Therefore, the phrase "This technology is very attractive..." reflects a judgment
with which reasonable people may disagree because of what may be assumed for
the innovative process in the future. But, today, it is more efficient not to use
hermetic systems with conventional vehicles. Electricity can be a more flexible
form of energy and may offer potential for innovative new ways to do things that
are yet to be invented. However, other things held constant (no new innovation),
the hermetic system would be inferior in terms of energy efficiency and may
create other problems as well.
5. Several places in the draft technical paper, it is stated that improved vehicle air
conditioners are vital to the successful commercialization and customer
acceptance of electric, fuel cell, hybrid, and other high-efficiency vehicles. In
most cases, however, there is no choice but to use an electric drive system and
these vehicles typically have relatively high voltage available, much higher than
42 volts. Because a system based on mechanical to electrical, then modulated
electrical, and then finally back to mechanical energy would have a hard time
competing with a straight mechanical to mechanical belt system, the case for
hermetic systems has been overstated in the technical paper. But, such
limitations need to be minimized and other innovations developed to bring the
operation of such systems to acceptable performance levels.
6. The paper creates unrealistic expectations with respect to
hydrocarbon/flammable systems and transcritical carbon dioxide systems. The
draft technical paper states that:
"It is estimated that systems with flammable refrigerants could be
implemented in the first vehicles in as little as 4-5 years."
We believe this projected time frame is unrealistic due to potential safety and
recall concerns. Until a manufacturer has addressed all potential safety issues
and customer problems with such AC systems, it is unlikely to take the risk of
putting such vehicles into the field. AC systems are a relatively expensive part
of a vehicle, and problems do not always surface immediately, or are not fully
understood, until some time after the vehicle hits the market. The risk of having
to recall several model years' worth of vehicles means that manufacturers are not
likely to proceed without an exhaustive risk assessment in hand. Product
liability and recall concerns may well prevent, and will certainly delay, a
wholesale switch to flammable refrigerants. Society is unlikely to accept even a
very low rate of fires and accidents during vehicle operation or during repair and
maintenance. Deaths and serious injuries have occurred in other sectors that
bave switched from HFCs to flammable substances. With millions of vehicles
on the road, a few incidents are likely to occur and society may find this
Likewise, transcritical carbon dioxide systems also must undergo risk
assessment. The statement that such systems could also be ready in as little as 4-
5 years ignores the potential for recall and retrofit should safety problems
develop for vehicle owners or the service industry. Earlier versions of the paper
had estimates of 4-7 years, and we are not aware of the basis for the original or
the new reduced time span, other than they were guesses based on updated test-
fleet announcements.
7. The Paper states (p. 8):
"The Partnership is investigating the technical feasibility, environmental
performance, and cost of these systems in configurations that satisfy safety
and reliability criteria. It is anticipated that any of the options can be
designed to be safe and reliable with equivalent cooling and heating
performance but at added cost."
This statement is inappropriate for the Technical Paper. Wherever it is placed,
there is no an indication as to who is "investigating" these matters and who is
funding that investigation, nor is there an indication of any funding source or
amount for that investigation. Currently, it is only individual manufacturers and
suppliers that are performing such investigations as the Partnership only
collected information from such sources.
Also, the last sentence in the quote above is troublesome because it suggests that
increased cost can solve all problems, which is not a very helpful, nor
necessarily a correct conclusion.
8. SAE, EPA, and others were instrumental in the effort to set industry guidelines,
develop service procedures, and coordinate agreements governing the switch
from CFC-12 to HFC-134a in motor vehicle air conditioners in accordance with
the Montreal Protocol and the Clean Air Act. It is widely agreed (both then and
now) that HFC-134a is a significant improvement over its predecessor, CFC-12:
> It is a complete (100%) solution from a stratospheric ozone depletion
standpoint;
Its global warming potential is six times lower than CFC-12;
➤ Improvements were made by manufacturers in making AC systems
> EPA recognizes it as an acceptable substitute in its regulations.
The effort to switch to HFC-134a has been a resounding success, and many
public and private organizations can claim a share of the credit. The question
needs to be answered why so soon after that success, another process aimed at
further changes to AC systems is being formulated in addition to efforts already
underway.
9. The Partnership is not the appropriate place for hardware development. In the
CFC-12 to HFC-134a switch, hardware development was up to each individual
manufacturer and their suppliers. The cost was born by manufacturers,
suppliers, and the service industry, amounting collectively to more than $5
billion spent in the United States alone. From what we can surmise, $5 billion
would be dwarfed by the cost of implementing some of the technologies
mentioned in the draft paper. In addition, the larger environmental benefit in
going from CFC-12 to HFC-134a (from both the ozone depletion and climate
change perspectives) far surpasses any environmental benefit for moving from
HFC-134a to a new AC technology. In short, we believe that the Partnership is
poorly equipped to address hardware development but might have a role in other
areas that need to be identified.
I am writing to respond to your April 20, 2000 letter concerning the Mobile AC Climate
Protection Partnership and its technical paper.
The Partnership-which was organized by the Society of Automotive Engineers, EPA,
and the Mobile Air Conditioning Society World-was conceived in July 1999 at the
Society of Automotive (SAE) "Phoenix Forum" and announced at the September 1999
"Earth Technologies Forum." Several dozen experts from a wide range of
organizations-including Ford's Visteon Division-were involved in planning the
The partnership has three goals. Its first goal is to minimize leakage and other sources of
emissions from current HFC-134a mobile air conditioning systems by promoting cost-
effective designs and improved service procedures. The second goal is to cooperate on
development and testing of “next-generation” mobile air conditioning systems that will
satisfy customer requirements and meet environmental, safety, cost, and reliability
concerns. The third goal of this voluntary program is to communicate technical progress
to policy makers and the public.
This voluntary partnership will provide environmental benefits in pollution prevention
and increased energy efficiency. It seeks to address technical issues in a credible manner
drawing both from industry and government participants.
Internet Address (URL) • http://www.epa.gov
Kelly M. Brown
Page 2 of 2
The comments accompanying your letter credit SAE, EPA, and others as instrumental in
cooperative efforts during the past decade to manage the successful transition from CFC-
12 to HFC-134a air conditioning refrigerants. The new Partnership will be co-chaired by
the same individuals who led that effort-Ward Atkinson (SAE), Simon Oulouhojian
(MACS) and me. Several of the Partnership technical advisors and peer reviewers also
have more than ten years of experience working on cooperative government-industry
teams. We are committed to bringing the experience gained in that effort to this new
cooperative venture.
The technical paper that is posted on the SAE web site was developed by consensus of
several dozen experts, including those of Ford's Visteon Division. Their names and
organizational affiliations are listed on the paper. Of the organizations participating in
the development of the paper, only Ford Motor Company chooses not to be listed as an
advisor or peer reviewer. Participation in the Partnership is in no sense closed. Experts
from Ford, other companies, the Alliance of Automobile Manufacturers, and other trade
organizations are welcome to participate as technical experts in future activities of the
Partnership
As you know, I discussed the Partnership in September 1999 with John Shiller (Ford
Emissions Control Analysis & Planning Department) and Duane Johnson (Ford
Environmental Quality Office). I would welcome the opportunity to sit down with you
and other Ford experts to discuss ways of broadening Ford's participation now that
Visteon has been spun off as a separate corporate entity. Please contact me if you or your
staff wish to further discuss your specific concerns or technical comments.
Stephen O. Andersen
Climate Protection Division
Ward Atkinson, Sun Test Engineering
Robert Babik, Alliance of Automobile Manufacturers
Wael Berrached, Society of Automotive Engineers
Simon Oulouhojian, Mobile Air Conditioning Society Worldwide
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