Statement of the U.S. Delegation on Hydrofluorocarbons (HFCs)
Thank you, Mr. Co-Chair. We have appreciated the opportunity this week – both at this meeting and at the Dialog -- to learn about and discuss the issue of high global warming potential (GWP) alternatives to hydrofluorocarbons (HFCs). The reports presented during these meetings and the discussion here have provided a great deal of information on the availability and efficacy of alternatives to HFCs. We appreciate the efforts of the secretariats of the Montreal Protocol and the United Nations Framework Convention on Climate Change (UNFCCC), the Montreal Protocol’s Technology and Economic Assessment Panel (TEAP), its Science Advisory Panel (SAP), and other Parties to prepare for and participate in these meetings, which are setting the stage for a productive discussion at the 21st Meeting of the Parties from November 4-8, 2009, in Port Ghalib, Egypt.
Our delegation drew a number of important conclusions from the discussion at the Dialog. Most important of those is this: If left unchecked, HFC emissions will grow enormously over the next several decades -- this is a cause for serious concern and a call to action. The information presented suggests that there are alternatives for HFCs in many -- but not all -- applications at this time. When considering alternatives to HFCs it is also important to take into account their energy efficiency and other environmental consequences. We should be careful to ensure that any action taken on HFCs does not hinder the accelerated phaseout of HCFCs agreed two years ago by this forum. A number of delegations also raised the importance of considering linkages to the UNFCCC and climate discussions taking place this year. We agree that such linkages are important, but do not believe that we must here wait to engage on this issue.
We are grateful to the Governments of the Federated States of Micronesia and of Mauritius for putting forward their proposed amendment to the Montreal Protocol that would bring HFCs under this instrument. Before discussing certain aspects of this amendment proposal, let me be clear that the United States has not yet taken a position on it. Nevertheless, we believe that it merits serious consideration by this body, and that it is consistent with the objectives of the Vienna Convention. We see no legal obstacle to controlling HFCs under the Montreal Protocol. Controlling HFCs would fall within the Vienna Convention’s Article 2.b. stating as an objective of the Convention to “cooperate in harmonizing appropriate policies” related to the phaseout of ozone depleting substances. In our view, such “harmonized policies” could include managing the transition from chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) past HFCs and into other technologies and substances. Thus, we do not need to amend the Vienna Convention to control HFCs under the Montreal Protocol. Moreover, we think it possible to establish arrangements between the Montreal Protocol and the UNFCCC to manage HFCs responsibly and efficiently as early as this year.
We are not in a position to provide detailed comments on the amendment proposal at this time, but we would like to share our conceptual thinking on certain elements included in it. First, the discussion in this room has already emphasized the fact that there are alternatives for some --but not all -- HFC applications. The phasedown approach of the amendment proposal -- as opposed to a phaseout -- appropriately reflects this fact. However, we believe that the rate of transition, and the end point of the transition, may be too ambitious for Article 2 countries as proposed. It will also be important to ensure that baselines are appropriately established such that they account for both HFC and HCFC consumption and production if they are historically set.
It is clear that the major environmental benefit of this proposal stems from early action to check the growth in HFCs that is projected over the next several decades. The progress to be made in Article 2 countries will send strong signals to the market that will spur the development and commercialization of climate- and environment-friendly alternatives. The path forward should reflect the need not only for progress in Article 2 countries, but for commitments from Article 5 countries to stop the growth and make progress in reducing reliance on HFCs. Both Article 2 and Article 5 Parties will need to make commitments for any approach to make progress, and in fact this is the model in this forum for all countries to work together to achieve our common environmental goals. Finally, we will need to consider other issues carefully -- such as addressing other HFCs identified by the TEAP (commonly referred to as HFOs) within the scope of the proposal and byproduct emission provisions.
Mr. Co-Chair, I would like to suggest that the mandate of the contact group should be agreed here, recognizing that we are in the early stages of a discussion on this issue. A number of delegates have expressed concern over the lack of information on alternatives, and the need for further analysis or reports better to inform this body. We believe that the contact group should work toward identifying further analysis or information that countries may find useful.
We have identified three different areas where we would like further TEAP analysis that I will briefly describe. First, we would like information on how the current availability of alternatives to HFCs compares with the situation regarding the availability of alternatives to CFCs in the late 1980s. Second, it may be useful to assess -- possibly on a sectoral basis -- those areas where feasible alternatives exist so as to understand, on a global level, the fraction of overall HFC demand that could potentially be replaced. Third, further information would be useful on HFC-23 emission levels and the relation to production of HCFC-22.
The contact group should also have a conceptual discussion of key elements of the amendment proposal, without delving into the text of the proposal itself. A co-chairs’ summary of the discussion could be forwarded to the MOP that would describe the major issues discussed, characterize the nature of the discussion, and identify areas for further clarification or analysis.
We look forward to working with our colleagues at this meeting on a path forward that will allow for robust consideration of this issue at the MOP. Thank you, Mr. Co-Chair.