HARC Hosts Meeting with California Air Resources Board Staff

The Halon Alternatives Research Corporation (HARC) held its March meeting in Sacramento so that staff of the California Air Resources Board (CARB) could attend to discuss their recent activities related to climate change. Elizabeth Scheehle and Jorn Herner of CARB reviewed options to address the use of high global warming potential (GWP) chemicals such as halons and hydrofluorocarbons (HFCs) in fire protection as part of California’s comprehensive climate change law (AB 32) that was passed last year. CARB staff are in the early stages of planning and are considering a number of options ranging from encouraging the voluntary use of lower GWP agents to a GWP threshold for new and existing systems. One option being considered is the incorporation of the industry’s voluntary code of practice for HFC and PFC fire protection agents (VCOP) into a regulatory requirement. This would put the focus of the regulation on leak reduction, training, recycling, and reporting, similar to HFC regulations in Europe.

A workgroup will be formed of interested stakeholders to review and provide input to staff proposals and reports. HARC will serve as a focal point for cooperation and information sharing between CARB and the fire protection industry. CARB will undertake an inventory analysis to determine the number of systems installed in California, the types of agents used, and the rate of emissions. The will also undertake a lifecycle analysis of halon destruction. Based on this and other information, the staff will evaluate the cost and effectiveness of various emission reduction options and make recommendations to the Board. According to the current schedule, any measures related to fire protection would come before the Board for approval in 2011.

AB 32

In 2006 California passed a comprehensive climate change law that gives the California Air Resources Board full authority to regulate emissions of greenhouse gases (GHGs) in the state in order to meet a reduction target of 1990 levels by 2020. The law requires CARB to adopt regulations on the mandatory reporting of GHGs by 2008 and to complete a scoping plan for achieving the maximum technologically feasible and cost-effective reductions in GHG emissions by 2020. The law also requires CARB to identify "discrete early actions" by June 2007 and make them enforceable by 2010.

Early Action Reduction Measures

In April of 2007 CARB released a draft report that proposed three new regulations as discrete early actions under the law, but also proposed an additional 23 reduction measures to be initiated and worked on over the next 3 years (2007-2009). Included in the of list of 23 additional measures was the "replacement of high-GWP gases used in fire protection systems with alternate chemical(s)." HARC provided comments to CARB on this proposal that included information on the industry’s voluntary code of practice for the reduction of emissions of HFC and PFC fire protection agents (VCOP) and the HFC emissions estimating program (HEEP).

The list of discrete and additional early action reduction measures was subsequently expanded by CARB staff to 44 and approved by the Board in October 2007. The fire protection measure is expected to achieve very small emission reductions, estimated by CARB to be about 0.1 million metric tons of carbon dioxide equivalents (MMTCO2e) per year in 2020. By comparison, other approved measures such as the reduction of HFC emissions from refrigeration or mobile air conditioning are expected to achieve reductions in the 1-2 MMTCO2e per year range in 2020.

Senate Climate Bill Includes HFC Cap-and-Trade Program

The climate change bill that was debated on the Senate floor in June included a separate cap-and-trade program for hydrofluorocarbons (HFCs). HFCs would be given a separate cap under the program and would not be counted as part of the calculation of total greenhouse gas (GHG) emissions for firms covered by the regulation. This means that emissions of HFCs by individual users would not be regulated. Instead, the total amount of HFCs produced each year would be capped and incrementally reduced. Production allowances would be issued to manufacturers, importers, and OEMs based on historical production, with an increasing amount auctioned each year. The bill is not expected to pass this year, but will likely be the starting point for development of climate legislation in the next Congress.

Climate Security Act of 2008

On December 5 the Senate Environment and Public Works Committee reported out legislation (S. 2191) that would establish a comprehensive Federal climate change regulation covering 87% of US GHG emissions. The bill, which is commonly referred to as "Lieberman-Warner" after its sponsors Senators Joseph Lieberman (I-CT) and John Warner (R-VA), sets out targets of reducing GHG emissions to 4% below 2005 levels in 2012, 19% below 2005 levels in 2020, and 71% below 2005 levels in 2050. It proposes an economy wide cap-and-trade program covering the electric power, transportation, manufacturing, and natural gas sectors, and a separate cap-and-trade program to cover HFC production. The basis for a cap-and-trade program is that firms that cannot meet their targets through direct emission reductions can buy emission allowances from firms that are able to achieve reductions beyond their targets. The European Union is currently beginning the second phase of its cap-and-trade program, which began in 2005.