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Weighing the A/C facts

Aftermarket Business/February 2010

The Environmental Protection Agency (EPA) seems ready to inhibit retail sales of the soon-to-be-approved air-conditioning refrigerant expected to replace R-134a. The agency is about to publish a significant new use rule (SNUR) regarding HFO1234yf (R-1234), the R-134a replacement. The SNUR is half of a two-part regulatory approval process.

The other half is EPA approval of R-1234 within its significant new alternatives policy (SNAP) program. The SNAP proposed rule implied that the SNUR would restrict use of R-1234 by do-it-yourselfers (DIYers).

At the end of 2009, the EPA extended the comment period on the SNAP proposed rule to Feb. 1, 2010 because of a request from the Automotive Refrigerant Products Institute and the Automotive Aftermarket Industry Association (AAIA). Michael Conlon, a Washington attorney who represents the groups, asked for the delay because the aftermarket industry wants to be able to review the SNUR before commenting on SNAP requirements. At the time of publication, Conlon expected the SNUR to come out soon in the form of a direct final rule, meaning any DIYer restrictions would be a done deal, unless opponents raised their voices. “Procedurally, if someone objects to a direct final rule, EPA has to withdraw it and start over,” Conlon explains.

Margaret Sheppard, the EPA official heading the SNUR, did not respond to a request on that announcement’s timeline.

We already reported on the proposed SNAP, approving R-1234 as the “green” successor to R-134a, the current global auto air-conditioning refrigerant of choice, which is being phased out in Europe and is likely to disappear in the U.S. soon, in part because of the EPA’s vehicle emissions rulemaking, which aims to improve mileage and decrease GHG emissions from vehicle tailpipes.

SNAP and SNUR regulatory proceedings are “inextricably intertwined,” according to a letter sent to the EPA by the Automotive Refrigerant Products Institute (ARPI) and AAIA, because the SNAP proposed rule said: “Consumer exposure from filling, servicing or maintaining MVAC systems without professional training and the use of section CAA Section 609 certified equipment may cause serious health effects.” In their letter, the two trade groups argued that the EPA cannot regulate a new refrigerant under its new chemical program unless it finds that Section 609’s refrigerant regulations (within SNAP) are insufficient to the task. The stratospheric protection division, which has authority over Section 609, has done numerous previous rulemakings on alternative vehicle refrigerants, and has the technical expertise to decide whether R-1234 requires limitations on “do-it-yourselfer” (DIYer) use.

The EPA concern is that consumers who buy R-1234 and then work with their vehicle’s air-conditioning system might be overcome by the chemical’s toxicity, or its flammability. But DIYers would only be using a couple of cans to service their own auto. Moreover, a study done for the Society of Automotive Engineers by Gradient Corporation found that there was little if any risk of an explosion under the hood caused by R-1234. If there were flammability concerns, it would be with large quantities stored in a warehouse, or in a retailer’s backroom; but even that threat would be remote. EPA concern about toxicity seems a stretch, too, as an argument it leans on is that there is a danger when a refrigerant can is held upside down for a period, but not when it is right-side up.

Aside from DIYer use restrictions, which could be included in the upcoming SNUR, there is continuing concern with the proposed conditions of use in the SNAP proposal, which includes requiring automobile manufacturers to make changes to the design of air-conditioning systems to mitigate any potential leakages of R-1234. If those steps are finalized, that would mean that all the cars on the road today using R-134a COULD NOT be retrofitted to use R-1234 for reasons having to do with engineering complexity.

U.S. to work with China on EV development

Automotive Engineering/January 2010

The U.S.-China electric-vehicles initiative announced while President Obama was in China in November caught some in the American vehicle industry by surprise. The initiative covers four areas, initially thought to include standards, with the details of exactly what is going to be done in each still to be worked out. Extensive work already has been done in some of those areas within the U.S. auto community, and without Chinese participation.

There were mixed reactions to the announcement. One spokesman for a U.S. company says there was little "substance or thought behind it." He views the initiative as a public relations gesture.

But Brian Wynne, President of the Electric Drive Transportation Association, is very positive. He says the four areas were developed at a forum in Beijing in September organized by the U.S. Department of Energy and its Chinese counterpart, the China Ministry of Science and Technology. There were about 50 U.S. participants at that meeting.

"Listening to the Chinese talk was an enlightening experience," said Wynne. "Their industry is facing the same challenges from an economic and technical standpoint as our industry. If we can help each other, we will get there faster."

To the extent that there was some confusion or uncertainty about the announcement, it may have been because of some unclear verbiage in the White House press release, which mentioned as the four areas of cooperation joint standards, joint demonstrations, joint public awareness and engagement, and a joint technical roadmap.

Phyllis Yoshida, Deputy Assistant Secretary for International Energy Cooperation at the DOE, is intimately familiar with the initiative. She said the White House statement on the four areas should not have mentioned standards. In an interview with AEI, she emphasized there was no thought of forcing SAE International or any other EV standards group to go back and get Chinese input into nearly completed standards.

"Hopefully, we will get the Chinese to adopt the SAE standards," she said.

Instead of mentioning standards, the White House statement should have listed the testing of standards as one of the four areas, said Yoshida, adding that the U.S. is doing something similar with European countries and hybrids at Argonne National Laboratory.

Jack Pokrzywa, SAE Director of Ground Vehicle Standards at SAE, said SAE technical standards committees are on the cusp of delivering about 20 EV-related standards in the near term. He pointed out that the standards have been vetted by experts from countries around the globe.

SAE standards such as J2836/1 through /5 “Use Cases for Communication between Plug-in Vehicles and the Utility Grid"; SAE J2847/1 through /5 “Communication between Plug-in Vehicles and the Utility Grid”; and SAE J1772 “SAE Electric Vehicle Conductive Charge Coupler” provide foundation to the rest of the standards suite. "SAE and their partners—the Chinese Automotive Technology and Research Center (CATARC)—have a good working relationship focused on standards development, among other initiatives," Pokrzywa added.

Yoshida explained that the next step in implementation of the U.S.-China EV initiative is to sit down and talk again with the Chinese about specifics. "There has been some activity," she said. "We are already talking to them about cities in both countries which could participate in demonstrations."

Of course, the Big Three U.S. automakers are already deep into EV demonstrations funded in 2008 by the George W. Bush DOE. This past August, Ford Motor Co. announced it was moving forward with its demonstration project involving Escape plug-in hybrids using an intelligent vehicle-to-grid communications and control system. This new technology—which builds on Ford’s advancements such as SYNC, SmartGauge with EcoGuide, and Ford Work Solutions—allows the vehicle operator to program when to recharge the vehicle, for how long, and at what utility pricing rate.

Any joint U.S.-China EV demonstrations may be worth more to smaller, entrepreneurial U.S. EV start-ups such as Coda, Tesla, and Fisker, who have a much smaller presence, if they have one at all, in the booming Chinese market, as opposed to General Motors, Ford, and Chrysler, who have marketing arms, joint R&D operations, and other contractual links there.

Mark Duvall, Director of Electric Transportation, Electric Power Research Institute, which is a participant in two of the three DOE-funded EV demonstrations, explained that the Chinese and Americans have taken a different approach to vehicle electrification. Duvall was in Beijing for the September forum. The Chinese have taken a bottom-up approach, starting with scooters but have not taken a major step into manufacturing full function EVs, which is where the Big Three and even Tessler, Coda, and the other smaller companies have begun. So Duvall sees an opening for the smaller companies in China.

"Who is to say Tesla, Coda, Fisker, or someone else can't have a showroom in downtown Beijing," Duvall said.