Climate Change Insights : Climate Change Law and Policy Lawyers & Attorneys : McKenna Long & Aldridge Law Firm : Climate Change Regulation, Green Strategies, Environmental Policy

What is driving the search for the next, “third generation” mobile refrigerant is both California's desire to move on and European Union regulations that will require air-conditioned vehicles sold in EU countries to use refrigerants with global warming potentials (GWP) less than 150 beginning in 2011 for new type vehicles and in all vehicles by 2017. HFC-134a has a 100-year GWP of 1,430, according to the Intergovernmental Panel on Climate Change. But, these regulations cannot be complied with in the EU alone without unacceptable impacts on the global market for autos and trucks, which today is a fully integrated international market. Vehicle manufacturers feel they must select a single global refrigerant that satisfies regulatory authorities in all markets worldwide.

Systems satisfying the EU regulation using carbon dioxide (R-744) and HFC-152a (R-152a) have been engineered and tested, and component and systems suppliers have announced their commercial availability. Additionally, global chemical manufacturers have developed and are currently testing new refrigerants that meet the GWP 150 limit. They would like to optimize fuel savings, cost savings, and environmental benefits by selecting the refrigerant that best satisfies life-cycle performance accounting standards for both direct greenhouse gas emissions and the indirect greenhouse gas emissions of the fuel burned to power the air conditioner.

HFC-1234yf has a GWP of four (4); the air conditioning system that uses it is safe and not substantially different from the system used for HFC-134a; and, perhaps most important of all, its system efficiency would allow 12 billion gallons of gasoline to be saved worldwide by 2025. Its slightly greater cost would be more than made up in fuel cost savings to the driving public over the life of the vehicle. The numbers involved are truly impressive: globally, vehicle air-conditioning consumes between four and twenty percent of national transportation fuels, depending on climate, traffic congestion, national wealth, and other factors. In the US, six percent of fuel use -- seven billion gallons -- is consumed annually just to operate vehicle air-conditioners. Refrigerant emissions have the carbon equivalent of burning another seven billion gallons of fuel. US vehicle air-conditioning fuel and refrigerant GHG emissions are equivalent to about 130 million metric tons of CO₂ equivalent or 36 million metric tons of carbon equivalent.

An HFC-1234yf air-conditioning system achieving 30 percent higher fuel efficiency worldwide would have an incremental cost of about $200 per car purchased but would save a typical car owner over $800 during the life of the car. Global benefits spread over 20 years might include 50 billion gallons of fuel saved -- a potential $200 billion benefit ($10 billion a year) if gasoline were valued at four dollars a gallon. Additional value for the carbon emissions saved if this fuel is not burned, and for HFC-134a emissions avoided, would add $4-6 billion more to the 20-year benefit total. These rough estimates are just that; they can be substantially refined by the vehicle manufacturers, research institutions, the National Renewable Energy Laboratory, and EPA, but for an initial indication of benefits of selecting HFC-1234yf, these “back-of-the-envelope” estimates show that significant benefits would accompany the switch in refrigerant.

What stands in the way of selection of HFC-1234yf? A number of issues need to be addressed, including EC REACH and US state approvals, some regional bans on flammable refrigerants, anti-trust concerns (cured if governmental agencies play a leading role), technology licensing to ensure competitive supply, “not invented here” syndrome, and ensuring leak-tight systems designed for high energy efficiency. But none of these problems is insurmountable, and great good can be achieved by not having to go as promptly to the fourth generation selection of a refrigerant because the third generation selection was not carefully done.

Perhaps what is most needed is for an appropriate entity -- perhaps the Transatlantic Economic Council is the place to start -- to convene the global vehicle manufacturers from the US, the EU, Japan, and perhaps India and China, as well as the relevant governmental agencies in these countries and California, environmental NGOs, and other key stakeholders, to seek prompt agreement on this solution.