising strategy for California and other states to explore as emerging leaders, since little has been done to address refrigerant banks under the Montreal Protocol.

The planned rulemakings are open for public comments this week. EIA urges stakeholders to support the state’s planned efforts and submit constructive comments to help make California’s ambitious goals a reality. Comments on CARB’s proposed rulemakings are due by this Friday November 10th and can be submitted here.

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