Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program Under the American Innovation and Manufacturing Act; Proposed Rule
July 6, 2021
EPA's proposed HFC trading system is based on bad data and fails to adequately account for the costs of the rule, and thus should be rewritten.
The U.S. Environmental Protection Agency's (EPA) HFC phase out rule amounts to an justified war on refrigeration. The rule is based in nearly non-existent data. It will benefit big firms competing with smaller firms and will impose high costs on the present poor for unknowable benefits delivered 300 years from now. Only after up-to-date data is gathered on the present levels of HFC usage, and an adequate accounting of the costs of the phase-out is calculated, should EPA then propose a rule to limit the use of HFCs.