Ozone-Depleting Substances: New Regulations, New Challenges
by Ali Farnoud
Snap! This is likely what many thought when the U.S. Environmental Protection Agency's (EPA) updated Significant New Alternatives Policy (SNAP) program was promulgated. The original program was designed to reduce the usage of certain refrigerants with high ozone-depletion potential (ODP) to help repair the damaged ozone layer. Limiting production and using market forces to substantially reduce these refrigerants was part of the Montreal Protocol that was ratified as part of the U.S. Clean Air Act (CAA) as early as late 1990s.
The SNAP program proved to be an extremely effective yet costly policy. Many facilities across the country were forced to prepare a meticulous plan to replace the ozone-depleting substances (ODS) with substitutes. The massive effort to remove ODS and the additional requirements to standardize the leak repair and maintenance of the refrigerant equipment resulted in significant improvement of the ozone layer.
The recent update to the SNAP program, however, is different from the previous versions in that the driver behind the program is not protecting the stratospheric ozone, but curbing climate change. The Kigali Amendment, which was signed in October 2016, shifts the direction of the Montreal Protocol toward climate change. Similarly, the new SNAP program promulgated in Section 612 of the CAA, as well as the less costly yet impactful repair and maintenance programs in Section 608, both list President Obama's Climate Action Plan and not stratospheric ozone protection rules.
This issue of EM focuses on the SNAP program, recent changes, and its effects, with three full-length feature articles that follow.