Transcript March 2010 (meeting notes) - Fire Suppression Systems Association

HARC Meeting
March 4, 2010
Arlington, Virginia
Aviation Issues

ICAO Resolution
 Dates
from original ICAO resolution
reaffirmed at December 2009 meeting:
– Lavatory, engine/APU, hand-held extinguishers
for which a new application for type certification
has been submitted (i.e., newly designed aircraft)
in the 2011 timeframe
– Lavatories in new production aircraft in the 2011
timeframe
– Hand-held extinguishers in new production
aircraft in the 2014 timeframe, with it being a
recommended practice by 2012
Aviation Issues

ICAO Resolution
 New
date for hand-held extinguishers in
new production aircraft subsequently
proposed by aviation industry - 2016
 Accepted in principal along with change in
resolution language from “consider a
mandate in the 2014 timeframe” to “establish
a mandate in the 2016 timeframe”
Aviation Issues

HARC submitted comments on FAA draft
hand-held circular on January 8:
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FAA’s toxicity assessment for streaming agents is
too conservative, more conservative than EPA
Raises questions about the safety of existing Halon
121 extinguishers on aircraft
Raises questions about the safety of currently
approved alternatives
Could hinder development of potential new
alternatives with a toxicity profile similar to 1211
Not appropriate to use conservative approach for
alternatives and not for Halon 1211
Aviation Issues

HARC comments on FAA hand-held circular:
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Recommend that FAA use the same approach for
toxicity of streaming agents as EPA under SNAP
Needs to provide simple guidance (single table) and
focus more on importance of using extinguisher
Corrected statement related to aviation “EPA critical
use exemption” and “production” of blends
Remove requirements to mark extinguishers with
statement related to minimum aircraft volumes and
warning to “use only amount necessary to
extinguish a fire” for fear of hesitation in using
Remove ventilation recommendation as it may
conflict with established crew procedures
Aviation Issues

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Major halon contamination issue in Europe
Large quantity of halon over last 7 years has
gone into aviation systems/extinguishers
EASA determined that Halon 1301 is safe?
EASA emergency airworthiness directive
issued in November requiring extinguishers
from Fire Fighting Enterprises to be replaced
Subsequent EASA directives covering other
types of extinguishers and aircraft
FAA emergency airworthiness directives
issued in January and February
ASTM

D26.09 Subcommittee
 D6127
(HFC-23 HT&S), D6427 (HFC-236fa
HT&S), D7123 (HCFC Blend B HT&S) were
balloted and received no negatives
 D7327 (HFC Blend B Standard) is overdue
for balloting - B. Colton to address
 Negatives received for D6064 (HFC-227ea
Standard), D6126 (HFC-23 Standard), and
D6231 (HFC-125 Standard)
ASTM

D26.09 Subcommittee
 Negatives based on needed conductivity
method for acidity withdrawn – ASTM
conductivity method will be developed, then
all ASTM standards can reference both
colorimetric and conductometric methods
 Other negatives based on lack of definition
of non-absorbable gases (NAG) - ARI 700
refers to these as non-condensable gases
 Additional definition will be added to reflect
that ARI refers to NAG as non-condensable
gases, and the standards will be re-balloted
ASTM

D26.09 Subcommittee
 Owing
to severely contaminated Halon 1211
being found in the European aviation sector,
and possible US as well, a new Halon 1211
standard is being developed under the
Rapid Ballot process
 Purity testing will use a GC/MS method
 The Halon 1301 standard will be revised to
replace GC testing with a GC/MS method
 A draft Halon 1211 Standard is currently
circulating for comment
Climate Change

Climate Science
 Recent
revelations from emails about IPCC
scientists hiding contradicting data
 Errors in 2007 IPCC report related to
Amazon rain forest endangerment,
Netherlands/sea level, Himalayan glaciers
 Raised questions about climate science and
about the methods of the IPCC
 Has contributed to recent polls in US and UK
showing less concern for climate change
Climate Change

Copenhagen - What Happened?
 Current
UNFCCC negotiation process is
unmanageable and almost collapsed
 UNFCCC Executive Secretary resigned
 Copenhagen Accord was negotiated by small
group of heads of state including President
Obama and China’s Premier Wen Jiabo
 China’s increased standing as an economic
power was evident
Climate Change

Copenhagen - What Happened?
 UNFCCC
consensus approach no longer
works, negotiations were consistently
thwarted by a handful of countries such as
Sudan, Venezuela, Bolivia, and Cuba
 Developing countries refuse to allow Kyoto
Protocol to go away until they have adequate
commitments from developed countries for
the post-2012 period
Climate Change

Copenhagen - Results
 Actions
by all countries, both developed and
developing, that would be listed in a table as
part of the Accord
 Guidelines that provide transparency for the
monitoring, reporting, and verification
(MRV) of the national actions listed in the
table (key issue for the US)
 Commitments for financial assistance to
developing countries in $100 billion range,
initially $10 billion/year for 3 years
Climate Change

Copenhagen - Results
 97
countries have kind of associated
themselves with the Copenhagen Accord
 57 countries, including 27 developing
countries, have entered national actions or
targets in the Accord’s table
– US - 17% reduction from 2005 levels by 2020
– EU - 20-30% reduction from 1990 levels by 2020
– China - 40-45% reduction in carbon intensity by
2020 (carbon emissions per unit GDP)
Climate Change

Copenhagen - What’s Next?
 Reexamination
by IPCC of the methods used
to assemble and edit climate science
assessments
 Continued negotiations aimed at turning the
Copenhagen Accord into a legally binding
international treaty
 Next Conference of Parties (COP 16) in
Mexico City in November or December
Climate Change

Montreal Protocol
 Proposals
by US and others were considered
at the 2009 Meeting of Parties in November
that would have added HFCs to the
Montreal Protocol and controlled their
production
 Controls would be similar to ODS (CFCs and
halons), but production would be phased
down slowly and not phased out completely
Climate Change

Montreal Protocol
 Mauritius
and Micronesia:
- freeze in 2012
- 15% reduction in 2015
- 30% in 2018
- 45% in 2021

- 60% in 2024
- 75% in 2027
- 90% in 2030
(2004-2006 baseline)
United States, Canada and Mexico:
- 10% reduction in 2013
- 70% in 2029
- 20% in 2017
- 85% in 2033
- 30% in 2020
Developing Countries: 10% in 2016
- 50% in 2025
85% in 2043
Climate Change

Montreal Protocol
 Proposals not expected to be approved, US
and EU supported carrying them over
 Instead they were killed due to opposition
from China and India among others
 Reasons HFC amendments not approved:
–
–
–
–
Not enough time to fully educate Parties on proposal
Not enough information on HFC alternatives
Timing not right – Wait for Copenhagen outcome
Developing countries unsure of cost issues
associated with the accelerated HCFC phase out
– Scope: UNFCCC/Kyoto, not the Montreal Protocol
Climate Change

Montreal Protocol
 Expected
that US, Canada and Mexico will
re-propose HFC amendment for
consideration at 2010 Meeting of Parties
(October in Uganda?)
 US seems optimistic, but others think it may
take 2 more years to get approved
Climate Change

Congress
 American
Clean Energy and Security Act of
2009 (Waxman-Markey, H.R. 2454)
 Clean Energy Jobs and American Power Act
(Kerry-Boxer, S. 1733)
 Both create an economy-wide cap-and-trade
program covering 85% of US greenhouse gas
(GHG) emissions
 Reduce GHG emissions by 17-20% below
2005 levels in 2020, and 83% in 2050
Climate Change

Congress
 House
bill (HR. 2454) passed in June by 219212 vote
 Senate bill (S. 1733) reported out of
Environment and Public Works Committee
in November and awaits further action
 HFC provisions of both bills very similar
 HFC provisions were supported by industry
and environmental groups
Climate Change

Congress - HFC Provisions
 Hydrofluorocarbons
(HFCs) would be
covered separately from other GHGs by
amending Title VI of the CAA (ODS
regulations)
 Class II substances would be split into two
groups, with group I containing the HCFCs
and group II containing the HFCs
 Overall production of HFCs would be
phased down between 2012 and 2032
Climate Change
Proposed HFC Reduction Schedule
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
-
90% of baseline
87.5%
85%
82.5%
80%
77.5%
75%
71%
67%
63%
59%
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
after 2032
-
54%
50%
46%
42%
38%
34%
30%
25%
21%
17%
15%
Climate Change

Congress - HFC Provisions (Allowances)
 Allowances
required to produce or import
HFCs, or import products containing HFCs
 The minimum sales price would be set in the
early years of the program as follows:
– $1.00 per MT in 2012, $1.20 in 2013, $1.40 in 2014,
$1.60 in 2015, $1.80 in 2016, $2.00 in 2017, and
then increases with inflation for rest of program
– After 2014 actual sales price determined by
combination of auction and non-auction price
Climate Change

HFC Provisions - Allowance Cost
 At
$1.00 per metric ton (2012):
- HFC-227ea = $1.46/lb
- HFC-236fa = $4.46/lb
 At
- HFC-125 = $1.59/lb
- HFC-23 = $6.73/lb
$2.00 per metric ton (2017):
- HFC-227ea = $2.93/lb
- HFC-236fa = $8.92/lb
 Why
- HFC-125 = $3.18/lb
- HFC-23 = $13.40/lb
has industry supported this approach?
– Under main bill, minimum allowance cost would
be $10 per ton = $11.46 per pound for HFC-227ea
Climate Change

HFC Provisions - Labeling/Assistance
 Essential
use, labeling, nonessential product,
safe alternatives, and other provisions of
Title VI would be extended to HFCs
 Products containing or made with HFCs
would be required to be labeled with the
phrase “contributing to global warming”
 Provides possible funding to manufacturers
of products containing HFCs, including fire
protection systems, to facilitate the transition
to low-carbon alternatives
Climate Change

HFC Provisions - Essential Use
 Essential
use provisions would allow EPA to
withhold allowances from under the cap and
allocate them specifically to produce HFCs
for medical devices, aviation and space flight
safety, fire suppression, and national security
 Essential use provisions would also allow
EPA to approve additional HFC production
above the cap for developing countries,
national security, and fire suppression
Climate Change

HFC Provisions - Destruction
 Offset
credits are provided at a 20% discount
for destruction of CFCs after 2011 in the US
 EPA can add other class I or class II ODS
 EPA can add ODS destruction to list of offset
projects that receive credit in main program
 CFC destruction projects that occur between
2009 and 2012 and are recognized under a
State or comparable program could receive
credit under the early offset provisions
Climate Change

Congress - Path Forward
 Climate
legislation may be taken up again by
the Senate in Spring 2010
 Senators Kerry (D-MA), Graham (R-SC) and
Lieberman (I-CT) are currently working on a
compromise (“tri-partisan approach”)
 Key issues include nuclear power and oil
exploration (Obama $8 billion in loan
guarantees for two nuclear plants in GA)
Climate Change

Congress - Path Forward
 Senators
Cantwell (D-WA) and Collins (RME) recently introduced “cap-and-dividend”
bill (S. 2877)
 Cap on CO2 emissions from fossil fuel
 Carbon shares 100% auctioned
 75% of proceeds returned to US residents on
a per capita basis, 25% for clean energy
 HFCs not covered, but some clean energy
funds could be used to finance reductions
Climate Change

Congress - Prospects for Passage
 Full
blown cap-and-trade appears to be dead
 Compromise based on “tri-partisan” or “capand-dividend” approach could gain support
 Industry might support adding HFC
provisions to other climate or energy bills
that have chance to pass or as stand alone bill
 Right now prospects of Senate climate bill
passing this year seem very small, would
have to happen before mid-year
Climate Change

Alternatives to Federal Legislation
 EPA
moving forward with regulation of
GHGs under existing Clean Air Act attempts in Congress (Murkowski), petitions,
and lawsuits to stop them
 EPA has restricted use of high-GWP fire
protection agents under SNAP
– HFC-236fa is restricted for use in total flooding
fire suppression to applications where other
alternatives are not technically feasible
Climate Change

European Union F-Gas Regulation
 Effective
on July 4, 2007
 Covers emissions of HFCs, PFCs, and SF6
 Does not prohibit the use of HFCs for fire
protection
 Most applications requires reporting,
recovery containment, leak inspection,
labeling, training
 Compliance with industry standards such as
ISO should meet most requirements
Climate Change

European Union F-Gas Regulation
 2010
Review
 Contractor has begun a study to evaluate
compliance with the current regulations and
to determine what else needs to be done
 Industry position is that most EU member
countries have not fully implemented
existing regulation - too soon for changes
 Could be superseded by addition of HFCs to
Montreal Protocol
Climate Change

States - Minnesota
 Law
passed in 2008 that requires reporting by
producers and users of high-GWP
greenhouse gases (HFCs, PFCs, and SF6)
 Reporting threshold changed in 2009 from
500 MT to 10,000 MT
 Minnesota Pollution Control Agency is
implementing the reporting program
 Reports for 2008 and 2009 include
refrigerants, PFCs in semiconductors, SF6 in
power generation - no fire suppression agents
Climate Change

States - California
 AB
32 - Alternative Suppressants
- High-GWP mitigation fees
- Use of lower GWP agents
- Leak reduction
- End of life agent recycling and destruction
 Still
under internal discussion and analysis
 Not likely to be any action on mitigation fees
or fire protection this year
 HARC met with IRTA yesterday to discuss
helping with CARB inventory
HEEP Update
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Data collection is complete for 2008
Same 21 companies have reported for last 5
years
Re-charge sales for 5 agents reported:
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HFC-23
HFC-125
HFC-227ea
HFC-236fa
PFC-3-1-10

2006 - 0.589 MMTCO2e = 0.161 MMTCE
2007 - 0.656 MMTCO2e = 0.179 MMTCE
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2008 - 0.622 MMTCO2e = 0.170 MMTCE

HEEP Update
Year
Companies
Reporting
MMTCO2
MMTCE
2002
22
0.530
0.145
2003
20
0.523
0.143
2004
21
0.625
0.170
2005
21
0.681
0.186
2006
21
0.589
0.161
2007
21
0.656
0.179
2008
21
0.622
0.170
Graphical Representation of Fire Protection
Emissions of HFCs and PFCs
Reported Fire Protection Emissions
of HFCs & PFCs
Emissions, MMTCE
0.25
0.20
0.15
0.10
0.05
0.00
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Year
Revised EU ODS Regulations
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Regulation (EC) No 1005/2009 effective 1/1/10
The draft new Annex VI on halon critical uses is
undergoing revisions following received
comments from the Member States
A main area of contention is end dates for civil
aviation - not all member states agree that end
dates are required for all applications, although
Commission may be flexible on final dates
Target is to have revised draft ready for vote of
Regulations Committee on March 23, 2010
Revised EU ODS Regulations


Most recent proposal (11/25/09) slips cut-off
dates for most applications by a year (2010) and
end dates by 5 years (2025 or 2035)
Dates for aviation critical uses:
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Cargo compartment fixed systems - cannot be installed
on new aircraft after 2016, end of use exemption is 2035
Cabin/crew compartment portables - 2012, 2025
Engine nacelles and APU - 2012, 2035
Lavatory (potty bottles) - 2011, 2020
Dry bays - 2011, 2035
Inerting of fuel tanks - 2011, 2035
Due account should be taken of ICAO initiatives
HTOC


HTOC meeting March 9-11, Montpellier France
2010 Assessment Report:
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Barriers to the free movement of recycled halons
A5 Halon banking issues
Impact of proposed HFC controls
New installations using recycled halons
Prolonged equipment use
Unusable, contaminated stockpiles
Delayed transition and impact on ozone recovery
Aviation issues, ICAO leadership/cooperation
Monitoring feedstock use
Will be looking for volunteer peer reviewers
HTOC

Decision XXI/7: Halons
 Support
for mandatory dates by when halon
alternatives will be used in newly designed
aircraft; TEAP/HTOC to report ICAO
progress to the 22nd Meeting of the Parties;
 Parties that have implemented import
and/or export restrictions of recycled halons
should consider reassessing their situation;
 Parties should refrain from destroying
uncontaminated recycled halons before they
have considered their domestic, as well as
the global long-term future needs for halons;
HTOC

Decision XXI/7: Halons
 Parties
should report their needs for halons
to the Ozone Secretariat for use by the
TEAP/HTOC in their assessment of halon
banks;
 Parties to inform, on a regular basis, their
users of halons, including the maritime
industries, the aviation sector and the
military, of the need to prepare for reduced
access to halons in the future and to take all
actions necessary to reduce their reliance on
halons.
HTOC

Decision XXI/9: HCFCs and
Environmentally Sound Alternatives
 TEAP
to provide the latest technical and
economic assessment of available and
emerging alternatives to HCFCs, and to
assess their impact on the environment,
including on climate;
 TEAP to list all sub-sectors using HCFCs,
and provide costs, relative energy efficiency,
market share etc., of technologies where lowGWP alternatives are used.
HTOC

Decision XXI/9: HCFCs and
Environmentally Sound Alternatives
 TEAP
to compare these alternatives with
other existing technologies, in particular,
high-GWP technologies that are in use in
the same sectors;
 TEAP to identify and characterize barriers
to the safe application of low-GWP
alternatives;
HTOC

Decision XXI/9: HCFCs and
Environmentally Sound Alternatives
 TEAP
to update the information provided
in accordance with Decision XX/8 to
inform the Parties of the uses for which
low- or no-GWP technologies are or will
soon be commercialized, and to predicted
the amount of high-GWP alternatives to
ozone-depleting substances uses that can
potentially be replaced;
HTOC

Decision XXI/9: HCFCs and
Environmentally Sound Alternatives
 Parties:
– To promote policies that avoid the selection of
high-GWP alternatives, and which promote the
development and availability of low-GWP
alternatives to HCFCs and other ODS;
– To consider reviewing/amending policies which
are barriers to the use of low- or zero-GWP
alternatives to ODS, particularly HCFCs;
HTOC

Decision XXI/9: HCFCs and Alternatives
 The
Executive Committee:
– Is to expedite the finalization of its guidelines on
HCFCs;
– For projects, particularly those phasing-out
HCFCs ,to consider providing additional funding
for additional climate benefits;
– The cost of projects is to take into account climate
benefits;
– To consider the effectiveness of low-GWP
alternatives to HCFCs, including in the Air
Conditioning and refrigeration sectors in high
ambient temperature areas in Article 5 countries;
ODS Destruction
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Decision XXI/2 on management of ODS banks
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Multilateral fund pilot projects on ODS destruction
in developing countries
Seminar on how to identify and mobilize funds for
ODS destruction prior to the OEWG meeting
Climate Action Reserve ODS destruction
protocol does not include destruction of halons
due to questions about the indirect GWP
Request at January 29 EPA/State Department
stakeholder meeting that MP Science Panel
clarify the issue of whether halon destruction
would provide any climate benefits