Introduction

        The Alliance for Responsible Atmospheric Policy is an industry coalition, including many multinational companies, that was organized in 1980 to address the issue of stratospheric ozone depletion. It is presently composed of about 200 manufacturers and businesses which rely on CFCs, HCFCs, and HFCs. Today, the Alliance is a leading industry voice that coordinates industry participation in the development of reasonable international and U.S. government policies regarding ozone protection and global climate change.

        The Alliance has become an effective voice in ensuring an appropriate global approach to the issues while minimizing costly and ineffective regulations on industries. Industry worked through the Alliance to advocate a responsible phaseout of CFCs and other ozone depleting compounds.

        Overall, the Alliance has advocated the benefits of alternatives to CFCs such as HCFCs and HFCs; educated policymakers as to the feasibility of laws and regulations, assisted in removing barriers to the use of many alternatives; focused the U.S. government on curtailing illegal trade in CFCs; guided government efforts on many regulatory issues, supported discussion of policy and technology developments, and disseminated information to the public, media, governments, and industry that is useful in making the transition to safer alternatives.

Value and Importance of HFCs

        The Alliance seeks your attention in recognizing the value and importance of HFCs to society. Recent decisions by the Parties to the Framework Convention on Climate Change in 1998 in Buenos Aires, and in 1999 in Bonn noted the relevance of HFCs. In addition, the Technical and Economic Assessment Panel (TEAP) of the Montreal Protocol on Substances that Deplete the Ozone Layer reported in 1999 that HFCs are important to the safe and cost-effective phaseout of CFCs in developing countries, and are essential substitutes for highly important uses of ozone-depleting substances. HFCs are also technically and economically necessary for the phaseout of HCFCs in developed and developing countries. The Technical Options Committees of the TEAP also reported in 1999 that HFCs are necessary and beneficial in many HFC applications. We can make this information available to you if it has not already been provided.

        In addition, the Joint Intergovernmental Panel on Climate Change (IPCC)/TEAP Expert Meeting on Options for the Limitation of Emissions of HFCs and PFCs concluded that alternatives to HFCs may not be technically and economically feasible for some current uses. The Intergovernmental Panel on Climate Change (IPCC) has estimated that HFCs are only 2-3% of the greenhouse gas emissions.

        HFCs are part of the overall Kyoto Protocol basket of six greenhouse gases; and the Alliance believes that they should not be singled out for regulation or restriction. HFC emissions should be addressed only as part of a comprehensive climate change plan which fully considers collective emissions reductions of all greenhouse gases, and all relevant environmental, safety, energy efficiency and associated emissions of carbon dioxide equivalent, and economic factors of the HFC-containing product as a whole.

        HFCs are a key to the operation of energy efficient refrigeration and air conditioning equipment, and the production of energy saving foam insulation. Because of their energy efficiency, HFCs have a positive role to play in actually reducing greenhouse gas emissions. The more energy efficient a system is, the less carbon dioxide is emitted by the generation of the power used to run the system. HFC systems often have a lower overall global warming impact than flammable refrigerant or foam insulation systems.

        Emissions can be minimized in the manufacture and routine servicing of products important to society such as metered dose inhalers, air conditioning, refrigeration, foam insulation, electronic components, technical aerosols, and fire extinguishers. HFCs are important to solving both the problems of ozone depletion and global climate change. They are energy efficient, cost effective, and can be used safely. Society relies heavily on HFCs in many areas.

        Industrialized nations have made significant progress toward recovery of the ozone layer under the Montreal Protocol through the use of HFCs and HCFCs. In fact, the Montreal Protocol has created the impetus for industry to use these compounds. While developing countries are in the early stages of this transition, they are allowed to produce and import CFCs until 2010. Such CFCs have a global warming potential (GWP) five to 10 times higher than the GWPs of the HFCs. Restrictions on HFCs discourage the transition from CFCs in developing countries. Such discouragement is disadvantageous to both the ozone and the climate. Controls on HFCs will lead to a delay in the transition away from ozone-depleting compounds, especially in developing countries.

        HFC emissions management is occurring through non-regulatory means, voluntary measures, and industry-government partnerships. Industry and government are jointly engaging in research, communication and other activities to find new technologies, designs and processes to manage HFC emissions and enhance overall product energy efficiency, considering, among other relevant criteria, the cost-effectiveness of these investments in other climate protection options. Unilateral government restrictions on HFCs create barriers to free trade and cause inappropriate product selection relative to cost, safety and performance.

Conclusion

        Therefore, the Alliance respectfully requests the Danish Environmental Protection Agency to reconsider its proposal for phaseout of HFC. The HFC-producing and using industries have determined that HFCs are viable and proven global long-term solutions to the problems addressed by the Montreal Protocol and Kyoto Protocol processes. They are energy efficient, low-in-toxicity, cost-effective, and can be used safely. Governments and industry support the global use of HFCs in applications which meet important environmental and societal needs.

Supporting Documentation - A.D. Little Report

        Arthur D. Little, Inc., of Cambridge, Mass. today released a report on August 23, 1999 entitled "Global Comparative Analysis of HFC and Alternative Technologies for Refrigeration, Air Conditioning, Foam, Solvent, Aerosol Propellant, and Fire Protection Applications". (Available on-line.)

        The report, which is enclosed, provides an objective analysis of the overall performance of HFCs in comparison with alternative fluids and technologies in the major applications where HFCs have emerged as replacements for ozone-depleting CFC and HCFCs. The performance attributes that have been addressed include energy efficiency and global climate impact, safety, and economics.

        The report states that various HFCs have emerged or are emerging as the preferred refrigerant, blowing agent, solvent, aerosol propellant, or fire extinguishant in a wide variety of applications. Where HFCs are the preferred alternative to replace ozone-depleting substances, the reason usually is that the HFC provides the most cost-effective combination of superior overall technical and environmental performance and safety. In many cases, less safe, poorer performing materials or processes might instead be used as alternatives to HFCs.

        A highlight of the report is its concentration on safety considerations and energy efficiency. The report states that HFCs have emerged as the preferred replacements for CFCs and HCFCs because of their desirable safety characteristics - low toxicity and nonflammability - and their ability to reduce energy consumption.

        In addition, the report analyzes the cost savings of HFCs to society. The report states that HFCs often provide the most cost-effective combination of superior environmental performance and safety. They provide significant cost savings in the range of $15 - $35 billion compared to the poorer performing and less safe alternatives, such as hydrocarbons.

        The report finds that in 1997, the three lesser of the six greenhouse gases, HFCs, perfluorocarbons (PFCs) and sulfur hexafluoride (SF6) were 2 percent of the total greenhouse gas emissions, of which HFC emissions from use were 0.8 percent of the total. It is anticipated that HFC emissions in 2030 will be approximately 2.3 percent of the total emissions, while carbon dioxide will comprise nearly 77% of total emissions.

Additional Supporting Documentation

        The Alliance has published several documents (available on-line) that contain evidence supporting the use of HFCs as viable and proven global long-term solutions to the problems addressed by the Montreal Protocol and Kyoto Protocol processes. They are energy efficient, low-in-toxicity, cost-effective, and can be used safely. These factual documents provide information needed by policymakers to understand the benefits of HFCs and the disadvantages of phasing out the use of such beneficial compounds.

        If the Alliance can provide any additional information or answer your questions, please contact Dave Stirpe in Arlington, Virginia at 703-243-0344. (Or go to the Contact form.)