Memo: Montreal Protocol Compliance
This memo details how the amount of HCFCs allocated in each option discussed in the proposed rule, "Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export," (2011 Proposed Rule for 2012 through 2014) compares to the cap under the Montreal Protocol. All allocations are expressed as ODP-weighted metric tons (ODP-MT). The total U.S. cap between 2010 and 2014 is 3,810 ODP-MT for consumption and 3,884.25 ODP-MT for production. In summary, the U.S. is in compliance with the Montreal Protocol under each of the scenarios discussed in the proposed rule by at least 36 percent for consumption and 33 percent for production.
HCFC-22
There are numerous options discussed as they relate to HCFC-22 allocations in 2012 through 2014. The proposed baselines for all options are identical to the baselines used in the 2011 Interim Final Rule. 
Consumption of HCFC-22
For consumption, these options include:
      1. Allocate the same number of allowances as the 2009 Final Rule -- 
         A. plus recoupment in 2013 (recoupment option 1)
         B. plus recoupment in 2013 and 2014 (recoupment option 2)
         C. including recoupment in 2013 and 2014 (recoupment option 3)
         D. with no recoupment (recoupment option 4)
Consumption Allocation equivalent to the 2009 Final Rule (ODP-MT)
                                       
                         Allocation before Recoupment
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                     2,239
                                       -
                                       -
                                       -
                                       -
                                     2013
                                     1,974
                                      325
                                      162
                                       -
                                       -
                                     2014
                                     1,709
                                       -
                                      162
                                       -
                                       -
         
      2. Allocate between 11 and 47 percent fewer allowances than in the 2009 Final Rule -- 
         * plus recoupment in 2013 (recoupment option 1)
         * plus recoupment in 2013 and 2014 (recoupment option 2)
         * including recoupment in 2013 and 2014 (recoupment option 3)
         * with no recoupment (recoupment option 4)
Consumption Allocation is 11 to 47 Percent Smaller than in the 2009 Final Rule (ODP-MT)
                                       
                               Larger Allocation
                                   Scenario
                          Smaller Allocation Scenario
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                     1,990
                                     1,381
                                       -
                                       -
                                       -
                                       -
                                     2013
                                     1,724
                                     1,147
                                      325
                                      162
                                       -
                                       -
                                     2014
                                     1,443
                                      905
                                       -
                                      162
                                       -
                                       -
N.B.: The specific reductions for each year are listed and explained in the "Adjustment Memo" included in the docket.
Production of HCFC-22
For production, these options include: 
      1. Allocate production at the same percentage as consumption, where the baseline percentage is such that total consumption allocation is the same as in the 2009 Final Rule --  
            a. plus recoupment in 2013 (recoupment option 1)
            b. plus recoupment in 2013 and 2014 (recoupment option 2)
            c. including recoupment in 2013 and 2014 (recoupment option 3)
            d. with no recoupment (recoupment option 4)
Production Allocation Based on 2009 Final Rule Consumption Allocation (ODP-MT)
                                       
                         Allocation before Recoupment
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                     2,038
                                       -
                                       -
                                       -
                                       -
                                     2013
                                     1,796
                                      254
                                      127
                                       -
                                       -
                                     2014
                                     1,555
                                       -
                                      127
                                       -
                                       -
               
      2. Allocate production at the same percentage as consumption, where the consumption allocation is reduced by 11 to 47 percent --   
            a. plus recoupment in 2013 (recoupment option 1)
            b. plus recoupment in 2013 and 2014 (recoupment option 2)
            c. including recoupment in 2013 and 2014 (recoupment option 3)
            d. with no recoupment (recoupment option 4)
Production Allocation Based on Lower Percentages of Baseline for Consumption (ODP-MT)
                                       
                    Range of  Allocation Before Recoupment
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                 1,257 - 1,811
                                       -
                                       -
                                       -
                                       -
                                     2013
                                 1,044 - 1,569
                                      254
                                      127
                                       -
                                       -
                                     2014
                                  824 - 1,314
                                       -
                                      127
                                       -
                                       -
         
      3. Allocate production at the same percentage as 2009 Final Rule, such that there is an increase in the production allocation as compared to the 2009 Final Rule --   
            a. plus recoupment in 2013 (recoupment option 1)
            b. plus recoupment in 2013 and 2014 (recoupment option 2)
            c. including recoupment in 2013 and 2014 (recoupment option 3)
            d. with no recoupment (recoupment option 4)

Production Allocation Using Percentages of Baseline from the 2009 Final Rule (ODP-MT)
                                       
                         Allocation Before Recoupment
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                     2,421
                                       -
                                       -
                                       -
                                       -
                                     2013
                                     2,137
                                      254
                                      127
                                       -
                                       -
                                     2014
                                     1,853
                                       -
                                      127
                                       -
                                       -
HCFC-142b
There are numerous options discussed as they relate to HCFC-142b allocations in 2012 through 2014. The proposed baselines for all options are identical to the baselines used in the 2011 Interim Final Rule.  
Consumption of HCFC-142b
For consumption, these options include allocating the same number of allowances as the 2009 Final Rule --  
   * plus recoupment in 2013 (recoupment option 1)
   * plus recoupment in 2013 and 2014 (recoupment option 2)
   * including recoupment in 2013 and 2014 (recoupment option 3)
   * no recoupment (recoupment option 4)
Proposed Consumption Allocation in ODP-MT
                                       
                          Allocation Before Recoupment
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                       7
                                       -
                                       -
                                       -
                                       -
                                     2013
                                       7
                                       4
                                       2
                                       -
                                       -
                                     2014
                                       7
                                       -
                                       2
                                       -
                                       -
Production of HCFC-142b
For production, these options include allocating the same number of allowances as the 2009 Final Rule --   
   * plus recoupment in 2013 (recoupment option 1)
   * plus recoupment in 2013 and 2014 (recoupment option 2)
   * including recoupment in 2013 and 2014 (recoupment option 3)
   * no recoupment (recoupment option 4)
Proposed Production Allocation in ODP-MT
                                       
                         Allocation Before Recoupment 
                 Additional Allowances  [Recoupment Option 1]
                 Additional Allowances  [Recoupment Option 2]
                 Additional Allowances  [Recoupment Option 3]
                 Additional Allowances  [Recoupment Option 4]
                                     2012
                                      30
                                       -
                                       -
                                       -
                                       -
                                     2013
                                      30
                                      26
                                      13
                                       -
                                       -
                                     2014
                                      30
                                       -
                                      13
                                       -
                                       -
Other HCFCs
This rulemaking does not affect the allocations for HCFC-123, HCFC-124, HCFC-225ca, and HCFC-225cb. The resulting amount allocated in each year between 2012 and 2014 is:
Consumption 				        Production
                                   Chemical
                               ODP- MT Allocated
                                       
                                   Chemical
                               ODP- MT Allocated
HCFC-123
                                      50
                                       
HCFC-123
                                       0
HCFC-124
                                      66
                                       
HCFC-124
                                      111
HCFC-225ca
                                       9
                                       
HCFC-225ca
                                       8
HCFC-225cb
                                      12
                                       
HCFC-225cb
                                      15
Total
                                      137
                                       
Total
                                      135

All HCFCs Combined

HCFC Consumption Allocation using Highest Proposed Allocation for HCFC-22 (ODP-MT)
Montreal Protocol cap: 3,810 ODP- MT
                                       
                    Highest Allocation without Recoupment 
                    Total Allowances  [Recoupment Option 1]
                    Total Allowances  [Recoupment Option 2]
                    Total Allowances  [Recoupment Option 3]
                    Total Allowances  [Recoupment Option 4]
                                     2012
                                     2,383
                                     2,383
                                     2,383
                                     2,383
                                     2,383
                                     2013
                                     2,118
                                     2,446
                                     2,282
                                     2,118
                                     2,118
                                     2014
                                     1,852
                                     1,852
                                     2,017
                                     1,852
                                     1,852
Each option is at least 36 percent below the Montreal Protocol Cap
HCFC Production Allocation using Highest Proposed Allocation for HCFC-22 (ODP-MT)
Montreal Protocol cap: 3,884.25 ODP- MT
                                       
                     Highest Allocation without Recoupment 
                    Total Allowances  [Recoupment Option 1]
                    Total Allowances  [Recoupment Option 2]
                    Total Allowances  [Recoupment Option 3]
                    Total Allowances  [Recoupment Option 4]
                                     2012
                                     2,586
                                     2,586
                                     2,586
                                     2,586
                                     2,586
                                     2013
                                     2,302
                                     2,582
                                     2,442
                                     2,302
                                     2,302
                                     2014
                                     2,018
                                     2,018
                                     2,158
                                     2,018
                                     2,018
Each option is at least 33 percent below the Montreal Protocol Cap
