New EPA Refrigerant Rules – Positives And Negatives

Iceberg in the Arctic. Photo by AWeith.

The EPA, at the direction of President Biden, has initiated a set of rules designed to eliminate 85% of production and import of hydrofluorocarbons (HFCs) over the next fifteen years. The reason for these actions is to address climate change concerns; HFCs are classified as greenhouse gases and are believed to contribute to global warming.

The changing of refrigerants is not new. A similar action was taken in the 1980s, banning CFC propellants in order to address the hole in the ozone layer. (And, to digress a little, there is ample evidence to suggest that elimination of CFCs has reduced ozone depletion, but the science is not as simplistic as is generally presented… the initial predictions did not match the tested results, which led to discoveries that the satellite testing data was wrong and that volcanic eruptions were likely the greatest single factor associated with the ozone hole, not as a direct cause but due to their removal of a catalystic agent which would normally greatly reduce CFC damage… the chemistry suggests that CFCs are damaging but that their problem doesn’t become significant until sulfuric compounds are present in the atmosphere, as explained in this overview paper from NASA. That oversimplification has in turn fueled misrepresentations of the ozone layer “healing itself” during the 2019 cycle when the ozone depletion was near historic lows and contrary misrepresentations during the 2020 cycle when the ozone depletion reached abnormal highs. Further doubts sometimes come into play when years of historical depletion were found prior to use of CFCs and when the uncertainty of older instrumentation is taken into account when trying to determine measurements of penny-width thickness thousands of feet in the air. While these points all have some measure of validity, the fact remains that even with all of them accepted fully the measurements using the same equipment in the same state produced charted and concerning trends which were negated starting in the early 1990s. The ozone threat did not exist in the way it was generally portrayed on news programs or to casual students, but it did exist and it was successfully addressed by the Montreal Protocol.)

Armed with a historical environmental success due to refrigerant bans and with the identification of HFCs as greenhouse gases, the new rules on HFCs are a natural extension. Because there is no direct chemistry involved (CFCs release chlorine upon breaking down, which in turn disrupts ozone production; greenhouse effect issues involve a large number of variables, mostly associated with gas solubility in water at varying temperatures) an equivalency isn’t truly there, but from a policy standpoint the move makes sense. It’s even directly spawned from the Montreal Protocol, in the form of something called the Kigali Amendment.

There are some immediate positives and negatives associated with these rules.

One positive can be found in global goodwill, as climate change is a matter of concern across many populations worldwide and there is a diplomatic bonus to be found in being seen to address the issue. Another is to be found in trade, as protocols are being enacted in a number of countries to restrict HFC production and distribution; manufactured goods which use fluid coolants (such as air conditioners or refrigerators) will need to be designed for HFOs, the abbreviated term for hydrofluoroolefins. By adopting the standard to be used in most other wealthy countries, our ability to trade the subject goods will be greatly enhanced. If we insist on staying with HFCs, we would soon find ourselves dealing with a problem like we have with our cars and their lack of safety features for nearby pedestrians… easily sold within the borders of the U.S. and to some less affluent nations but restricted and undesired in many other places. All of this is distinct from the key reason for the rule, which is reduced production of greenhouse gases.

A less obvious positive is in the creation of new work – and with that, job growth. While many of the jobs touted by the production of HFOs will be roughly counterbalanced by the jobs lost in the production of HFCs, whenever there is more work to do – such as in the design of new vehicle systems and the replacement of older appliances – there will be a commensurate increase in labor required to perform that work.

So, what are the negatives?

First, let’s make clear: you don’t have to swap out your AC systems or appliances unless they start leaking, and if and when they do leak you may be able keep the same systems in place and simply use the new refrigerants. The rules will not mandate that everyone go out and buy new systems.

That said, the effect may be that people have to go out and buy new systems.

HFOs generally operate in the same way HFCs do, but they operate less efficiently. A sample test for a typical automotive air conditioning system found that HFOs required a compressor to work more to perform cooling tasks, and that the cooling provided had a heat transfer coefficient 18-21% less than that of the HFCs. In simpler terms, the mechanical components have to work harder and still provide significantly less cooling.

The greater workload will result in appliances breaking down more frequently and having significantly higher energy usage, and the diminished cooling capacity will result in older systems which were designed for HFCs not being able to reduce heat as designed. Newer systems will likely incorporate a greater quantity of coolant to counteract the loss in cooling capacity. This will be felt most immediately in cars, which have a tendency toward coolant leaks. New cars will need to be designed with larger coolant volumes, and cars manufactured up until now will have greatly diminished AC capability.

The Biden rules are also going to result in additional costs for things like food and medical transport and storage. Due to the perishable nature of the refrigerated items, simply accepting a higher temperature will not be possible; it’s one thing to tell someone they won’t be able to have a home that gets under 85 degrees during the afternoon during a heat wave, it’s another thing entirely to have food at temperatures which facilitate bacterial growth. As units with small leaks are replaced (repairs will be impossible, as the small amounts of refrigerant lost will not be able to be replaced) the costs of food and medicine will rise.

Also, the greater energy demand during the summer will necessitate new power plant construction. Existing power demands regularly strain generation capacities during heat waves in California and Texas. The long delays and licensing hurdles faced by new plants will need to be reversed, or rolling blackouts during the summer are inevitable.

An additional toll in human lives is expected. Every year, as summer heat blankets certain areas of the country, warnings are issued about the need for relief. In many places, cooling centers are set up for elderly and poor who may not be able to afford air conditioning; despite those precautions, about 702 people die every year in the US due to heat, with about 260 of those deaths coming from just three states: California, Arizona, and Texas. In countries where air conditioning is less readily available, those numbers are regularly higher; France averages about 1500 deaths annually, for example, with more than 14,000 dying in the heat wave of 2003. With the recognition that current prices are too high for many, it is reasonable to project that increased costs associated with the new equipment – both initial installation and energy drain – will result in a corresponding spike in deaths from high-heat states as people either cannot or choose not to pay; and during periods of rolling blackouts until generation capacity is brought into line with demand.

About the opinions in this article…

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About AlienMotives 1991 Articles
Ex-Navy Reactor Operator turned bookseller. Father of an amazing girl and husband to an amazing wife. Tired of willful political blindness, but never tired of politics. Hopeful for the future.

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