Almost every new car has air conditioning. Almost every car air conditioner uses a refrigerant called HFC-134a, a “super greenhouse gas” with 1430 times the global warming punch, pound for pound, as carbon dioxide. In a welcome move, the auto industry is on the verge of a world-wide transition from this potent climate-changing gas to an alternative with the clunky name HFO-1234yf and roughly 1/360th the global warming impact -- it has a “global warming potential” (GWP) of only 4.
Here in the U.S., the transition is being driven by the Obama administration’s landmark clean car and fuel economy standards. The EPA component of those standards, issued under the Clean Air Act, covers all four climate-changing pollutants (carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons), and sets a combined standard for all of them weighted on a carbon dioxide equivalent basis. This creates a strong incentive to shift from 134a to 1234yf as the standards tighten year-by-year, and some car makers have started to use the new refrigerant in some models.
In Europe, after several delays, the European Commission’s F-Gas Directive for mobile air conditioning is finally slated to take effect January 1, 2013, after which it will be illegal to sell a “new type” model with a refrigerant that has a GWP greater than 150. A “new type” car is basically a major redesign, which occurs to all vehicles every few years. So the refrigerant change-over should start in Europe next month and cover more and more models over succeeding years.
That’s unless Daimler, maker of Mercedes Benz, gets its way.
Until September of this year, Daimler, together with all other major auto makers, was on board the transition to 1234yf.
The auto industry has rigorously tested 1234yf’s performance and safety. It has been known from the start that the chemical is mildly flammable – like many other fluids under the hood, starting with gasoline and diesel fuel. Consequently, both individually and through organizations such as the Society of Automotive Engineers (SAE), the automakers carefully assessed the risks and engineered counter-measures, such as insulating hot surfaces and isolating refrigerant lines from them. The SAE produced guidelines for safe design.
As summarized by the Mobile Air Conditioning Society, the trade association for the aftermarket air conditioning service industry:
HFO-1234yf has been extensively tested, using proven scientific methods, by prestigious industry organizations, independent laboratories, and a group of 15 global vehicle manufacturers organized by SAE International in an industry Cooperative Research Program. At the conclusion of this testing, all of the participants expressed their satisfaction that HFO-1234yf could be used in MAC systems.
The Environmental Protection Agency, European regulators, and other national authorities reviewed and cleared the new refrigerant for safe use.
As recently as September 17th, Daimler was on board with the entire German auto industry in endorsing 1234yf as “a new, safe and environmentally friendly refrigerant” for mobile air conditioning. Their presentation said:
* Ignition of R1234yf is nearly impossible in the engine compartment
considering operating conditions of the vehicle.
* Ignition of R1234yf is impossible inside the vehicle cabin in reality.
* TÜV SÜD confirms: “… in der Praxis ein schwer entzündbares Gas.”
“... very difficult to ignite in reality.”
But one week later, Daimler issued a surprise announcement that it was abandoning 1234yf and reverting to 134a, because the company had performed simulations – not actual crash tests – of a very unusual accident scenario: a car with its engine super-overheated by miles of towing a heavy trailer uphill, or by miles of extreme acceleration and deceleration, was assumed to have immediately suffered a high-speed front-end crash causing the air conditioning refrigerant hose to rupture and spray the refrigerant on the hottest parts of the engine. (No actual crash, but the refrigerant purposely released from a valve.)
And lo! There was a fire!
There’s much speculation on Daimler’s motives. The company apparently sat on its simulations for months before releasing them. After the announcement, Daimler was slow to share its data. Questions have been raised about the representativeness and rigor of the simulations, and about the purity of the compound tested (it was mixed with lubricating oils). Some suggest the company is under serious financial pressures and wants to stick with the current refrigerant, 134a, indefinitely as a cost-cutting measure.
Daimler has since been pleading with the European Commission in Brussels for yet another postponement of the F-Gas Directive deadline. To its credit, to date the Commission has held firm.
Most other car makers also have been holding firm. Signs are that the General Motors, Chrysler, Volvo, and others are confident in their risk analyses and engineering and are sticking with plans to use the new refrigerant.
The Society of Automotive Engineers convened a special panel of car-maker engineers to quickly review Daimler’s tests and to determine whether they call for any change in the group’s prior risk assessment and engineering guidelines. No results are public yet, although rumors are that participants other than Daimler have found no reason to change course, and that Daimler is holding up the report.
Update Dec. 14: The SAE released a statement today that said:
The new CRP [Cooperative Research Program] team began by conducting a detailed review of the original Fault Tree Analysis (FTA) and chose to expand the trees to ensure that newly-identified information and testing from each of the OEMs [Original Equipment Manufacturers] is incorporated. This study has highlighted concerns with relying on one test to be reflective of real world collisions across vehicle applications.
To date, the majority of the OEMs involved in the new CRP do not believe that any of the new information reviewed will lead to a change in the overall risk assessment. Several OEMs have shared test results regarding their vehicles. With the exception of Daimler, no OEM in the CRP has provided information that would suggest a concern for the safe use of R-1234yf in their vehicles.
But Daimler is lobbying relentlessly in Brussels and Berlin for another postponement as the end-of-year deadline approaches. With European officials home from the Doha climate change conference, most observers expect matters to come to a climax, one way or the other, within the next week or so.
European environmentalists have weighed in with the European Commission on the urgency of rapidly phasing out 134a to protect the climate, and they are urging strict enforcement of the F-Gas Directive without further delays. Even groups with a preference for other refrigerants – such as CO2-based systems – agree that Daimler has had all the lead-time it needs and should not be rewarded now with another delay. The German group DUH, for example, urges the imposition of fines of 665 Euros for each non-conforming vehicle sold.
American and multinational industries and trade associations are also voicing their concerns about the world-wide ramifications of a European delay. The two companies that manufacture and market 1234yf, Honeywell and DuPont, are staunchly defending its safety and questioning the realism and credibility of Daimler’s latest tests. The Mobile Air Conditioning Society told the EC:
[I]t is important that the [current] mandate be observed without any further delay. If a firm mandate suddenly becomes indefinitely flexible, then our members will lose confidence in the process, and it will be more difficult for them to commit resources to support future initiatives.
We ask that the EU hold to their strong record of environmental leadership and take any and all actions necessary to see that the EU Directive … is enforced post haste now that compliant refrigerants, meeting internationally recognized standards, are freely available in the marketplace.
American environmental organizations also have raised their voices. The Natural Resources Defense Council (NRDC) and the Institute for Governance & Sustainable Development told the EC in a letter earlier this week:
The fact that R-1234yf is mildly flammable has been known for years. Following SAE standards, auto manufacturers can design vehicles to use this refrigerant safely just as they manage the many other flammable fluids found under the hoods of their vehicles. A failure of Daimler to design safe mobile air conditioning systems should lead to a recall and correction of the faulty design, not to abandonment of a technology proven to protect climate. Of course, Daimler had the option under the F-gas Directive to adopt other alternatives, such as CO2 systems, and the company had ample time to make its choices. Daimler should not now be rewarded with additional time to use HFC-134a while it further considers CO2 systems.
We suggested that Daimler either be fined or “required to provide offsetting carbon pollution reductions, for example, by further accelerating fuel economy improvements” until it adopts an air conditioning system that complies with the F-Gas Directive by using 1234yf or another refrigerant with GWP less than 150.
So will Daimler’s last-minute gambit pay off with another postponement? Or will the European Commission enforce its laws, stand by its commitment to protecting the climate, and hold Daimler to its responsibilities?