August 26, 2013
HALON ALTERNATIVES RESEARCH CORPORATION
FROM: TOM CORTINA
SUBJECT: EPA SNAP STAKEHOLDER MEETING
On August 22 EPA held a meeting with representatives of industry and environmental NGOs to discuss the potential for the Agency to use its authority under the SNAP program to further the goal of reducing emissions of HFCs. Attached are the agenda and a list of key discussion questions. About a hundred people attended the meeting, which was held at the Capital Hilton in Washington DC. Speaking for EPA were Sarah Dunham (Director of the Office of Atmospheric Programs), Drusilla Hufford (Director of the Stratospheric Protection Division), and Cindy Newberg (Branch Chief).
EPA began the meeting by reviewing the President’s Climate Action Plan that was announced in June. Part of the plan directs EPA to use its authority under the SNAP program “to encourage private-sector investment in low-emissions technology by identifying and approving climate-friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives.” EPA is seeking input from stakeholders on how they can address these two goals.
There was general agreement among the participants on the first goal of encouraging investment and approving climate-friendly chemicals. It was suggested by a number of participants that EPA prioritize the SNAP review of alternatives that are safer for the climate and focus resources to complete those reviews faster.
There was some disagreement among the participants on the second goal of prohibiting certain uses of HFCs. Environmental NGOs such as the Natural Resources Defense Council (NRDC) and the Environmental Investigation Agency (EIA) asked EPA to begin a process of delisting HFCs from the SNAP program for specific uses, beginning with HFC-134a in auto air conditioning, if there are more climate-friendly alternatives commercially available. These two groups made similar requests to EPA in petitions filed in 2010 and 2012.
Industry associations representing fluorocarbon and appliance manufacturers as well as individual manufacturers objected to the idea that EPA would use the SNAP program as a means to prohibit specific HFC uses, questioning both the appropriateness and legality of such an action. A number of manufacturers of equipment using non-HFC refrigerants spoke on the need for EPA to accelerate the approval of these technologies and remove barriers to their use, but most stopped short of publically supporting the delisting of HFCs under SNAP.
Their was broad support expressed by most participants for a global phase down of HFCs, and EPA stated that working towards a Montreal Protocol amendment on HFCs remained their first priority for action on this issue.
During their opening presentation EPA displayed a list of potential applications where they might consider making changes to SNAP listings that included mobile air conditioning and commercial refrigeration. Fire protection applications were not included on the EPA list and there was no mention of fire protection during the meeting.
We will discuss this issue in more detail at the September 12 HARC meeting.