ASHRAE Journal - June 2021 - 32

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pathways to adopt the most suitable provisions for a given
country. The European Partnership for Energy and the
Environment (EPEE), for example, has developed such
a modeling tool with the United Nations Environment
Programme and a consulting firm that provides expertise
related to climate change mitigation, heating and cooling.
The tool has helped EPEE's members understand
different scenarios and provide constructive input.
Yurek and Walter-Terrinoni: AHRI will be sharing
petitions across borders and will continue conversations
with other countries to work to align as much as possible.
However, some different needs exist in different
countries with different markets and climates.
Fay: The Kigali phasedown schedules provide ample
lead time for adjustment as well as the added advantage
of being a phasedown and not a phaseout. Additionally,
significant advances in refrigerant management and
reclamation should allow for appropriate transitions in
each country. Each country has the sovereignty to create
its own regulatory structure, and it will be important for
each country to take these factors into account.
Developing A5 parties countries have later phasedown schedules
than developed non-A5 parties. Are there potential risks or
opportunities to pull this schedule forward, much like occurred
with ozone depletion phaseout schedules?
Fay: There may be an opportunity to accelerate the
phasedown in both A5 and non-A5 parties. The A5 parties
are in the midst of their HCFC transition decisions
and may be able to leapfrog to low-GWP technologies.
Yurek and Walter-Terrinoni: There may especially be
an opportunity to accelerate the phasedown for non-A5
parties that are planning ahead (as in the AHRI petitions
and strategy), as well as for A5 parties that have an HFC
baseline developed in recent years with an additional
65% of the HCFC baseline added to that, creating a significant
gap between phasedown schedule compared to
actual use for several years.
HFOs and Environmental Regulations
Fluorinated gases seem to be under constant pressure for
secondary environmental impacts, both real and perceived
(trifluoroacetic acid, per- and polyfluoroalkyl substances, etc).
What are potential issues? Will HFOs be at risk before 2030 due to
environmental regulations?
Fay: It is unlikely HFOs will be at risk before 2030 due
to environmental regulations. HFOs have been vetted
and approved as safe alternatives by regulatory bodies
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in countries around the world. HFOs, HFCs and their
blends should not be characterized or regulated as perand
polyfluoroalkyl substances (PFAS).
The Montreal Protocol Environmental Assessment
Panel has analyzed trifluoroacetic acid (TFA) and its
impact to the environment and noted there is not a
concern in the near future. Although TFA is persistent
in the environment, it does not bioaccumulate and has
low toxicity. TFA is produced and found in oceans, with
more than 95% from natural sources. The EPA concluded
that " the current and estimated concentrations of TFA
and its salts in the environment that result from the degradation
of HCFCs, HFCs and HFOs in the atmosphere
do not present a risk to humans and the environment. "
While the current assessment of risk from HFCs and
HFOs as it relates to PFAS is negligible, it is unclear at
present whether this could result in future regulatory
coverage. This will continue to be monitored.
Additional policy issues related to the use of refrigerants
and HVAC&R could be more related to energy efficiency
and accessibility. All of these will need to be taken
into account with respect to long-term efforts to achieve
the United Nations Sustainable Development Goals.
Yurek and Walter-Terrinoni: The atmospheric fate
of some HFOs and many HFCs (including HFC-134a) is
TFA. Technically, using a very broad definition, TFA is
technically perfluorinated; however, TFA could not be
considered a persistent bioaccumulative toxin because
it has low toxicity and is not bioaccumulative. The EU is
evaluating whether to include fluorinated refrigerants
in the PFAS group or to address it solely under the F-Gas
Regulations.
References
1. NRDC. 2021. " AIM Act Allies Press EPA to Move Industries Beyond
HFCs. " Natural Resources Defense Council. https://tinyurl.com/37f3cxfh
2. NRDC. 2021. " Petition to Reinstate HFC Prohibitions from
SNAP Rules 20 & 21 Under the AIM Act. " Natural Resources Defense
Council. https://tinyurl.com/exjxkunn
3. U.S. EPA. 2021. " Petitions Under the AIM Act. " U.S.
Environmental Protection Agency. " https://tinyurl.com/rez23uam
4. U.S. EPA. 2021. " EPA Moves Forward with Phase Down of
Climate-Damaging Hydrofluorocarbons. " U.S. Environmental
Protection Agency. https://tinyurl.com/4pbxss47
5. European Environment Agency. 2020. " National Emissions
Reported to the UNFCCC and to the EU Greenhouse Gas Monitoring
Mechanism. " European Environment Agency.
6. European Union. 2014. " Regulation (EU) No 517/2014 of
the European Parliament and of the Council of 16 April 2014 on
Fluorinated Greenhouse Gases and Repealing Regulation (EC) No
842/2006. " Official Journal of the European Union.
https://www.tinyurl.com/37f3cxfh https://www.tinyurl.com/exjxkunn https://www.tinyurl.com/rez23uam https://www.tinyurl.com/4pbxss47 https://www.ashrae.org/
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