July 13, 2010 meeting notes

I. International Regulatory Issues 

EU Regulation Overview

Presenter: Klaus Steininger, European Commission

The presentation focused on main regulatory requirements for green house
gas (GHG) emission control and reduction, measured in terms of CO2.

EU regulations on CO2 have 3 main legal actions:

Directive 2006/40/EC ( MVAC emissions

2007/40/EC ( administrative

2007/37/EC ( amendments

EU regulatory actions are applied on a step-wise base:

1st step: 

Control direct emissions of MVACs >150 GWP:

mandatory as of Jun 21, 2008 (new types of vehicles)

mandatory as of Jun 21, 2009 (all new vehicles)

2nd step: 

Prohibition of F-gases > 150 GWP

Starting Jan 2011 (new types of vehicles)

2017 (all new vehicles)

Part of the EU regulations on GHG includes:

EC/848/2006

F-gases not critical, no disproportionate costs

EC/307/2008

Appropriate qualification of personnel 

Regulations under the European Commission also includes requirements to
report CO2 emissions 

Emissions <= 130 g/km CO2 (powertrain improvements)

Addition of  10g/km CO2 (other tech improvements)

Thus, to reduce CO2 emissions and achieve EU requirements the following
has to be addressed:

Efficiency improvements on MVAC system

Fuel efficiency (driving patterns studies)

Pressure monitoring on A/C system

Gear shift indicators

For a total of 140g/km of CO2 emissions, it is necessary to attain a
reduction of 10g/km

MVAC indirect emissions – test procedures, must consider:

Cost effectiveness

Incentive reduction of emissions from MVAC

Insulation technologies

Draft for MVAC test procedure is anticipated on August 2010

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EPA Ann Arbor Indirect Energy Consumption Developments

Presenter: Brian Nelson, U.S. Environmental Protection Agency

EPA issued a final rule, Light Duty Vehicle Green House Gas Emission
Standards and Corporate Average Fuel Economy Standards. The main focus
of final rulemaking issued by EPA-OTAQ with join efforts from NHTSA is
to guide toward GHG emission reduction and the approval of “GHG
credits”. MVAC systems are considered part of GHG emissions from
vehicles, thus the presentation had particularly focus on A/C credits. 

A/C Credits are evaluated according to:

MVAC system efficiency

Type of MVAC refrigerant used

Other technologies that reduce GHG*

*Other types of credits include: “off-cycle credit”, which is not
captured in an existing test cycle. However, manufacturers must justify
this credit. 

Efficiency credits are evaluated using two methods:

1.  “Menu” method, which is a table offered on the final rule –
manufactures must follow this method only for 2012-2013 automobile
models.

2. “A/C idle test” method, which is used to measure incremental CO2
due to A/C use  - manufacturers must follow this method for 2014 –
2016 automobile models only (for these models an adjustment factor must
be applied).

GHG emission, measured as CO2, of 14.9 g/min or less may be eligible to
receive credit. Starting with 2009-2011 year models, manufacturers may
be eligible to receive “early” A/C credits if these attain with the
minimum A/C emission rate (see final rule for more details, 75 FR
32324).

The method to evaluate and determine refrigerant emissions from the MVAC
system is applied referencing the SAE J2727 standard (as of 2008).

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Update on California’s Regulatory Efforts to Reduce Greenhouse Gas
Emissions from Mobile Air Conditioning

Presenter: Tao Zhan and Leela Rao, California Air Resources Board

MVAC refrigerant emissions are being determined using mass balance:

Refrigerant introduction (into MVAC system):

Initial OEM charge

Recharge/ servicing

Refrigerant emission (out to the environment):

Leakage 

Accidental break of the A/C system

MVAC servicing (topping of a leaky system, unintentional venting)

End-of –life (recyclers/salvage yards) activities

Containment heel

CARB’s regulatory evolution:

CA-AB 1493 (PAVLEY)

Standard to be applied on 2009-2012 automobile models

MVAC improvement can earn credits for GHG emissions

LEV III

Mandatory standard to be applied on automobile models starting 2017

The use of low GWP refrigerants are required

Low leak rates on MVAC systems

Indirect emissions limit

These regulations are intended to complement EPA regulations on GHG
credits. CARB expect their standard align with federal regulatory
activities. 

LEV III requirements are as follows:

MVAC refrigerants must have a GWP equal or lower than 150

MVAC systems  must have a 90% reduction of direct emissions

Average leak rate must be equal or lower than 9g/yr

OEMs can choose from 3 SNAP refrigerants: HCF-152a, CO2, or HFO-1234yf 

Indirect emissions standard

CARB is proposing to develop a fleet average MVAC indirect emission
standard

Evaluation through a whole-vehicle performance test procedure (under
development)

CARB is evaluating leak rates on MVAC systems using SAE 2727 standard 

Initial adoption using EPA’s final rule on GHG credit

However, proposed test procedure adds into consideration solar load,
moderate annual loading, and A/C during initial cooling and steady-state
temperature control.

CARB regulatory activities are intended for long term MVAC performance
and consumer protection. Also main focus is being directed to MVAC
efficiency improvement. Comments are currently being requested. In
addition, CARB is looking forward to address other MVAC system
improvements, including adequate lubricants. CARB believes a 9g/yr MVAC
GHG emission rate is achievable and a 18g/yr per USEPA, 50% of goal
reduction is feasible.

CARB expressed the need to develop new standards in the US if EU
switches to HFO-1234yf.

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Q & A session for the first 3 Presentations:

Q: Is CARB aware of EU direct/indirect emission restrictions?

A (CARB rep.): Yes. CARB is currently determining feasibility of tests
and proposed standards. 

A (EU Commission rep.): EU regulations proposed minimum requirements
(see presentation and EU rulemaking for further information).

Q: What are the plans for enforcement for CARB’s standards

A (CARB rep.): Right now CARB is working on developing standards,
Enforcement will be determined once the standards are published. 

Q: How will the SNAP approved refrigerants affect efforts to implement
low GWP refrigerants?

A (EPA rep.): More information about SNAP is covered during the
afternoon session. (see afternoon session meeting notes)

Q: What is being approved regarding highway (heavy duty) equipment?

A (EPA rep.): The current regulatory actions are being focused on light
vehicles (i.e., cars, SUV’s and light duty vehicles) and primarily on
emissions due to leakage. Other types of vehicles are targeted for the
future.

A (EU Commission rep.): Several mobile air requirements for off-road
vehicles are being verified. However, regulation for these vehicles may
be applied on future regulations. 

Q: Is 1/3 of the overall GHG credit issued for indirect emissions? What
is the base to determine those emissions?

A (EPA): 13.6g/yr of CO2 based on indirect emissions or 70.6% efficiency
improvement of the MVAC system could attain the requirements for
credits. A leakage inventory was developed by OAP based on the
approximate amount of losses from vehicles. EPA referred to the
Vintanging model. Other analyses and assumptions were obtained from
studies from NREL and standards. 

Q: SAE J2727 standard addresses type of compressor energy penalty due to
different type of A/C, and system emissions, How has this been addressed
in the regulations?

A (EU Commission Rep.): Issue is going to be taken into account.

A: (W. Atkinson, SAE): “If we have control of the refrigerant leakage,
e.g. 15g/yr, and in the past it was common to recharge the A/C every 90
days, we have measured the efficiency and had tried to reduce
refrigerant indirect emissions (due to increase of system efficiency)”

Q: What is the emission rate technology?

A (EPA): See EPA final rule on GHG credits. SAE J2727 standard is one of
the main bases for this.

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OEM Evaluation of MAC Fuel Consumption by Physical Testing. Comparison
of Test Benches, Engine Types and MAC Technologies

Presenters: Bruno Rose, PSA; Enrique Peral, Renault

The purpose of the research was to find consistency of efficiency
measures for the MVAC industry. Attention was brought toward the need of
express results whether in fuel consumption (thus engine efficiency
regarding MVAC fuel consumption) or MVAC technical efficiency itself.

Q & A Session:

Q:  What is the A/C consumption?

A: Number of energy consumption may be dependent on temperature. If
different compressor systems are used, with different maximum loads,
measurements are going to be different.

Q: What assumptions were used in the study?

A: Constant load on the A/C

Q: Did the study considered different solar load technologies?

A: Not enough tests have been done on that field.

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Quantificational Analysis of Automotive AC Fuel Consumption on EPA Drive
Cycles

Presenter: Kelvin Zhai, 

Studies on MVAC systems done in NREL facilities have found that running
electrical accessories in the automobile reduces fuel economy.by 5-25%

Modeling technologies such as A/C dynamic simulator are options to
evaluate energy consumption, reflected as fuel consumption from the use
of A/C systems in vehicles. However, great variability exisst due the
significant amount of existing driving patterns and conditions.

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HFO-1234yf – Safety When Exposed to Ignition Sources

Presenters: Kai Holtappels, Volkmar Schroder, BAM; Gabrielle Hoffman,
Wolfgang Plehn, UBA

UBA presented a study (including a video) of ignition inside the
passenger compartment when “enough” concentrations of HFO-1234yf
(900g) and ethane are released into the passenger compartment and an
ignition source such as a spark is present.  The researchers presented
concerns on HF formation since concentrations surpassed 90 ppm inside
the passenger compartment. However, the presenter did not say what was
the exact concentration and duration. The presenter reiterated that
preventive measures regarding HF and flammability are necessary but
recognized that flammability is not a barrier for HFO-1234yf use on MVAC
systems. 

The presenter recognized that HF concentrations above 90 ppm also
resulted from HFC-134a thermal decomposition. Results did not show the
exact concentration.

Q & A session:

Q: Was a Fault Tree Analysis conducted in the study?

A: No fault tree analyses were conducted. 

Q: What was amount of energy released to cause the fire? Were
combustible materials identified inside the passenger compartment (e.g.,
textiles)?

A: Amount of energy was not measured during the study. Seat material was
not taken into consideration.

Q: What is the computation analysis of HF formation?

A: Details of the analysis will be published on their website (UBA’s).

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Review of SAE CRP 1234 Results

Presenter: William Hill

The presentation focused on results of the CRP 1234 risk analyses
regarding HFO-1234yf toxicity, flammability, and HF, in addition to
risks assessments on CO2 refrigerant (For more information, the CRP1234
is on EPA’s SNAP rule docket: EPA-HQ-OAR-2008-0644).

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II. ICCC Standards Meeting

Regulatory Updates on Alternative Refrigerants for MVACs

Presenter: Yaidi Cancel, U.S. Environmental Protection Agency

A review on SNAP regulatory actions and current status of EPA rulemaking
for CO2 and HFO-1234yf refrigerants were presented.

*For further details, please find the presentation on SNAP Rule docket
(EPA-HQ-OAR-2008-0644)

Q & A Session:

Q: Various concerns exist regarding the current SNAP list finding
acceptable numerous refrigerants that do not have appropriate/approved
servicing equipment. What is EPA going to do about that?

A: Under current regulations EPA requires the use of unique fittings and
labels to avoid cross-contamination of MVAC systems. Also, EPA provides
on the regulations requirements for the approval of equipment to extract
refrigerants, acceptable under SNAP, other than CFC-12 and HFC-134a. EPA
prohibits intentional venting of any refrigerant. 

Q: The industry understands there are refrigerants (blends) on the
market that may be cheaper than HFO-1234yf and there are no current
industry standards for control and safety of these blends. What would be
EPA’s actions for that?

A: Based on EPA regulations SNAP is not currently mandating the use of
any particular refrigerant but offers alternatives to be used under
certain specifications described by the regulations. When EPA receives a
submission under the SNAP program, the agency reviews risks on
environment and human health prior finding acceptable any refrigerant.

Note: The inquirers expressed concerns of venting due to the lack of
control of “SNAP-approved” refrigerant blends in the market since
many are accessible to untrained consumers that tend to service the MVAC
system inappropriately and end up venting the refrigerant into the
atmosphere because service equipment for most blends are currently
unavailable or inaccessible. 

Q: EPA received a petition to “un-SNAP” (remove from the SNAP list)
HFC-134a. What is being done about that?

A: EPA is currently reviewing the petition and will issue a response as
soon as the revision process ends. EPA understands it has 90 days to
respond after the petition is received. 

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ICCC Meeting

During the meeting attention was brought on the standards with technical
issues pending to solve. Some of the standards discussed were:

SAE J639, Safety Standards for motor Vehicle Refrigerant Vapor
Compression Systems

SAE J2727, HCF-134a Mobile Air Conditioning System Refrigerant Emission
Chart

SAE J2844, R-1234yf New Refrigerant Purity and Container requirements
Used in Mobile Air Conditioning Systems 

SAE J639 – Fittings and labeling issues

The industry found issues regarding the similitude of HFC-134a fittings
and HFO-1234yf that could lead to possible cross-contamination of MVAC
systems. 

Labeling issues were discussed as well. Further review of fitting
dimensions and labeling color was considered and final agreements were
going to be presented on Thursday, July 15, 2010, on a subsequent ICCC
meeting. After revisions and agreements are done, the standards are sent
into “ballots” where industry members vote to accept or decline the
decisions adopted during the ICCC meeting. 

SAE J2727 – Under revision

OTAQ’s rule regarding GHG limits on vehicles makes references of a
previous version of this standard.  The Agency may use this standard to
issue further regulations on emissions. 

SAE J 2844 – Labeling requirements on containers

ICCC member discussed whether to include a detailed label, describing
compliance with the standard. Issues were discussed regarding confusion
with DOT’s labeling system.

SAE J2844 – HFO-1234yf refrigerant purity issue

Concerns were raised about inconsistent concentrations of “trace
impurities” containing HFO-1225ye which is considered considerably
toxic. Manufacturers discussed issues regarding what may be the
“safe” concentration of this trace impurity (40 ppm, 70 ppm, or 150
ppm). Consensus was not attained on impurity concentration and concerns
remains on toxicity of HFO-1225ye. Manufacturers agreed to performs
further reviews before making a final decision. 

July 14, 2010 meeting notes

MAC Indirect Emission Workshop

Mobile Air Conditioning Test Development Procedures

Presenter: Klaus Steininger, European Commission

EU commission representative presented an overview on test procedures
and conditions to develop standards for MVACs. Procedures focused on
fuel consumption and overall system efficiency. 

National Renewable Energy Lab (NREL) Research on MVACs

Presenter: John P. Rugh

Research was done on effective passenger cabin cooling, analyzing
several factors including ambient temperatures and humidity, A/C
operation (high, low), vehicle operation and driving patterns, fuel
consumption and solar load. The study assumed the highest load during
the first minutes of driving, while the A/C is on and steady state
conditions while the vehicle was driven at constant-like pattern (e.g.,
highway driving). NREL studies shows glazed windows help reduce 5.5%
(KW) MVAC load in the vehicle. Furthermore, a 4.5gCO2/mi reduction could
be achieved with the use of this technology. Further studies may include
cooling performance analysis when vehicle ignition on and off. 

EPA’s GHG Emissions and CAFE Standards

Presenter: Brian Nelson

EPA’s final rule “Light-Duty Vehicle Green House Gas Emission
Standards and Corporate Average Fuel Economy Standards” regulates
direct and indirect emissions. Based on SAE I-MAC team 2 studies, a 50%
reduction of refrigerant leakage can be attained. EPA used 50% leakage
reduction to establish maximum direct credit for vehicles. Higher
credits could be achieved when sealed electric compressor technologies
and/or low GWP refrigerants are used. As described in the final rule,
CO2 impact due to indirect emissions is 14.9g/mi. Indirect emissions can
be calculated using the table indicating indirect emission values for
certain components. Further details on how to determine direct and
indirect emission credits may be obtained from EPA’s final rule (75 FR
25324).

CARB’s Indirect Emissions Standards

Presenter: Leela Rao, Ph..D.

The state of California is proposing to issue credits based on “PAVLEY
– AB 1493”. If a MVAC industry meets all the criteria of a system
with reduced emissions of 9.0g/yr CO2 equivalent, it may become eligible
to obtain CARB’s credits. Methods used to determine CARB’s emissions
credits includes modeled results presented in NESCCAF (2004), vehicle
simulation modeling using CRUISE model and other analytic tools. 

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July 15, 2010 meeting notes

ICCC Meeting Conclusions and OEM/Regulator Discussion on Indirect MAC
Emissions Workshop

ICCC Meeting Conclusions 

ICCC members reviewed issues with SAE J standards 639 and 2844 since
those presented the most concerns. Members agreed to change the
dimensions of the high-pressure side fitting to avoid misuse with
HFC-134a fittings (since both fitting showed compatibility previously).
The new dimensions are unique and will help avoid MVAC system
cross-contamination and other safety issues. Members agreed to continue
reviewing alternatives to address refrigerant purity as per SAE J2844.
Both standards will go to ballot after further agreements within members
are done (specifically on SAE J2844). Since SAE J639 covers as a summary
all MVAC related SAE standards. Its finalization depends on total
consensus for all other standards. 

OEM/Regulator Discussion on Indirect MAC Emissions Workshop

This meeting focused mainly on fuel efficiency regarding MVAC use.
European and US industry, research and regulatory sectors are searching
for consistent testing methods to evaluate fuel consumption and MVAC
system efficiency effectively. OEMs and regulators (EPA and CARB) agreed
to organize periodic meetings (bi-monthly) to discuss technology and
regulatory approaches to assess MVAC and overall vehicle power train
efficiency. OEMs recognized that MVAC efficiency and GHG reduction may
not only be attained by the type of refrigerant used but on complex
factors such as MVAC system and vehicle components, driving patterns,
and ambient factors. 

 MAC (Mobile air conditioner) = MVAC (Motor vehicle air conditioner)

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