Comment Log Display

October 29, 2013




Chair Mary Nichols
California Air Resources Board



Re: Comments regarding ARB Scoping Plan actions to promote the use
of low Global Warming Potential (GWP) blowing agents 



Dear Chair Nichols: 

We commend ARB for promoting the use of low-GWP blowing agents in
California within the current ARB Scoping Plan.  Honeywell agrees
with ARB, as stated in the Scoping Plan, that there are a number of
commercially available alternatives to cost effectively replace
existing use of high-GWP blowing agents in California.  Honeywell
has consistently helped manufacturers replace ozone-depleting and
global warming substances and is a recognized leader in developing
high-performance blowing agent technology for closed-cell spray
polyurethane foam insulation, extruded polystyrene board insulation
and advanced energy efficient refrigerants.

Today in California, high-GWP foam blowing agents incorporated into
polyurethane and polystyrene foams are installed every day onto
roofs, wall cavities of unfinished walls, against the interior side
of sheathing, and through holes drilled in sheathing or drywall to
insulate new and existing buildings.  The predominant foam
technologies used to insulate buildings and reduce energy usage
utilize high-GWP gases such as HFC-134a (or R-134a), HFC-365mfc, or
HFC-245fa with each being up to 1,200 times more effective at
trapping atmospheric heat than carbon dioxide.  For example, one
twenty-four ounce can of R-134a has the equivalent GWP of one ton
of carbon dioxide, roughly equivalent to the emissions from a car
driven from Los Angeles to New York.

As you know, a new generation of gases and liquids have been
developed called Hydrofluoroolefins (HFOs) that can replace
HFC-134a, HFC-365mfc and HFC-245fa which are commonly used today. 
These new technologies have better characteristics for reducing
climate impacts with no apparent compromise on performance.  
Examples of these include HFO-1233zd(E) and HFO-1234ze(E) produced
by Honeywell and branded under our Solstice line of products. 
These alternatives have GWP values of 1 or less and have multiple
uses in foam insulation as well as aerosol applications such as
dusters and tire inflators among others.  These cost effective,
safe and commercially available alternatives are readily available
and can reduce the GWP impact of existing products by more than
100X.  In fact, users of this emerging technology have found it
cost effective with realized increases in energy efficiency
performance, improvements in material properties and no significant
equipment or processing changes. 

With California leading a number of new initiatives to support
greater energy efficiency in school buildings (Proposition 39), in
existing Buildings (AB 758-Skinner) and now in the ARB Scoping
Plan, low-GWP products should be promoted to ensure state GHG
reduction measures are making net GHG reductions over the long
term.  A key opportunity for GHG reductions within California is to
encourage the replacement of 134a, HFC-365mfc and HFC-245fa for use
in insulating foam applications and propellant applications.  As
mentioned in the existing Scoping Plan, low-GWP alternatives to
foam blowing agents are readily available and are gaining
acceptance globally.  For example, 1233zd(E) is currently being
used in construction and appliance applications in the US, Japan,
and next year in even China. Similarly, 1234ze (E) is currently
being used in polystyrene, foam and aerosol applications.

Thank you for your consideration and please contact me at +1 (973)
455-4187 if I can provide any more details regarding the use,
promotion and availability of alternative low-GWP blowing agents
and other technologies.  



Sincerely,




Sanjeev Rastogi
Director, Structural Enclosures
Honeywell Performance Materials and Technologies