By meeting and discussing amendment proposals with lead Montreal Protocol negotiators from the U.S. State Department and the EPA, EIA supports and encourages movement by the U.S. delegation to the Montreal Protocol for a strong amendment proposal. Additionally, EIA publishes briefings containing recommendations on actions and positions that should be adopted by delegates, prior to each Montreal Protocol related meeting. EIA’s in-depth analysis of Montreal Protocol amendment proposals and related documents provides delegates with the knowledge they need to take action to support a fair and robust phase-down of HFCs under the Montreal Protocol.
As one of the world’s largest HFC users, leadership and action by the United States is essential to mitigating HFC emissions and moving an international HFC phase-down forward.
Encouraging Strong Leadership at the Montreal Protocol
Urging the EPA to Phase-down HFCs & Control Emissions
Domestically, EIA works to influence the Environmental Protection Agency's (EPA's) Stratospheric Protection Division in the Office of Atmospheric Programs. The Stratospheric Protection Division oversees the Significant New Alternatives Policy (SNAP) program, which is a program that maintains a list of acceptable and unacceptable substances available for use on the U.S. market. EIA has developed several petitions to the EPA, including two with partner NGOs, which petitioned the EPA to remove HFC-134a (GWP of 1430) from the acceptable alternatives list for non-essential uses, and suggested a process for eliminating additional HFCs moving forward. EIA continues to push the EPA to remove high-global warming potential (GWP) HFCs from the SNAP program and provides comments on proposed regulations by the EPA that aim to list or delist various HFCs in certain sectors. In addition to petitions and comments on rulemakings, EIA calls on the EPA to issue regulations reducing the allowable emissions from products containing or using HFCs and mandating tighter reduction, recovery, and reclamation requirements for refrigerants, which are regulated under Section 608 of the Clean Air Act.
Stimulating Government Procurement of HFC-free Technologies
EIA advocates for the U.S. government to lead by example by procuring HFC-free technologies in its buildings and equipment, which would have a significant impact on market penetration and uptake of HFC-free technologies in the U.S. EIA’s report, An Initial Guide to HFC-free Procurement and Refrigerant Management for the U.S. Government LINK, analyzes where the U.S. government can procure HFC-free equipment and provides information on the authority of agencies to act on HFC-free procurement. Additionally, EIA has pushed for strong language in Federal Acquisition Regulations (FAR) promoting procurement of low-GWP alternatives.
Engaging the California Air Resources Board on Regulating HFCs
EIA is actively working with the California Air Resources Board (CARB) , encouraging actions that go above and beyond those taken by the EPA under SNAP, including instituting an ambitious HFC phase-down in California , on par with the reductions proposed by countries leading the charge to negotiate a global agreement to phase-down HFCs. A market transition to HFC-free technologies in California, which is the eight largest economy in the world, would have substantial positive ramifications on market acceptance and uptake of HFC-free technologies in the U.S. and beyond.