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Comments on EPA Rollback of Refrigerant Substitutes Regulation

EPA recently proposed rolling back regulatory provisions that curb emissions of refrigerant substitutes, which are highly potent greenhouse gases. The agency admits that the rescissions would significantly increase the release of refrigerator hydrofluorocarbons (HFCs) but fails to monetize the climate damages caused by forgone emissions reductions. We submitted comments explaining how EPA should value the climate damages of these greenhouse gases.

The agency supports its proposed rescissions by monetizing their alleged cost savings. It is arbitrary and misleading, however, to calculate savings without estimating the damages caused by the same deregulatory action. While the federal Interagency Working Group (IWG) has not developed social cost metrics specific to hydrofluorocarbons, we recommend EPA apply the Social Cost of Carbon to the carbon dioxide-equivalent of HFC emissions. EPA estimates, for example, an increase of 5,266,000 metric tons of carbon dioxide-equivalent emissions in the year 2020. Monetizing these climate damages using the Social Cost of Carbon, even indirectly, is crucial to rational analysis of the proposed rescissions.