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Comment 16 for California Cap-and-Trade Program (capandtrade10) - 15-2.

First NameLaurie & Allan
Last NameWilliams & Zabel
Email Addresswilliams.zabel@gmail.com
AffiliationVolunteers Citizens Climate Lobby
SubjectComment on Ozone Depleting Substances Protocol
Comment
AB 32 – Greenhouse Gas Offsets - Comment submitted September 27,
2011  
COMMENT ON OZONE DEPLETING SUBSTANCES OFFSET PROTOCOL 
AND AB 32 REGULATIONS – IMPLEMENTATION OF AB32

Comment by Laurie Williams & Allan Zabel on behalf of themselves as
private citizens, as residents of California and as volunteers,
writing on behalf of Citizens Climate Lobby, a non-profit
organization located in San Diego, California, asserting that
adoption of the proposed greenhouse gas offset program, regulations
and protocols is arbitrary and capricious and contrary to the
intent and requirements of AB 32, the California’s Global Warming
Solutions Act of 2006. 
Please incorporate by reference our August 2008, December 13, 2010,
July 27, 2011 and August 10th, 2011 comments.
This comment focuses on the proposed Ozone Depleting Substances
(“ODS”) Protocol and provides evidence that protocol does not meet
the AB 32 criteria for additionality:
1.	Evolving Technology and Public Demand for Environmentally
Responsible Practices: The protocol ignores the fact that new, more
efficient technologies have been developed and deployed to capture
and destroy ODS from refrigerators and their foam insulation. 
These technologies have become more cost-effective, and demand has
grown to avoid ODS releases to the atmosphere.  As a result, the
traditional approaches of draining ODS from refrigerator
compressors, storing non-economic captured ODS indefinitely, and
landfilling the ODS laden foam have gradually become more
unacceptable and non-competitive.  This evidence establishes that
the proposed business-as-usual baseline in the proposed ODS
protocol is inaccurate and the ODS protocol would provide offsets
for many non-additional projects that are already underway.  These
projects do not meet the AB 32 criteria for additionality (“in
addition to any greenhouse gas emission . . .  that otherwise would
occur,” see Section 38562(d)).   U.S. Department of Energy funding
and other programs have played a role, as has the development of
ODS capture and destruction technology in Europe.  As a result,
much of the ODS destruction that would receive offset credits under
the protocol would not be additional to what would have occurred in
the absence of the AB 32 program.  See Notes below: Note 1 - NY
Times Article Sept. 24, 2011; Note 10, GE Press Release Sept. 9,
2011.
2.	Evolving Regulatory Context & Perverse Incentives:  The protocol
ignores the fact that the regulatory context is evolving. 
California and several other states now prohibit dumping
refrigerators and freezers in landfills.
http://www.riversideca.gov/utilities/fridge-recycle.asp ;  
http://www.aham.org/industry/ht/a/GetDocumentAction/i/16317  (see
page 21 of 122).  Authorizing offsets would create a perverse
incentive to halt or slow this regulatory progress.  See also
comment from Michael Wara at Note 15.
3.	Existing Operations:  The protocol ignores the fact that a
growing number of states and other programs are successfully
funding and incentivizing capture and destruction of ODS from foam
and refrigerators, even though the California Offsets Protocols
have not been finalized, suggesting that there is the potential for
this activity to be profitable and publicly supported, even without
the added incentive of offset payments.  While, in some cases,
economic stimulus funding from the U.S. Department of Energy played
a role, it is clear that there are many incentives for such
programs to continue, including public demand for recycling as
shown in the statistics in GE’s press release and other references
below. (GE Press Release Note 10: “We have a viable business that
has the potential to grow well beyond the 12 states we now serve,”
said Jack Cameron, president and CEO of ARCA. “The AAP facility in
Philadelphia is a true investment in our environment, our economy
and our community.”  Note: this statement does not say that ARCA
can have a viable business only if the California ODS Offset
Protocol is approved.)     
Resources and References:
1.	 New York Times, Sept. 24, 2011, Robots Extract Coolant from Old
Refrigerators
http://www.nytimes.com/2011/09/25/business/energy-environment/recyclers-extract-coolant-from-old-refrigerators.html?ref=earth&gwh=89FC928A260B413BECD9EC7F45451FF1
      
Robots Extract Coolant From Old Refrigerators
RECYCLING refrigerators — especially those made more than 15 years
ago — is a tricky job. The coolant in old appliances (now banned
from newer versions) can cause serious trouble, warming the
atmosphere and depleting the ozone layer. 
Enlarge This Image
 
General Electric
The refrigerator's foam insulation is turned into pellets that can
be used as fuel or other products. 
Regulations forbid the release of liquid refrigerants during
disposal. But what if the refrigerant was not in the cooling
system, but stored up in the old foam used for insulation? The
insulation in older machines is full of a gassy refrigerant that
can waft away during dismantling and continue to diffuse later when
the foam is shredded and sitting in a landfill. 
Now a few American companies have embarked on voluntary recycling
programs that go beyond what many local governments do when a
resident leaves an old refrigerator on the curb for pickup. The
companies use ingenious robotic systems to squeeze out almost all
of the coolant in refrigerators — including the hard-to-reach
coolant in the foam — before they head for the landfill. 
Appliance Recycling Centers of America, a company based in
Minneapolis with a chain of recycling depots, recently unveiled a
40-foot-tall behemoth that dismantles refrigerators the
environmental way, extracting the coolant until only 0.2 percent is
left. 
The machine, installed in Philadelphia, has a panoply of shredders,
magnets, chutes and sluices worthy of a green Willy Wonka. Send a
refrigerator down the conveyor belt of this unit and it is
transformed into neat piles of plastic and metal that can be
recycled rather than buried in a landfill. The foam insulation is
turned into pellets that can be used as fuel or for other products.

About a third of the coolant is recovered from the compressor and
about 70 percent from the foam insulation, said Peter Hessler,
managing director of Untha Recycling Technology, a company in
Karlstadt, Germany, that created the new recycling system. 
The entire mechanical dismantling takes about a minute, said Jack
Cameron, chief executive of Appliance Recycling Centers of America
and of ApplianceSmart, a chain of appliance stores. The system
costs about $5.5 million and can tackle about 150,000 used
refrigerators a year, he said. 
The capital investment for the system was possible, Mr. Cameron
said, because the recycling company has a six-year contract with
General Electric. G.E. delivers new appliances and hauls the old
ones away in 12 Northeastern and mid-Atlantic states for Home
Depot. G.E. is supplying the recycler with all of those returns. 
Elaborate refrigerator recycling systems like Untha’s are rare in
the United States but not in Europe, which has strict controls
against the release of refrigerants. The dismantling of appliances
in the Untha system takes place in a vacuum so that the gases,
commonly known as freons, CFCs or chlorofluorocarbons, cannot
escape into the atmosphere. 
The system Untha installed in Philadelphia had to be scaled up for
American refrigerators. “The U.S. refrigerators are three times the
size of European ones,” Mr. Hessler said. 
First refrigerators go through two Dumpster-size shredders placed
end to end. The foam insulation is handled in a separate step. “We
crack the cell matrix of the foam by heating it up in a pelletizer”
and extracting the remaining coolants, he said. 
Another robotic system that captures refrigerants down to the last
few drops is at the Stow, Ohio, location of JACO Environmental.
Michael Dunham, director of energy and environmental programs, said
the system separates more than 95 percent of the materials used to
manufacture the old appliances and sends them to be made into other
products. The system, which is portable, was manufactured by SEG of
Mettlach, Germany. 
Many of these old refrigerators are still chugging along, Mr.
Dunham said. JACO picked up about 480,000 refrigerators for
recycling last year, with an average age of 21 years. “And the old
ones stored away in garages and basements aren’t getting any
younger,” he said. The company, which participates in a voluntary
program to bag and burn old insulating foam in refrigerators,
expects to receive a comparable volume of old refrigerators during
the next decade. 
In the future, financial incentives may encourage the capture and
destruction of refrigerants. To reduce greenhouse gas emissions,
California is completing a cap-and-trade regulation, set to start
in 2012, that includes credit for pre-1995 refrigerants said Bart
Croes, chief of the Research Division at the Air Resources Board,
which will oversee the program. 
“Companies can use credits from the proper destruction of
refrigerants to cover part of their annual emissions,” said Gary
Gero, president of Climate Action Reserve in Los Angeles, which
certifies projects that reduce greenhouse gas emissions and issues
offset credits. 
Mr. Gero said many companies had already bought carbon credits in
anticipation of the new regulation. 
Mr. Dunham of JACO says his company is already taking one of the
refrigerants it destroys, CFC 12, to the carbon offset market.
“People are buying the credits and banking them, hanging on to them
in hopes they will be more valuable when cap and trade comes into
effect,” he said. 
Many refrigerants that are now banned from production, but are
still legally captured and recycled, have about 700 to 10,000 times
the heat-trapping potential of carbon dioxide, Mr. Gero said. An
average old refrigerator has about half a pound of the now-banned
refrigerant in the cooling system and one pound in the foam, he
said. 
“So the refrigerator has an equivalent of approximately five tons
of carbon dioxide,” Mr. Gero said. “For comparison, that is like
driving over 10,000 miles in an average car.” 
“If you capture these gases and take them to a destruction
facility,” he said, “you’ve prevented a problem, and we give you
credit.” 
E-mail: novelties@nytimes.com 
2.	Southern California Edison, Safeguarding the Environment, One
appliance at a time.  ODS recovered from refrigerators are
reclaimed or destroyed.   The program calculates the benefit cost
ratio (without offset payments) is high. The main point is that
this program is performing the activity contemplated by the
protocol in advance of protocol approval.
http://www.epa.gov/ozone/partnerships/rad/downloads/RAD_SCE_Case_Study.pdf
 
Southern California Edison Safeguarding the Environment One
Appliance at a Time 
Energy conservation is becoming one of the nation’s top priorities,
as concerns over climate change, national security, and energy
costs have deepened. Recognizing this, the California Public
Utilities Commission (CPUC) is sponsoring programs funded with
ratepayer dollars to reduce statewide energy consumption. With
these funds, Southern California Edison (SCE) and other California
utilities are implementing appliance recycling programs (ARP),
designed to reduce energy consumption and benefit both consumers
and the utility company. Specifically, these programs encourage
retirement of inefficient appliances to reduce energy demand,
thereby eliminating the need for utilities to build new power
plants and, at the same time, lowering customers’ electricity
bills. 
Large appliance replacement and retirement programs – focused
primarily on refrigerators and freezers – are often targeted by
utilities and state agencies as one of the first elements of a
Demand Side Management (DSM) program since they are substantial
users of electricity. These appliances are bulky and have a long
shelf life, so they are often slow to replace. To decrease demand
on the energy grid and ensure responsible appliance disposal, SCE
provides customers with monetary incentives to pick-up and dispose
of their old working refrigerators and freezers using best
environmental practices. 
To gain recognition and track environmental benefits beyond energy
savings, SCE partners with the Environmental Protection Agency
(EPA) as part of the Responsible Appliance Disposal (RAD) program.
"SCE has enjoyed a strong relationship with EPA over the years, and
participation in RAD is a continuation of that," offered Tom
Schober, SCE ARP Program Manager. "The RAD Program provides us with
an opportunity to partner with the EPA in an effort we both believe
in." 
Description of SCE’s Appliance Recycling Program: Using Tactics of
Social Marketing and Education 
SCE, which serves a region with 13 million residents, started its
appliance disposal program in 1994, and has recycled more than
600,000 appliances to date. During PY 2006-2008, 245,000
refrigerators/ freezers and 12,000 air-conditioning (AC) units are
planned for removal. During this program year, the ARP is being
expanded to non-residential customers, including office complexes,
industrial customers, schools, etc. Collected appliances are being
processed by Appliance Recycling Centers of America, Inc. (ARCA)
and JACO Environmental, Inc. 
SCE’s ARP utilizes social marketing tools—such as financial
incentives, appliance pick up events, and educational
information—to change consumer behavior and encourage energy
conservation. "By reaching out to households throughout our service
area about the importance of energy conservation, the appliance
recycling program educates consumers and allows them to contribute
in a meaningful way," says Schober. 
SCE offers their customers free appliance pick-up and a $35
incentive for disposing of an old working refrigerator and $50 for
disposing of an old working freezer. The only requirement is that
collected refrigerators and freezers be in working condition and
that their size be between 10 and 27 cubic feet. 
SCE also leverages energy efficiency partnerships to increase
outreach and project penetration. Events such as "Refrigerator and
Freezer Pick-Up Day" are held in concert with other energy
efficiency programs. During these events, working refrigerators and
freezers in a particular geographic area are picked up on
Saturdays, which increases the convenience of pick-up for
customers. SCE works with retailers to provide consumers with POS
(Point of Sale) materials to inform them of events and provides
them with information on ARP. SCE has also partnered with property
management companies to encourage the replacement and proper
disposal of old appliances. 
In addition, SCE collects and recycles room AC units as part of
ARP. Specifically, SCE holds AC Turn In events to encourage
customers to retire their old room ACs. Customers bring their
working room AC units to the event and receive $25 credit for their
old units, as well as a $50 voucher towards the purchase of a new
ENERGY STAR® room AC unit—for a total incentive of $75 off the
purchase of a new ENERGY STAR® room AC unit. 
ARP marketing activities include bill inserts and messages, the SCE
website, special mailings, e-mail blasts and occasional radio
commercials. SCE has also targeted the environmental community and
has used recycling trucks as mobile billboards. "These marketing
techniques are not only effective in increasing program
participation and decreasing energy consumption," says Schober,
"but they also give SCE visibility, so that consumers can see our
commitment to the environment put to action."
Environmental Benefits of the Program
According to Schober, "SCE recognizes that ARP not only saves
energy but also helps protect the environment." EPA has recognized
SCE’s contribution to the environment by awarding ARP with the
Stratospheric Ozone Protection Award in 2004. 
Based on SCE’s own calculations, removing old appliances from the
electric grid during PY 2006-2008 will result in net annual energy
savings of nearly 180 million kWh (assumed to be realized each year
for 10 years), and coincident peak reductions of over 30,824 kW.
Such energy savings will lead to reduced emissions of greenhouse
gases (GHGs) and smog precursors emitted by power plants. Indeed,
removing 245,000 old refrigerators/freezers from the grid is
expected to result in the following lifetime emission reductions:
• NOX emissions: ~ 260,000 lbs 
• GHG emissions: ~ 985,000 MTCO2eq 
• PM10 emissions: ~ 127,000 lbs 
In addition to the above benefits, additional climate and ozone
benefits are realized through the proper disposal of refrigerated
appliances. Under SCE’s program, ozone-depleting refrigerants and
foam blowing agents—which are also potent greenhouse gases—are
recovered from appliances and reclaimed or destroyed. Raw material
components, including metal, glass, and plastic, are also recycled,
which reduces energy consumption associated with the production of
virgin materials. During PY 2006-2008, reclaiming the refrigerant,
reclaiming or incinerating the foam, and recycling the raw material
components of refrigerators/freezers is estimated to result in a
climate benefit of 1,015,000 MtCO
2eq, and an ozone benefit of 136 ODP-weighted tons. 
Program Effectiveness
SCE ranks "cost effective energy savings" as the most significant
benefit derived from its ARP. To ensure the program realizes these
energy savings, ARP conducts inspector "ride alongs," on-site
inspections of recycling facilities and customer surveys, which are
part of the program’s compliance and verification procedures. Using
random statistical sampling, SCE energy efficiency inspectors ride
with the contractor pick-up staff to ensure that units collected
meet the program requirements and that the units are handled
properly. In addition, on-site inspections of recycling facilities
are conducted to verify that proper procedures are being followed.
Finally, customer surveys are also conducted over the phone to
measure satisfaction levels and determine what impact the program
has on customer behavior (i.e., what the customer would have done
with the unit in the absence of such a program). 
The total program cost for PY 2006-2008 is approximately $39.9
million. SCE has valued the associated electric benefits at over
$93 million. Depending on the program cost measure used (i.e.,
whether rebate is included or not), the benefit-cost ratio ranges
from almost 7:1 to about 3:1; similarly, the levelized cost per kWh
saved is about $0.013 (i.e., it costs SCE about 1.3 cents to reduce
each kWh).
"For what it costs to implement and administer this program, we get
much more in return from the energy savings that are generated,"
says Schober. In fact, SCE has found ARP to be one of the most cost
effective energy savings programs that is offered through their
portfolio of energy efficiency programs. The additional
environmental benefit associated with the proper disposal of
ozone-depleting refrigerant and foam is the "cherry on top."
Additional Information 
For more information on SCE’s ARP program, visit www.sce.com or
contact Tom Schober at tom.schober@sce.com.
For more information about EPA’s RAD Program, visit
www.epa.gov/ozone/snap/emissions/radp.html or contact Evelyn Swain
at swain.evelyn@epa.gov or 202-343-9956. 
SCE and ARCA are awarded a 2004 Stratospheric Ozone Protection
Award for their leadership, dedication, and technical achievements
in protecting the ozone layer through appliance recycling. From
left to right: Bruce Wall (ARCA), Drusilla Hufford (EPA), Gene
Rodrigues (SCE), and Jack Cameron (ARCA).
These GHG emission savings are equivalent to not driving 
213,243 passenger cars for one year, or removing 126,467 households
from the electricity grid for one year 
Energy Impacts & Effectiveness at a Glance, PY 2006-08
A
AnnualAnnual Net Energy Savings 177,322,800 kWh
Average Energy Savings/ Unit/ Year 722 kWh
Coincident Peak Reduction 30,824 kW
Total Program Cost $39,893,411 
Rebate Cost $9,400,000
Average Program Cost Per Unit 
Including Rebate $155.23 
Not including Rebate $118.65
Electric Benefits $93,063,110
Benefit-Cost Ratio 
PAC
b 2.52 
TRC
c 6.07
Levelized Cost 
PAC
b $0.032 
TRC
c $0.013
Net-to-Gross Ratio 
Refrigerators 0.35 
Freezers 0.54 
AC Units 0.80
"For what it costs to implement and administer this program, we get
much more in return from the energy savings that are generated,"
says Schober. In fact, SCE has found ARP to be one of the most cost
effective energy savings programs that is offered through their
portfolio of energy efficiency programs. The additional
environmental benefit associated with the proper disposal of
ozone-depleting refrigerant and foam is the "cherry on top."
3.	City of Riverside Website on Refrigerator Recycling
http://www.riversideca.gov/utilities/fridge-recycle.asp (city of
riverside - California prohibits putting frig in landfill) 
Refrigerator Recycling is a public benefit service that offers
residential electric customers the opportunity to recycle older,
operating inefficient refrigerators and stand alone freezers free
of charge. These units are transported to a recycling facility for
dismantling and processing, making the program easy and convenient
for our customers. 
It is important to know that California law prohibits dumping your
refrigerator or freezer in landfills and that many disposal
companies charge a fee to pick up refrigerator or freezers for
recycling
What are the benefits of recycling my older units? 
By turning in your older inefficient operating refrigerator or
freezer, you can save on future electric costs. Old inefficient
refrigerators and freezers are typically high energy users. In
fact, older refrigerators can cost over $200 more yearly to operate
than a newer energy efficient refrigerator. 
A second refrigerator in the garage can be adding up to an
additional $100 or more a year to your electric costs. Another
reason to recycle is the environmental benefits. Because
refrigerators contain metals and refrigerants, they must be
dismantled and removed in an environmentally safe manner. 
What Do I Need to Do? 
Qualified customers can call 
(800) 685-2722 weekdays 8:00 a.m. - 5:00 p.m. 
to schedule an appointment for pick-up. Please have your electric
account number available when calling. Once the appointment has
been scheduled, a representative will come to your home to pick up
the appliance and deliver it to a recycling center. The recycling
center dismantles the appliance and disposes of the metal and
refrigerant according to Federal, State and local requirements.
If you have a non-working appliance,
please call the Appliance Recycling Center of America at 
(800) 654-2722 for recycling alternatives.

Refrigerator Recycling Program Guidelines
•	Customers must fulfill all program guidelines, program specific
and general RPU program guidelines, to be eligible for incentives.

•	Operating refrigerator or freezer must be 10 to 28 cubic feet in
size. 
•	Non-operational units do not qualify. 
•	A contractor retained by RPU must pick up the qualifying unit. 
•	Customers must schedule an appointment for the pick up of
qualified units through the Appliance Recycling Centers of America
Inc. at (800) 685-2722, Monday through Friday, 8 a.m. to 5 p.m. 
•	All General Program Guidelines apply. 

4.	Texas Encourages Refrigerator Recycling:  
Everyday hundreds of people are giving away refrigerators- Why-
nobody wants to haul it away- Refrigerator Roundup will pick it up
for Free-  Heres a great article from earth911.com on the Great
Texas Refrigerator Roundup Underway by Lori Brown
Have an old refrigerator or freezer lying around the house? Live in
Texas? If you answered “yes” to both  questions, you could have $50
headed your way. Oncor, in partnership with Appliance Recycling
Centers of America (ARCA), has begun the second annual “Great Texas
Refrigerator Roundup,” encouraging customers to get rid of
out-of-date and inefficient refrigerators and freezers.
 
http://www.p2sustainabilitylibrary.mil/p2_opportunity_handbook/7_I_A_6.html
Although appliances comprise only a small portion of the municipal
waste disposed in landfills, they do have a market value. According
to the Steel Recycling Institute (SRI), the steel that is used in
appliances consists of a minimum of 25 percent recycled steel, with
the internal steel parts containing anywhere between 25-100 percent
recycled steel. According to SRI, steel recycling saves on an
annual basis the equivalent energy that is required to power an
estimated 18 million households electrically. All appliances are
recyclable, including refrigerators, washers, dryers, air
conditioners, water heaters, and de-humidifiers. 
Appliance recyclers specialize in recovering all hazardous
materials and wastes prior to recycling the appliance as scrap
metal. For a small fee, appliance recyclers will pick up the
appliance, transport it to their recycling facility and conduct a
multi-stage recycling program to recover all hazardous materials
and wastes. The following table presents the typical hazardous
materials and wastes recovered from appliances and their ultimate
disposition.
Recovered Material/Waste	Type of Application	Ultimate Destination
of Recovered Material
CFC-11	Refrigerator Foam Insulation	Recycled for Reuse
CFC-12	Refrigerator Compressors	Recycled for Reuse
R22	Air Conditioner Compressor	Recycled for Reuse
500R500-502	Water Cooler Compressor	Recycled for Reuse
PCBs	Motor Capacitors	Hi-Temp Incineration
Mercury	Switches, Thermocouples	Recycled for Reuse
Oil	Refrigerator Compressors	Treatment to remove CFCs, Oil then
Recycled for Reuse
Oil	Washing Machine Motors	Recycled for Reuse
SO2	Refrigerators Compressors (pre-1960)	Disposed as Waste Gas
Appliance recycling should only be conducted by fully licensed
recyclers. As of 1997, 21 states had regulations restricting the
disposal of appliances in municipal landfills. California, New
Jersey, and Massachusetts have strict regulations regarding
appliance disposal. Check with your state representative to
determine the regulations in your area.

Compliance Benefit:	Appliance recycling will help facilities to
meet the requirements of Executive Order 13101, which call for
executive agencies (e.g., Department of Defense) to incorporate
waste prevention and recycling into their daily operations. 
The compliance benefits listed here are only meant to be used as
general guidelines and are not meant to be strictly interpreted.
Actual compliance benefits will vary depending on the factors
involved, e.g., the amount of workload involved.

Materials Compatibility:	N/A

Safety and Health:	Appliance recycling should only be conducted by
trained professionals in a licensed recycling facility. CFC
recovery must be conducted in facilities equipped for proper CFC
recovery and in accordance with Clean Air Act requirements. Gas
operated appliances should not be recycled due to potential
explosion hazards.

Consult your local industrial health specialist, your local health
and safety personnel, and the appropriate MSDS prior to
implementing this technology. 

Benefits:	•	Reduces the appliance-related waste disposed in
landfills by an average of 55.6% (U.S. EPA, 2000). 
•	Conserves natural resources needed to produce CFCs, mercury, oil,
and steel. 
•	Reduces landfill disposal fees. 
Disadvantages:	•	Currently not marketable in some regions. 
•	Scrap metal recyclers may refuse to accept metal from appliances
due to potential exposure to PCB and mercury components.
Contracting with trained licensed recycling contractors will
address this concern. 

Economic Analysis:	Appliance recycling should only be conducted by
trained licensed recycling contractors. Recycling costs vary and
are dependent upon the quantity of appliances recycled and the
region. Utility supported recycling programs are currently
conducted in California and New York. These programs are free and
in some cases include cash incentives. These programs typically
require that the recycled appliance is in good working order and is
currently serving as a second (spare) appliance in the household. 
Average recycling fees for a medium scale (50-100 units per year)
recycling program range from $0 to $25 per appliance.
Assumptions:
•	Medium scale appliance recycling program: 50 units per year. 
•	Recycling fees: None. 
•	Labor for removal/transport of appliance to recycling center or
landfill: 2 hrs/unit. 
•	Average appliance weight: 150 lbs. 
•	Landfill fee: $25/ton. 
•	Labor rate: $30/hr. 
•	Transportation cost to recycle center or landfill: $1,000/yr. 
Table 1. Annual Operating Cost Comparison for Diversion and
Disposal for Appliance Recycling
 	Diversion	Disposal
Operational Costs: 	 	 
Labor: 	$3,000	$3,000
Transportation: 	$1,000	$1,000
Recycling fees: 	$0	$0
Landfill fees: 	$0	$100
Total Operational Costs: 	$4,000	$4,100
Total Recovered Income: 	$0	$0
Net Annual Cost/Benefit: 	-$4,000	-$4,100
Economic Analysis Summary:
•	Annual Savings for Appliance Recycling: $100
•	Capital Cost for Diversion Equipment/Process: $0
•	Payback Period for Investment in Equipment/Process: Immediate
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5.	EPA Website on Safe Disposal of Refrigerated Household
Appliances:  Frequently Asked Questions
http://www.epa.gov/ozone/title6/608/disposal/household.html  
Safe Disposal of Refrigerated Household Appliances: Frequently
Asked Questions (FAQ) 
Appliance owners play a critical role in helping to protect against
environmental hazards associated with appliance disposal. The
sections below provide consumers with information on:
I.	Environmental Concerns 
II.	Energy Consumption of Refrigerators/Freezers 
III.	How to Dispose of an Appliance 
IV.	What Happens to Disposed Appliances 
V.	Additional Regulatory Information 
I. Environmental Concerns
What are the environmental concerns associated with the disposal of
refrigerated household appliances?
Refrigerant: Household refrigerators and freezers manufactured
before 1995 typically contain chlorofluorocarbon (CFC) refrigerant.
Most window air-conditioning units and dehumidifiers contain
hydrochlorofluorocarbon (HCFC) refrigerant. CFCs and HCFCs are
ozone-depleting substances (ODS) that, if released to the
environment, destroy the protective ozone layer above the earth.
Moreover, CFC and HCFC refrigerants are also potent greenhouse
gases, meaning that their release contributes to global climate
change. Refrigerators and freezers manufactured since 1995 contain
ozone-friendly hydrofluorocarbon (HFC) refrigerants; however, these
refrigerants still need to be carefully handled since they are
greenhouse gases.
Foam: Refrigerators and freezers manufactured before 2005 are
insulated with foam that contains ODS—either CFCs or HCFCs. If
emitted, CFCs and HCFCs contribute to both ozone depletion and
climate change. Only units manufactured since 2005 contain foam
blowing agents that are ozone and climate friendly.
Air-conditioners and dehumidifiers do not contain foam. 
What are the Dangers of Used Oil, Mercury, and PCBs?
•	If improperly disposed, used oil from refrigerated appliances can
result in the release of dissolved ODS refrigerant and groundwater
contamination. In addition, short-term exposure to used oil can
cause skin, eye, and respiratory irritation; in the long-term, it
can cause cancer and damage to the liver, brain, immune system, and
reproductive system.
•	When released to the environment, mercury accumulates in the
tissues of plants and animals and, when consumed by humans, impairs
neurological development and causes other problems associated with
the nervous system.
•	PCBs are toxic substances with carcinogenic and non-cancerous
effects on humans, including effects on the immune system,
reproductive system, nervous system, and endocrine system.
Hazardous Components: Household appliances may also contain
hazardous components, including used oil, polychlorinated biphenyls
(PCBs), and mercury. For example, the cooling circuit contains oil
that can be contaminated with ODS refrigerant. Some refrigerators
and chest freezers manufactured prior to 2000 have
mercury-containing components (i.e., switches and relays).
Appliances manufactured prior to 1979 may contain PCB capacitors.
For this reason, appliances should be recycled by facilities that
safely remove these components prior to shredding and recycling.
The Association of Home Appliance Manufacturers (AHAM) has more
information on mercury and PCBs  contained in home appliances. 
The diagram below provides approximate quantities and locations of
substances contained in refrigerators manufactured prior to 1995.
Components of a Refrigerator Manufactured Prior to 1995 
 
II. Energy Consumption of Refrigerated Appliances
Would I save money by replacing my old refrigerator with a more
energy efficient unit instead of waiting until the old unit fails?
What is a Bounty Program?
 A bounty program is an appliance turn-in program – typically
sponsored by a local or regional utility. Through the program, an
appliance owner is paid a "bounty" to allow the recycler to collect
and recycle their old, inefficient appliance. Some programs also
offer rebates and discounts towards the purchase of new ENERGY
STAR® qualified models. Most bounty programs have specifications
for the appliances they can accept. To find out if bounty programs
are offered in your area, try contacting your electricity
provider.
A 20-year old refrigerator or freezer can consume two to four times
more energy annually than a new model, and, as a result, can
significantly increase your electric bill. Older refrigerators or
freezers put a great strain on local power grids, especially during
peak hours. By replacing your old refrigerator or freezer with a
newer model, particularly one that has earned the government's
ENERGY STAR® label, you can conserve energy and save upwards of
$70/year! If your old refrigerator is a secondary unit located in a
basement or garage, you can save approximately $120/year on
electricity charges by removing it and not replacing it.
Getting rid of old refrigerators or freezers may be even more
financially attractive if your local utility provider operates an
appliance disposal program. Some utilities will actually pay you to
get rid of your old refrigerator or freezer through bounty programs
or rebate programs.
How do I know how much energy my refrigerator, freezer, or window
air-conditioner uses?
Consult the energy guide in your owner's manual or visit HomeEnergy
online and enter the required information. The Department of Energy
also provides a formula for calculating energy usage for various
appliances. Energy consumption is rated in kilowatt hours/year
(kWh/y). Modern refrigerators consume an average of about 500
kWh/year, while a unit manufactured 20 years ago consumes an
average of approximately 1,200 kWh/year.
When buying a new appliance, how do I know which are most energy
efficient?
 ENERGY STAR® is the government-backed symbol for energy
efficiency. Products that have earned the government’s ENERGY STAR®
label (such as refrigerators, freezers, and other appliances) lower
greenhouse gas emissions by meeting strict energy efficiency
guidelines established by U.S. Environmental Protection Agency and
the U.S. Department of Energy.
III. How to Dispose of an Appliance
How can I dispose of my refrigerated appliance in an
environmentally responsible way?
First, you should check with your electric utility to see if a
bounty program is offered in your area. Since some bounty programs
have required specifications for appliances (e.g., must be in
working condition, of a minimum vintage and/or dimension), you may
also need to confirm that your appliance is acceptable. 

If a bounty program is not available, you can contact your
municipal department of public works to inquire about the
procedures for collecting and disposing of refrigerated appliances
in your neighborhood. Typically, for refrigerators/freezers,
municipalities require you to make an appointment for bulky item
collection, which may be provided at no additional cost. Some
municipalities charge a fee for refrigerated appliance collection
or require you to haul items to a transfer station or dump. (Your
municipality can direct you to a solid waste contractor for more
information.) Other municipalities may require the refrigerant to
be recovered from appliances before they will accept it for
pick-up. In such cases owners would need to hire a technician with
certified recovery equipment to remove the refrigerant prior to
disposal.
! 	NOTE: Do not attempt to remove refrigerant or compressors
yourself. Improperly handled refrigerant may result in physical
harm. Only properly trained individuals using EPA-approved
refrigerant recovery equipment should attempt to remove refrigerant
from appliances. 
Additional information on recycling and proper household hazardous
waste disposal in your community may also be available at
www.earth911.org . 
When disposing of a refrigerated appliance, try to inquire about
the disposal practices of the entity removing your unit to ensure
that it will be disposed of responsibly. If you learn about illegal
or suspect activities (e.g., refrigerant venting), you can file a
report easily and anonymously by visiting EPA's Office of
Enforcement and Compliance Assurance website.
! 	See Section IV, “What Happens to Disposed Appliances” to help
ensure that your appliance is responsibly disposed.
How much does it cost to dispose of my old appliance?
The cost of appliance pick-up and/or disposal varies. For example,
your municipal public works department may provide free collection
of refrigerant-containing appliances or there may be a fee for this
service, which may vary by appliance type. 

Some retailers offer appliance pick-up and disposal services with
the purchase and delivery of a new model. Depending on the
retailer, a fee of $10 to $50 may be charged for this service. 
Enterprises such as utilities that operate a bounty program may
also provide free pick-up/disposal services for old
refrigerators/freezers or even pay you to pick up your unit.
IV. What Happens to Disposed Appliances
What typically happens to my old refrigerator or freezer once I get
rid of it?
 Almost all of the materials in your refrigerator or freezer can be
recycled. This includes the metal cabinet, plastic liner, glass
shelves, the refrigerant and oil in the compressor, and the blowing
agent contained in polyurethane foam insulation.
After appliances are collected they can be resold, recycled, or
landfilled.
Resale: Sometimes appliances that are in working condition are
refurbished and resold domestically or abroad to developing
countries. Because these appliances consume large amounts of
electricity and are less efficient toward the end-of-life,
appliance re-sale should be avoided to save energy. Moreover, for
those units sold in developing countries, their ultimate disposal
is less likely to be carried out responsibly.
Recycling: Appliance recycling typically entails recovery of
refrigerant and removal of hazardous components followed by
shredding of evacuated appliances. Metal components are typically
separated and recycled, while glass, plastics and polyurethane
foam, are typically sent to a landfill. Because there are no legal
requirements for foam recovery, the blowing agent contained in the
foam insulation is emitted during shredding and landfilling—thus
contributing to ozone depletion and to global climate change.
 Landfilling: Typically, when a waste hauler brings appliances to a
landfill, refrigerated appliances are separated until a technician
recovers refrigerant and other hazardous components, after which,
the appliances are landfilled. Sometimes disposed appliances are
reportedly landfilled whole, without shredding or removal of
durable components.
! 	When disposing of a refrigerated appliance, you should inquire
about the disposal practices of the entity removing your unit to
ensure that it will be disposed of responsibly. If you learn about
illegal or suspect activities (e.g., refrigerant venting), you can
file a report easily and anonymously by visiting EPA's Office of
Enforcement and Compliance Assurance website.

What is being done to encourage more responsible appliance
recycling/disposal?
To encourage appliance recycling and proper disposal of hazardous
components, EPA has launched the Responsible Appliance Disposal
(RAD) Program. RAD Partners ensure the proper handling not only of
refrigerant and other hazardous components regulated by federal
laws, but also foam blowing agent.
V. Additional Regulatory Information
Do technicians recovering refrigerant from disposed appliances need
to be certified?
Currently, technicians removing refrigerant from small appliances
in the waste stream are not required to be certified.
Do establishments that recover refrigerant from disposed appliances
need to be certified with EPA?
EPA requires establishments that dispose of small appliances to
certify to the appropriate EPA Regional Office that they have
recovery or recycling equipment that meet EPA standards for such
devices (i.e.,equipment must achieve 90% recovery efficiency when
the appliance compressor is operational, or 80% recovery efficiency
when the appliance compressor is not operational). This
certification form (140K, 4 pp, About PDF) must be signed by the
owner of the equipment or another responsible officer and sent to
the appropriate EPA Regional Office. Owners do not have tosubmit a
new form each time they add recycling or recovery equipment to
their inventory.
Are the hazardous components or insulating foam contained in
appliances regulated?
Hazardous components, including PCBs and mercury, and compressor
oil, must be removed from appliances before disposal in accordance
with 40 CFR Parts 273, 279, 761. However, the treatment of
ODS-containing foam is not regulated.
 How does EPA ensure that refrigerant is recovered from appliances
in compliance with all regulations?
The final disposer of appliances is responsible for recovering any
refrigerant contained in appliances. If the enterprise that
recovers the refrigerant is not also the final disposer of the
appliance, EPA requires (40 CFR 82.156(f)(2)) a signed statement
containing the name and address of the person who recovered the
refrigerant, and the date that the refrigerant was recovered.
Please note that no sticker is required for disposal.
! 	Nevertheless, illegal activities, including appliance dumping,
venting of refrigerant, and release of hazardous components to the
environment, still occur. Appliance owners should avoid illegal
dumping and should dispose of appliances responsibly. To the extent
possible, make sure to schedule the collection of your appliance
with your Department of Public Works, a retailer, bounty program,
or other recycler; appliances simply left on the curb without a
scheduled pick-up date are likely to be picked up by peddlers who
may improperly vent refrigerant or otherwise dispose of the
appliance in an unsound manner.

6.	EPA Website:  Appliance Disposal Practices in the United States
http://www.epa.gov/ozone/partnerships/rad/raddisposal_factsheet.html

Appliance Disposal Practices in the United States
•	Replacing an inefficient, 20–year old refrigerator with one that
has earned the government’s ENERGY STAR® label will save a
household roughly 700 kWh/year or more—or upwards of $70/year.
•	If a secondary refrigerator (e.g., in a basement or garage) is
removed and not replaced, households can save about 1,200 kWh/year,
or roughly $120/year.
•	Reducing energy demand results in reduced emissions of greenhouse
gases and certain criteria air pollutants.
•	Additional energy savings can be achieved if the components of
disposed units are recycled instead of landfilled by eliminating
the need to produce virgin materials.
Refrigerated Applications 
•	Replacing an inefficient, 20–year old refrigerator with one that
has earned the government's ENERGY STAR® label will save a
household roughly 700 kWh/year or more—or upwards of $70/year.
•	If a secondary refrigerator (e.g., in a basement or garage) is
removed and not replaced, households can save about 1,200 kWh/year,
or roughly $120/year.
•	Reducing energy demand results in reduced emissions of greenhouse
gases and certain criteria air pollutants.
•	Additional energy savings can be achieved if the components of
disposed units are recycled instead of landfilled by eliminating
the need to produce virgin materials.
Older refrigerators/freezers contain ozone-depleting refrigerants
and/or foam blowing agents, depending on the year they were
manufactured. In addition to depleting the ozone layer, these
substances are also potent greenhouse gases (GHGs) that contribute
to climate change when emitted to the atmosphere. While the
refrigerants used in newly manufactured units are still potent
GHGs, these appliances do not contain ozone depleting substances
(ODS) and are significantly more energy efficient than older
models.
Similarly, window air conditioners and dehumidifiers contain
environmentally-harmful refrigerants, and the older units consume
significantly more energy than the newer ones.
To reduce energy demand, ozone depletion, and global climate
impacts, it is critical that older units be permanently removed
from the energy grid and properly disposed of so that
environmentally-harmful refrigerants and foam blowing agents are
captured and recycled or destroyed.
To learn more about the environmental impacts of refrigerated
household appliances click here.
Top of page
Why is Removal and Proper Disposal of Appliances Important?
In the United States alone, it is estimated that there are
approximately 200 million household refrigerators/freezers, 40
million window air conditioning units, and 15 million dehumidifiers
(AHAM 2001, EIA 2001). Of the refrigerators and freezers, over 20
million are secondary units located in people’s basements or
garages (AHAM 2001, EIA 2001). Often, these secondary units are
older, less efficient models that are underutilized, but kept for
convenience.
Roughly 9 million refrigerators/freezers, 4.5 million window air
conditioning units, and nearly 1 million dehumidifiers are disposed
of each year. The proper removal and disposal of these appliances
would:
•	Prevent emissions of ODS and GHGs by not allowing their release
from refrigerants and insulating foams;
•	Prevent the release of PCBs, mercury, and used oil;
•	Save landfill space and energy by recycling rather than
landfilling durable materials (i.e., metals, plastics, and glass);
and
•	Reduce energy consumption.
Given the large number of refrigerated appliances that are taken
out of service each year, the environmental impacts of removing and
properly disposing of old appliances can be significant. The figure
below illustrates the climate benefits of removing old units from
the power grid and disposing of them properly.
 
Top of page
What is Required by Law?
When household appliances are taken out of service, Federal law
requires that: (1) all refrigerant be recovered prior to
dismantling or disposal (40 CFR Part 82 Subpart F  ); and (2)
universal waste (e.g., mercury), used oil, and PCBs be properly
managed and stored (40 CFR Parts 273  , 279  , 761  ).
State laws may have additional requirements. For example, in 2006,
California introduced a law requiring entities that remove
materials such as mercury, used oils, PCBs, and refrigerants from
appliances be certified by the State (AB 2277  ). Similarly, some
States require that certain durable appliance materials be
recycled. At this time, no Federal or State laws require that
appliance foam be recovered; however, the common practice of
shredding and/or landfilling of foam represents a significant
source of ODS and GHG emissions which could be avoided through foam
recovery.
For more information on disposal requirements for appliance
recyclers please see this document (PDF) (4 pp, 384K, About PDF).
Top of page
What Typically Happens to Disposed Appliances?
Many old refrigerated appliances are disposed through curbside
pick-up programs offered by municipalities or through appliance
pick-up services offered by retailers when a new unit is purchased
and delivered. Typically, municipalities and retailers subcontract
the disposal of old appliances to third parties, who may re-sell
some of the units domestically or abroad. For example, an estimated
40% of used appliances collected by retailers are placed on the
secondary market each year—meaning that they may be put back on the
domestic electricity grid, where they continue to operate
inefficiently, consuming excessive amounts of electricity.
Alternately, some of the operational units are exported to
developing countries, where they are less likely to be handled
responsibly at end-of-life.
Units that are not fit for resale are typically sent to appliance
recyclers, scrap metal companies, or other third parties, where
valuable metals are generally salvaged for recycling, and foams,
plastics, and glass are typically shredded and landfilled. While
Federal regulations govern the treatment of refrigerant, mercury
and PCBs, the ultimate fate of these components is often unknown;
there have been reports of appliance dumping, venting of
refrigerant, and release of hazardous components to the
environment.
Top of page
What Can Be Done to Help?
Municipalities and retailers can have a positive impact on
appliance recycling by ensuring that all old units collected are
permanently removed from the electricity grid (i.e., not re-sold)
and are responsibly disposed. Utilities, many of which have a
mandate to reduce energy demand, can also play a role in
facilitating responsible appliance disposal by promoting the
permanent removal of old, energy inefficient appliances from the
grid. Similarly, manufacturers can facilitate the appliance
recycling process in the name of product stewardship by promoting
and supporting the responsible disposal of old appliances produced
under their brand name.
To date, dozens of utilities have implemented appliance disposal
programs across the country—many of which are ongoing. These
programs promote the removal and safe disposal of old, inefficient
refrigerators and freezers, typically through advertisements and by
offering appliance owners a financial incentive (e.g., $35) for the
collection of their old units. In some cases, rebates toward the
purchase of a new refrigerator/freezer or window air conditioning
unit that has earned the government’s ENERGY STAR® label are
provided when old units are turned in. To collect and process the
old appliances and administer and/or market the program, utilities
typically hire a third-party contractor. Because of reduced energy
demand, these appliance disposal programs are considered to be
highly cost-effective. On average, these programs cost $0.04 to
reduce each kWh of demand, and can lead to benefit-cost ratios of
more than 3 to 1 (for refrigerators) (Kolwey 2006).
Universities and other large organizations can also reduce
emissions of ODS and GHGs through the collection and proper
disposal of refrigerated appliances in their facilities and/or
surrounding communities.
Entities that have a responsible appliance disposal program in
place, or would like to implement one, should consider joining
EPA’s voluntary Responsible Appliance Disposal (RAD) Program!
Top of page
References:
Association of Home Appliance Manufacturers (AHAM). 2001.
INFOBulletin #7: Mahor Home Appliance Saturation and Length of
First Ownership Association of Home Appliance Manufacturers
Research Study, 2001. Available at:
http://www.aham.org/industry/ht/a/GetDocumentAction/id/5369.  
Energy Information Association (EIA). 2001. Appliance Reports: US
Data Table 2001. Available at:
http://www.eia.doe.gov/emeu/reps/appli/us_table.html
Kolwey, Neil. 2006. “Refrigerator Recycling Programs: Rounding Up
the Old Dogs for Easy Energy Savings.” E-Source. April.

7.	http://www.usatoday.com/money/industries/environment/2009-08-25-appliances-cash-...
Appliances get their own recycled clunkers programs 
Updated 8/27/2009 12:15 PM | Comments 384  | Recommend 63 
E-mail | Print | Reprints & Permissions |  


 
 

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By Patricia Beck, Detroit Free Press	
 

Vincent Dallas hauls a refrigerator for recycling o Jaco
Environmental in Livonia, Mich.	


•	
By Kathleen Gray, USA TODAY
Cash for clunkers ended this week — for cars. 
But old energy-hogging refrigerators and freezers qualify for
recycling and cash from more than 60 utilities across the nation.
And the federal government is making money available to states so
consumers could get rebates of $50 to $200 for new, more
energy-efficient appliances later this year in a so-called "cash
for appliances" program.
Combined, the appliance initiatives have a goal similar to the
cash-for-clunker program for autos: They get less-efficient
appliances off the nation's energy grid in favor of newer efficient
ones.
FINAL CLUNKER TALLY: More than 690,000 new cars sold
The government's rebate program, in which the Department of Energy
is providing states with $300 million approved earlier this year as
part of President Obama's $787 billion stimulus plan, serves
another goal similar to the cash-for-clunker program: It's designed
to boost the economy.
"These rebates will help families make the transition to more
efficient appliances, making purchases that will directly stimulate
the economy and create jobs," Energy Secretary Steven Chu said in
announcing the rebate program earlier this summer.
Unlike cash for clunkers, consumers taking advantage of the rebate
program wouldn't need to trade in their old refrigerators to get
the benefit of buying a new one with an energy-star seal
designating it as efficient.
A 'win-win situation' 
Meanwhile, utilities in many states offer to pick up and recycle
old refrigerators and freezers and give the customer a rebate
ranging from $25 to $50. Such programs began on the West Coast in
the last decade but more recently have been moving east. 
"It's an excellent win-win-win situation," says John Hargrove of NV
Energy in Nevada, which has had a refrigerator recycling program
for five years. "There are environmental benefits,
energy-efficiency benefits and benefits for customers who have a
hard time dealing with that old refrigerator holding a six pack of
water in the garage."
Old refrigerators and freezers are some of the biggest energy users
in homes, and getting old ones out for energy-efficient models will
save customers anywhere from $50 to $150 a year on electricity
bills, says Steven Rosenstock, manager for energy solutions at the
Edison Electric Institute, which represents 70% of the
investor-owned utilities in the United States.
In five years, NV Energy in Nevada has picked up 50,000
refrigerators, giving $30 to customers in Nevada and California who
have turned in their working, but old appliances. The company hopes
to boost the program to 20,000 appliances a year and help the
utility reach its goal of producing a state-ordered 25% of its
electricity through renewable or energy-efficiency sources by 2025,
Hargrove says.
In Michigan, where 2008 energy legislation required utilities to
cut electricity production by 5% a year, the program is exceeding
expectations.
DTE Energy, parent company of Detroit Edison which serves 2.2
million electric customers in Detroit and its suburbs, collected
more than 3,300 appliances since starting the recycling program at
the end of June. It offers $50 per refrigerator or freezer and $20
for old window air-conditioner units.
"Today's appliances consume three times less than old appliances,"
says Steven Kurmas, president of Detroit Edison. "We're hoping to
get rid of 30,000 by 2011."
New Jersey's Clean Energy program, which includes energy-efficiency
programs for eight utilities in the state, started its program at
the end of July and has picked up 815 appliances with another 754
scheduled to be picked up. It hopes to recycle 20,000 refrigerators
and freezers in its first year.
"By providing an incentive of $30 and removing (the appliance), we
figured we could take a lot of demand out of the system," says Tim
O'Donovan with the New Jersey Board of Public Utilities.
'Environmental time bombs' 
At Nebraska Public Power District, Ken Curry says the utility hopes
to defer construction of new power plants with programs such as
refrigerator recycling, which already has picked up 1,400
appliances since starting this spring.
"We're estimating that the refrigerators we're picking up have
eight years remaining life, and by getting them off the grid, we're
saving 19 million kilowatt hours over the life of those units," he
says. "And if our customers are saving money on their electric
bills … they can upgrade to a better brand. A lot of our customers
can relate to that."
Jaco Environmental is a Seattle-based company that has been picking
up and recycling refrigerators for 20 years, first for retailers
and now for utilities. It runs recycling programs for 61 utilities
in 26 states. 
Money from the stimulus bill is a boon for business, says Michael
Dunham, director of energy and environmental programs for Jaco. 
Jaco recycles 95% of the refrigerator, including
chlorofluorocarbons, which are destroyed at a waste-to-energy
incinerator. The steel is used in rebar to reinforce roadways, and
the plastic goes into everything from laptop computers and
cellphones.
"These refrigerators are environmental time bombs," Dunham says.
"But this is all recycled and made into new products."
Gray writes for the Detroit Free Press 

8.	http://www.energysavers.gov/financial/70022.html  - Information
on the U.S. Department of Energy Rebate Program to encourage
recycling of refrigerators and freezers.

9.	http://www.greenecoservices.com/recycle-make-money-refrigerators/
Refrigerators and freezers contribute to hazardous waste if
landfilled improperly. Photo: Oncor.com.
The Great Texas Refrigerator Roundup is part of Oncor’s “Take A
Load Off, Texas” tour, an educational campaign designed to speak to
consumers about the importance of energy efficiency. The program
has reached more than 2.8 million consumers throughout the state.
According to the U.S. EPA, older refrigerators and freezers can put
a great strain on local power grids, often using more than twice
the energy of a new ENERGY STAR qualified model. By upgrading to an
energy efficient model, consumers can save between $50-100 in
energy costs annually.
ENERGY STAR estimates there are over 47 million refrigerators over
ten years old in the U.S. If every American home replaced its
pre-1993 refrigerator with an ENERGY STAR model, enough energy
would be saved to light more than 8.1 million homes for an entire
year.
If you’re looking to recycle a refrigerator or freezer outside of
Texas, check out the Recycle My Old Fridge Campaign.
10.	GE Press release at
http://www.marketwatch.com/story/ge-expands-appliance-recycling-for-consumers-and-retailers-how-rad-2011-09-09
Sept. 9, 2011, 10:45 a.m. EDT 
GE Expands Appliance Recycling for Consumers and Retailers -- How
RAD.
70 percent of consumers want all or part of their appliance
recycled.   
PHILADELPHIA, Sep 09, 2011 (BUSINESS WIRE) -- --GE and Appliance
Recycling Centers of America (ARCA) now provide appliance recycling
services to 12 Northeastern and Mid-Atlantic states. 
New technology system reduces landfill waste of refrigerators by 85
percent by weight.   GE Appliances launches initiative to
facilitate retailer participation in appliance recycling efforts. 
/quotes/zigman/227468/quotes/nls/ge GE -0.13% -- GE is expanding
appliance recycling options for consumers and retailers through its
relationship with Appliance Recycling Centers of America, Inc.
/quotes/zigman/62484/quotes/nls/arci ARCI +4.93% , which has
doubled its service offerings to 12 states in the Northeastern and
Mid-Atlantic regions of the U.S. 
It's What Consumers Want: Today, 70 percent of consumers want all
or part of their appliances recycled, and 82 percent will go out of
their way to purchase from a manufacturer that recycles.
Sixty-seven percent are even willing to pay more if a retailer
offers recycling programs -- making an Environmental Protection
Agency (EPA) Responsible Appliance Disposal (RAD) Program
partnership a desirable goal for appliance retailers.(1) 
As the first and only major appliance manufacturer to partner with
the EPA RAD Program, GE is helping retailers become partners of the
program as well -- helping differentiate them among consumers in
this tough economy. 
"We envision a day when consumers walk into a retail store and are
presented with a myriad of new appliance options -- including
appliances that are clearly marked with information about the
manufacturer's and retailer's recycling practices and participation
with the EPA RAD Program," said Mark Shirkness, general manager,
distribution services, GE Appliances & Lighting. "The RAD Program
is the industry's marquee recycling initiative. Similar to ENERGY
STAR(R), it's designed to create consumer awareness." 
GE's Initiative to Engage RAD Retail Partners: Currently, about 40
percent of appliances collected by retailers are resold -- putting
inefficient, used models back on the grid.(2) In a new initiative
to engage appliance retailers in the RAD Program, GE will help
ensure a steady stream of appliances to the ARCA Advanced
Processing (AAP) regional recycling facility in Philadelphia, Pa. 
To encourage retailers in the Northeast and Mid-Atlantic regions of
the U.S. to participate in the RAD Program, GE will help facilitate
the retailer's relationship with AAP, ARCA and the EPA; GE will
provide RAD Program retail partners with marketing assistance to
promote their program participation to consumers; and ARCA will
haul away the retailer's used appliance volume for delivery to
AAP(3) and support the retailer in reporting environmental metrics
annually to the EPA. 
More States Serving More Consumers: Since February, GE and ARCA
have doubled the number of states where recycling services are
offered, providing 100,000 additional appliance units to AAP
annually. AAP now receives used appliances from Massachusetts,
Connecticut, Pennsylvania, Maryland, Virginia, West Virginia, New
Jersey, New York, North Carolina, Delaware, Rhode Island and
Vermont. 
"EPA applauds GE and ARCA's commitment to expanding recycling
options for consumer appliances," said Gina McCarthy, assistant
administrator for EPA's Office of Air and Radiation. "Their
innovative partnership helps to reduce pollution, eliminate waste
and protect the Earth's ozone layer. EPA encourages other
manufacturers to follow their example." 
New Recycling System Reduces Waste and Emissions: Now operational,
AAP's advanced refrigerator recycling technology, the UNTHA
Recycling Technology (URT) system: 
-- Recovers approximately 95 percent of the insulating foam in
refrigerators.(4) 
-- Reduces typical landfill waste of the refrigerator by 85 percent
by weight.(5) 
-- Lowers greenhouse gas (GHG) and ozone depleting substance (ODS)
emissions recovered from insulating foam compared to what typically
happens in the industry today. 
-- Recovers high-quality plastics, aluminum, copper, steel, and
even pelletized foam from refrigerators that can be used to make
new products, such as GE locomotives. 
A 40-foot tall engineering marvel, the URT system -- which is the
only URT system in North America and the only refrigerator
recycling system of this scale in the U.S. -- is capable of
recycling 150,000 refrigerator units per year. 
Good for the Environment, Good for the Economy: "At AAP, we've
created a sustainable business model that's good for both the
environment and the economy," said Jack Cameron, president and CEO,
ARCA. "We have a viable business that has the potential to grow
well beyond the 12 states we now serve. The AAP facility in
Philadelphia is a true investment in our environment, our economy
and our community. ARCA's goal is to ensure the success of this
program so it can be replicated throughout the country." 
The installation of the URT System and other capital equipment
represents an approximate $10 million AAP investment that has
created over 50 additional green jobs in the Philadelphia facility.

GE Appliances & Lighting takes a cradle-to-cradle approach to
managing the life cycle of an appliance, from the manufacturing of
refrigerators with more environmentally sustainable insulating
material, to more responsible end-of-life disposal. GE also offers
hundreds of ENERGY STAR(R)-qualified models to ensure appliances
deliver efficiency and cost savings to customers during product
life. 
See February announcement that GE was the first and only major
appliance manufacturer to partner with the EPA on its RAD Program
focused on responsible refrigeration recycling, which is consistent
with GE's ecomagination(SM) initiative to deploy solutions for
today's energy and environmental challenges. 
For high-resolution photography, broadcast quality footage
(b-roll), fact sheets, videos and animations describing this
cutting-edge process, visit:
http://pressroom.geconsumerproducts.com/pr/ge/ge-expands-appliance-recycling-214918.aspx
. 
About GE Appliances & Lighting 
GE Appliances & Lighting spans the globe as an industry leader in
major appliances, lighting, systems and services for commercial,
industrial and residential use. Technology innovation and the
company's ecomaginationa" initiative enable GE Appliances &
Lighting to aggressively bring to market products and solutions
that help customers meet pressing environmental challenges. General
Electric /quotes/zigman/227468/quotes/nls/ge GE -0.13% ,
imagination at work, sells products under the Monogram(R),
Profile(TM), Cafe(TM), GE(R), Hotpoint(R), Reveal(R) and Energy
Smart(R) consumer brands, and Tetra(R), Vio(TM) and Immersion(R)
commercial brands. For more information, consumers may visit
www.ge.com . 
About Appliance Recycling Centers of America 
ARCA ( www.ARCAInc.com http://www.arcainc.com ), one of the
nation's largest recyclers of major household appliances for the
energy conservation programs of electric utilities, currently
provides services for more than 175 utility programs in the U.S.
and Canada. Toxic chemicals and environmentally harmful materials
such as ozone-depleting refrigerants, PCBs, mercury and oil are
carefully recovered in the decommissioning process for destruction
or disposal, preventing them from contaminating soil, air and water
resources. The company is also the exclusive North American
distributor for UNTHA Recycling Technology (URT), a materials
recovery system for household refrigeration appliances. (Emphasis
added.)
About EPA RAD Program 
EPA's Responsible Appliance Disposal (RAD) Program is a voluntary
partnership program that began in October 2006 to help protect the
ozone layer and reduce emissions of greenhouse gases. As part of
the RAD program, partners recover ozone-depleting chemicals from
old refrigerators, freezers, window air conditioners, and
dehumidifiers. For more information, please visit
www.epa.gov/ozone/partnerships/rad/index.html 
(1) Based on results from a 2010 survey conducted by the Stevenson
Company on behalf of GE Appliances & Lighting. (2) U.S
Environmental Protection Agency. "Appliance Disposal Practices in
the United States."
http://www.epa.gov/ozone/partnerships/rad/raddisposal_factsheet.html
. (3) Retailer must be within AAP's service territory. (4) Based on
ARCA Advanced Processing letter dated December 2010 re: PUR
recovery rates. (5) ARCA Advanced Processing 2010 Landfill Data,
based on the component listing found in the American Plastics
Council 1994 Composition, Properties and Economic Study of Recycled
Refrigerators Report. 
Photos/Multimedia Gallery Available:
http://www.businesswire.com/cgi-bin/mmg.cgi?eid=6855751&lang=en 
SOURCE: GE Appliances & Lighting 
GE Appliances & Lighting  Kim Freeman, Global PR Manager,
502-452-7819 kim_freeman@ge.com
Copyright Business Wire 2011
11.	http://waste360.com/business/arca-ge-expand-appliance-recycling-program
ARCA, GE expand appliance recycling program 
Allan Gerlat, Waste Age,  Sep. 14, 2011 7:32pm, 
Appliance Recycling Centers of America Inc. (ARCA), together with
GE Appliances & Lighting, have doubled their recycling offerings
from six to 12 states in the Northeast and Mid-Atlantic regions.
The initiative is part of the Environmental Protection Agency’s
Responsible Appliance Disposal (RAD) program. In a new effort to
involve appliance retailers in the RAD program, GE will help ensure
shipment of old appliances to the ARCA Advanced Processing (AAP)
regional recycling facility in Philadelphia.
GE also said in a press release that it will provide retail
partners with help marketing the program to their customers and
that ARCA will haul away the retailer’s used appliances and deliver
them to the recycling facility.
GE said about 40 percent of appliances collected by retailers are
resold.
The AAP facility uses a refrigerator technology that recovers about
95 percent of the insulating foam and reduces typical landfill
waste by 85 percent.  The UNTHA Recycling Technology (URT) system
cost $10 million and is capable of recycling 150,000 refrigerators
per year.
The EPA endorsed the move. “Their innovative partnership helps to
reduce pollution, eliminate waste and protect the earth’s ozone
layer,” said Gina McCarthy, assistant administrator for the EPA’s
Office of Air and Radiation. “EPA encourages other manufacturers to
follow their example.”
“We have a viable business that has the potential to grow well
beyond the 12 states we now serve,” said Jack Cameron, president
and CEO of ARCA. “The AAP facility in Philadelphia is a true
investment in our environment, our economy and our community.”
12.	E-Cycling Environmental -
http://www.ecycleenvironmental.com/junk-pick-up  
Appliance recycling is a service that everyone will need at one
time or another. Whether it is a refrigerator, freezer, washer, or
dryer. Everyone uses these items in their households. It makes
sense to recycle your appliance due to the high metal content.
However most people don’t know that your appliance may very well be
full of toxic substances. Hence, after E-Cycle Environmental’s junk
removal service comes and performs the pick up there is a lot of
prepping that has to take place before your old appliance can be
recycled. 
Refrigerators, freezers,AC Units, and dehumidifiers contain
refrigerants. These refrigerant substances are ozone depleting
substances, that if released to the environment, destroy the
protective ozone layer above the earth. Refrigerants have high
levels of green house gases, which means an improper release can
contribute to global warming. So after our junk removal serivce
picks up your appliance it needs to drained of any harmful
materials. Then the toxic substances have to be “treated” so as not
to harm the environment.
Other popular toxic substances that lie in your appliances are
mercury, lead, pcb’s, and oil liquids. All of these items need to
be handled and removed safely prior to the recycling process.
13.	San Francisco Peak Energy Program
http://www.sfaa.org/0410recycle.html 
Recycle a Fridge - Get 50 Bucks
By San Francisco Peak Energy Program 
Is your second refrigerator running? What sounds like an old
telephone prank is actually an invitation to have your older, spare
refrigerator or freezer picked up and recycled for free. Not only
is the pickup free, but Pacific Gas and Electric Company (PG&E)
will also pay customers $35 to take it away. Customers living in
San Francisco, will receive an additional incentive of $15 as part
of a joint partnership with San Francisco's Department of the
Environment (until funds are depleted).
The additional funding comes from San Francisco Peak Energy Program
(SFPEP), an energy-efficiency program designed specifically for
residents and business owners in San Francisco. The goal of the
SFPEP is to reduce peak energy demand in San Francisco and assist
in the closure of Hunters Point Power Plant by using a portfolio of
energy efficiency programs.
Under PG&E's statewide refrigerator recycling, customers are
encouraged to recycle eligible refrigerators and freezers, saving
energy and money while also earning a $35 incentive payment from
the utility. An environmentally recognized Bay area company, JACO
Environmental Inc., is operating the program.
This incentive is to encourage people who buy new refrigerators not
to hang onto their old ones. These inefficient units usually end up
in a garage, where they become storage for a few cans of soda or
some frozen dinners-a waste of energy and money.
To have your refrigerator or freezer picked up and recycled under
the approved program, the appliances need to be at least 14 cubic
feet in size and must have been manufactured before 1990. The
program is only open to customers who receive their electricity
from PG&E.
"This program is mostly targeted at those second refrigerators that
customers have in the garage or basement that operate needlessly,"
said Terry Pang, Senior Program Manager at PG&E. "Research has
shown that the majority of these spare refrigerators were built
before the current energy efficiency standards were put in place,
using up to five times the energy of newer models."
SFPEP hopes this added San Francisco incentive will encourage
residents to replace their older refrigerators with newer
energy-efficient models. The average refrigerator or freezer
manufactured before 1990 consumes about 1,500 kilowatt-hours
annually, costing up to $200 a year to run. Since 2001, federal
codes called for more energy efficient refrigerators/freezers,
which only use about 450 kWh per year. This means property owners
can save up to $150 on their annual bills if they replace an old
refrigerator with a newer model.
Both refrigerators and freezers are eligible for the program, with
a limit of two appliances per apartment unit. All refrigerators and
freezers must be empty and working at the time of pick-up. About 90
percent of each refrigerator or freezer will be recycled.
This program will also help relieve some of the pressure on the
state's electricity supply. Because refrigerators account for
almost 20 percent of the energy used by the average California
household, removing spare refrigerators and replacing older units
with Energy-Star models will remove some of the strain on the
electrical grid.
To expedite your request, please have your PG&E account number
available when placing the call. The refrigerator/freezer recycling
program is available to all PG&E customers through 2005 or until
funds are depleted.
For more details or to schedule an appliance pick-up PG&E customers
can call 800-299-7573. This program is funded by California utility
customers and administered by Pacific Gas and Electric Company,
under the auspices of the California Public Utilities Commission.
For more information on the San Francisco Peak Energy Program,
residential customers can contact the Smarter Energy Line at
800-933-9555 or www.pge.com/sfpep.
Please Note: San Francisco customers are eligible for the extra $15
incentive under the SFPEP through December 31, 2004 or until funds
are depleted. Under the SFPEP program, customers can receive $50
for recycling an eligible refrigerator or freezer that was
manufactured before 1990 and is 14 cubic feet or greater.
The opinions expressed in this article are those of the author and
do not necessarily reflect the viewpoint of the SFAA or the San
Francisco Apartment Magazine. 
http://www.pge.com/includes/docs/pdfs/shared/saveenergymoney/rebates/recycling/refrigerator/refrigeratorrecycle.pdf

At PG&E, we are committed to being an environmental leader and
demonstrating this through our actions. Up to 98 percent of all
materials from your refrigerator and/or freezer are recycled, and
all harmful chemicals are disposed safely.
14.	JACO Environmental Recycling Refrigerators
http://www.onearth.org/blog/jaco-repurposing-refrigerators 
Jaco Environmental: Recycling Refrigerators and Boosting the Ohio
Economy 
By Lauren Kubiak 
August 18, 2011 | (0) Comments 
Share | | 
Refrigerator recycling is a mysterious topic. How it’s done, if the
materials are separated, and how the iceboxes are repurposed is a
topic little known to the public and, until yesterday, myself. 
Jaco Environmental changed all of that. With what has to be the
most advanced refrigerator recycling method in the United States,
Jaco’s Stow, Ohio facility disassembles between 100 and 150
refrigerators a day, says facility manager Tom Stenheiser.
Employing cutting-edge shredding technology, Jaco is able to reduce
the refrigerators down to material parts in a matter of hours,
ending up with iron, copper, aluminum, plastic -- all valuable
commodities -- in addition to foam, CFC’s, oil, and refrigerant at
the end of the process. And beyond processing whole refrigerators,
Jaco’s Stow location’s shredder is capable of recycling an
additional 150-200 refrigerators that have gone through the first
stage of dismantling at one of their other U.S. facilities. 
So how does Jaco break the fridges down into their bare parts?
First, the refrigerator rolls through the initial processing
station and its compressor line is punctured, draining refrigerant
and oil. Next, workers saw the compressor off of the bottom and
move it onto the shredder. A giant monstrous-looking machine with a
saber toothed claw (see video below) grabs the refrigerator and
lifts it toward the jaws, four sets of spinning knives inside the
machine. Once the claws drop the refrigerator into the airtight
compartment, a blowing agent captures CFC’s -- a potent
ozone-depleting greenhouse gas -- from the foam insulation.
The shredder continues to process the refrigerator, and a thermal
distortion unit cleans the foam, which is extruded as a liquidy
mixture. A magnet in one of the machine’s compartments then removes
iron from the mix, and aluminum, copper, and plastic are left
behind to move onto another processing machine inside the facility.
 Don’t say you’re not intrigued. 
Company Profile: Jaco Environmental Location: Founded in
Washington, facilities in 26 states including Stow, OH  Recycling
appliances for: More than 20 years  Incentive: Offers $50 tax
rebate for functioning fridges (not to mention reduced consumer
energy bills)  Number employed: 35 at Stow facility  Serves:
Primarily U.S.  Recent trends: Growing. As Steinheiser explains,
"We haven't felt any pain [from the economic downturn], we keep
growing." 
15.	Ozone Depleting Substances and the Climate Action Reserve:
Perverse Incentives?  By Michael Wara
http://blogs.law.stanford.edu/enrlp/2010/11/18/ozone-depleting-substances-and-the-climate-action-reserve-perverse-incentives/
  Ozone depleting substances and the Climate Action Reserve:
Perverse Incentives? 
November 18, 2010 • by Michael Wara • comment [1] 
Some may have noted in the figures in my post from last week that
the Climate Action Reserve’s portfolio of issued offsets has a
heavy emphasis on the Ozone Depleting Substances (ODS) protocol. To
date, about 1/3 of issued Certified Reduction Tons (CRTs) come from
destruction of ODS at just one facility in Arkansas. This is also
why Arkansas is the origin of the greatest number of issued CRTs to
date. There are actually two ODS protocols, one for international
and one for domestic ODS. These protocols, particularly the
international protocol, illustrate some of the problems with the
CAR process as well as some of the potential pitfalls of offsets in
general and so bear further examination.
First off, a note on process. The ODS protocols were developed by a
working group that included not a single person with an
environmental advocacy background (see the acknowledgments to get a
sense for participation in the Working Groups). This is neither
good from an optics perspective nor a substantive one. Furthermore,
the public workshop for this protocol and notice and comment could
not have been more poorly timed to elicit participation. The
workshop was held on December 7, 2009 and notice and comment period
for the draft protocol were from November 20 to December 18, 2009.
These dates may not seem like a problem until you consider what
else people interested in international carbon markets might have
been preparing for and attending at the time (hint: I do not mean
Thanksgiving followed by an extended round of work-related holiday
parties). So, after the working groups failed to include NGO
participation, the process was poorly designed to illicit comment.
Indeed, it might have made more sense, given the international
nature of what was under consideration, to hold the public meeting
as a side-event at COP-15, either on- or off-site. If memory
serves, the CAR was represented in Copenhagen. Now this isn’t to
say that the Policy Team at CAR intended anything nefarious with
their scheduling; it is to say that the schedule they chose was
very poorly designed to attract participation.
Now to substance: the protocols require that a project purchase ODS
from a private or public facility, transport it to a RCRA certified
or equivalent ODS destruction facility within the US, and then
certify the chemical’s destruction. So far so good. The question a
thoughtful offsets critic might ask is, how much credit does the
developer get for this? And when? The protocols give 100% credit
for projected atmospheric emissions over a 10-year period on the
day that the ODSs are destroyed. The protocols call this
“conservative.” I would argue that it is both extremely aggressive
in its GHG accounting and creates potentially perverse incentives
for Article-5 (developing country) parties to the Montreal
Protocol.
The accounting is aggressive because it assumes that the current
legal and regulatory restrictions on ODSs will not get any stricter
over the next 10 years. This makes little sense, especially for
Article 5 countries, which, under the Montreal Protocol, only
stopped producing the ODSs in question as of January 1, 2010. These
countries might very well be in the process of developing stricter
regulations concerning the capture and destruction of existing,
legally produced, stocks of ODSs within their borders. The protocol
ignores this possibility, blithely stating that economic incentives
favor continued recycling of this material.
That argument may have had merit for non-Article 5 parties to the
Montreal Protocol (developed countries) because substitutes were in
the process of being invented and phased in for these countries at
the same time as the ODSs were being phased out. It is less clear
that the same will be the case in major developing economies where
the substitutes have been in use for some time. It’s one thing to
hoard your Cluorofluorocarbons when there are no competitive
substitute gases or substitute compatible equipment. But that is
just not the case for Article-5 parties in the present day because
of the earlier phase out in the non-Article 5, developed
countries.
In short, the protocol makes the most aggressive assumption
possible regarding credit for ODS destruction by giving all the
credit upfront for tons that might or might not have been allowed
to leak over the next decade. A far more conservative assumption
would have been to give credit on an annual basis based upon
regulatory developments in the ODSs country of origin.
The protocol also creates regulatory incentives that disfavor
domestic or international action to deal with ODS banks at agreed
incremental cost. One of the key successes of the Montreal Protocol
is its Multilateral Fund (MF). The MF has, over the past two
decades, paid the agreed incremental costs of conversion from ODSs
to safer alternatives in Article-5 nations. It has distributed more
than $2.5 billion to more than 6000 individual projects. “Agreed
incremental cost” means an agreed upon additional cost of an
alternative technology relative to the use of the CFCs. So if for
example, CFC production costs $100 million while HCFC production
costs $110 million, the MF will kick in $10 million to make the
net-cost to the developing country zero. Negotiation and agreement
of these costs occurs at the level of the MF Executive Committee.
I, amongst others, have proposed that this program might be the
appropriate avenue, rather than the carbon market, for especially
potent GHGs.
The US government under both the Bush and Obama Administrations,
has supported extensions, first proposed by the Maldives, to the
Montreal Protocol that are explicitly aimed at reducing the climate
impacts of ODS. What does this have to do with the ODS protocols
produced by CAR?
Creation of these protocols is, given time, likely to create a
strong constituency opposed to further modifications to the
Montreal Protocol that might address the existing banks of ODS.
It’s worth noting that addressing these banks has been the subject
of substantial study and policy analysis, most of which recommends
against the use of carbon markets. Thus to the extent that the CAR
protocol creates an incentive for a government to cease domestic
efforts to deal with its banks of ODS, resources are likely being
wasted (via inframarginal rents derived from the carbon market),
more effective domestic regulation is discouraged, and
international action on this important issue for the ozone layer
and climate is likely delayed.
None of this context is even addressed in the protocol’s
justification of additionality (of what would have happened in the
absence of the carbon offset project). The protocol instead takes
the view that the regulatory picture for ODS banks is static,
rather than highly dynamic, and elects to freeze the regulatory
picture so far as it relates to offset crediting, in the present
day. This both discourages what would likely be more cost- and
environmentally effective approaches to these ODS and potentially
allows the use of these substances within domestic cap-and-trade
schemes, thus diluting the environmental credibility of the climate
initiatives. Once again, a better solution here would be to allow
credit to be claimed for 10 years but to issue credits on an annual
basis that takes into account the then-current regulatory picture
for these gases.
My personal view is that the CAR needs to do a much better job of
incorporating environmental NGOs or advocates into their protocol
development process.  This will help to insure both political
credibility and that truly conservative assumptions regarding
baselines and accounting are built into their offset protocols.
Better process can lead to better substantive outcomes. Perhaps
this will occur without any action on CARs part: climate policy
wonk attention is rapidly shifting to California’s AB-32
implementation and away from Washington DC. But CAR’s Policy Team
shouldn’t remain a passive actor in this – the ODS protocols
illustrate the need to engage in active solicitation of NGO
participants for the offset development process. 
o	
16.	 EPA Website on the Partnership Program:
http://www.epa.gov/ozone/partnerships/rad/    
Responsible Appliance Disposal (RAD) Program 
EPA's Responsible Appliance Disposal (RAD) Program is a voluntary
partnership program that began in October 2006 to help protect the
ozone layer and reduce emissions of greenhouse gases. As part of
the RAD program, partners recover ozone-depleting chemicals from
old refrigerators, freezers, window air conditioners, and
dehumidifiers. Using best practices, RAD partners ensure that:
For the 2010 RAD Program Annual Report, visit RAD Annual Report.
Upcoming Events
RAD Program Webinar: Carbon Financing Opportunities for ODS
Destruction
The RAD Program Webinar Carbon Financing Opportunities for ODS
Destruction has been postponed. Updated information will be
available soon. Refrigerant is recovered and reclaimed or destroyed

Foam is recovered and destroyed, or the blowing agent is recovered
and reclaimed 
Metals, plastic, and glass are recycled 
PCBs, mercury, and used oil are recovered and properly disposed 
As part of the program, EPA serves as a technical clearinghouse on
responsible appliance disposal program development and
implementation; calculates annual and cumulative program benefits
in terms of ODS and GHG emission savings and equivalents and, as
available, potential cost savings; and provides partner recognition
for achievement, such as through press releases, brochures,
articles, and awards. 
RAD partners include utilities, retailers, local governments,
manufacturers, universities, and other interested organizations. In
addition to public recognition, joining the program may also serve
as a way to document climate efforts, and may help partners meet
any voluntary commitments or pledges they may have to reduce
greenhouse gas emissions. Partners may also reap additional
environmental benefits – in the form of reduced energy consumption
– by encouraging appliance owners to retire old inefficient
appliances that may consume between two and four times more energy
than new units.
State governments may also join the Program as RAD Affiliates, to
increase environmental benefits within their states. As Affiliates,
States promote the RAD Program to potential partners within their
state through information dissemination and strategic outreach.
They may also serve as technical resources and provide recognition
to Partners within their states.
GE Appliances Helps Unveil Fridge-Recycling Behemoth in Philly,
Expands Options for Customers and Supports New Jobs
It wouldn’t be out of place at a monster truck rally. 40 feet tall
and capable of eating up and breaking down 150,000 used
refrigerators annually, the new UNTHA Recycling Technology (URT)
system at the Appliance Recycling Centers of America’s (ARCA’s)
facility in Philadelphia is an engineering marvel. At an event
there this morning, GE and ARCA announced that the URT system is
ready to go to work on its first old fridge (as are the facility’s
50 new employees, whose new green jobs were supported by ARCA’s $10
million investment in URT and other new capital equipment). 
The URT system – a 40-foot tall engineering marvel that helps
reduce refrigerator landfill waste by 85 percent by weight.
The URT system can process approximately one refrigerator per
minute, and ARCA Advanced Processing (AAP) anticipates 150,000 used
refrigerators will be processed in the URT system annually. 
The first in North America, the URT system is a 40 foot tall
engineering marvel. It is the only refrigerator recycling system of
this scale in the U.S.
The URT system can transform refrigerator insulating foam into
pellets for use as fuel or other products.
The URT system recovers approximately 95 percent of the insulating
foam in refrigerators in a sealed system, reducing greenhouse gas
and ozone-depleting substance emissions compared to what typically
happens in the industry today. 
“Industry Way” – one refrigerator’s shredded insulating foam which
is typically landfilled (three large blue barrels). “The RAD Way” –
one refrigerator’s degassed and pelletized insulating foam, which
can be used as fuel or other products (lower, far right bucket).
Mark Shirkness, general manager, distribution services, GE
Appliances, watches the URT system process refrigerator insulating
foam. The URT system degasses and compresses insulating foam into
pellets, helping reduce greenhouse gas emissions and landfill waste
of a refrigerator by 85 percent by weight. The URT system recovers
high-quality plastics, aluminum, copper, steel and even pelletized
foam from refrigerators that can be used to make new products.
Shown here: steel. 
The URT system degasses and compresses insulating foam into pellets
in a sealed system, helping reduce greenhouse gas emissions and
landfill waste of a refrigerator by 85 percent by weight.   
There will be plenty of those refrigerators: since February, GE and
ARCA have doubled the number of states served, feeding 100,000
additional appliance units to the Philly facility from
Massachusetts, Connecticut, Pennsylvania, Maryland, Virginia, West
Virginia, New Jersey, New York, North Carolina, Delaware, Rhode
Island and Vermont. Consumers bring their used refrigerators to
participating retailers, like The Home Depot, who then send them to
ARCA. It’s all part of GE’s participation in the Environmental
Protection Agency’s Responsible Appliance Disposal program. 
The towering URT system’s performance is impressive. By recovering
around 95 percent of the insulating foam in refrigerators, in
addition to high-quality plastics, aluminum, copper and steel, URT
reduces the typical landfall waste of a refrigerator by 85 percent.
It also lowers the greenhouse gas and ozone depleting substance
emissions recovered from insulating foam. 
These achievements help ensure that the end of a GE appliance’s
life is just as sustainable as its birth: In April, GE became the
first full-line appliance manufacturer in the U.S. to adopt an
emissions-reducing foaming agent to make its top-freezer
refrigerators at its plant in Decatur, Alabama. From there and
everywhere else GE appliances are manufactured, they live
energy-efficient lives, recognized with the GE’s winning of a sixth
straight Energy Star “Sustained Excellence” award. Now, with URT
operational, GE refrigerators will be reborn as completely new
products. For example, steel recovered by URT will be sold to a
supplier for processing and then repurchased as steel deck plate by
GE Transportation for use in building locomotives. 
http://www.gereports.com/ge-appliances-helps-unveil-fridge-recycling-behemoth-in-philly-expands-options-for-customers-and-supports-new-jobs/

17.	Ozone Depleting Substances Redux – Instrument of Choice -
December 3, 2010 • by Michael Wara •
http://blogs.law.stanford.edu/enrlp/2010/12/03/ozone-depleting-substances-redux-%e2%80%93-instrument-choice/

First off, thank you to the many people that have responded, both
via email and in the comments section of the blog.   The point of a
blog is to elicit a conversation, and that has certainly ensued. 
The comments have all been very thoughtful and needless to say,
I’ve learned a lot. I strongly recommend that readers take the time
to read through them.   I’ve also continued reading on the issue
and have a few more thoughts to add.
All ODS projects are not created equal
First off, as Jeff Cohen of EOS Climate is at pains to point out,
it is important to distinguish between so-called “virgin”
stockpiles of ODS that exist in both government and private hands
in developing countries and the more dispersed banks that are where
most ODS reside. The stockpiles were the focus of my previous post.
Cohen states that, as far as he knows, government stockpiles
currently eligible for import into the US for destruction under the
CAR protocol, are relatively small – on the order of 300,000 tons.
If that estimate is accurate and the total mass of ODS in
government hands is not growing, then this is probably not worth
focusing too much attention or effort on. On the other hand, we’ve
already seen close to 2 million CRTs (23% of issued credits) enter
the market from virgin stockpiles to date.  Presuming that these
are the last of the privately held stockpiles that made it into CAR
before the deadline for private stockpiled imports closed, this
represents about 2 months of issuance at current rates and is
perhaps not something to be too concerned about as well.
The more interesting and important question then is, what do we do
about the dispersed banks of ODS, both in developed and developing
countries? 
These are (relatively) small volumes of gas incorporated into
things like building HVAC systems, large industrial chillers,
residential refrigerators, and the like.  The big question is
instrument choice for these dispersed ODS banks, in developed and
developing countries. In developed countries, most of this gas is
recycled under current law and regulation with only the fraction
that is too polluted to clean up being destroyed. In developing
countries, the extent of recycling is less clear. 
In my previous post, I made the argument that these dispersed banks
would be better addressed under the auspices of the Montreal
Protocol for developing countries.  Many in the ODS offset
community argue that carbon markets are essential.  For developed
countries, I think there are real questions that need to be
answered before we rush into a carbon market approach.
Dispersed ODS in developing countries
A key point of negotiation at the most recent MOP, second only in
importance to the issue of an early HFC phaseout, were the
developing country banks of ODS. There is a desire on the part of
some to utilize the Multilateral Fund (MF) of the Montreal
Protocol, mentioned in my previous post, to begin dealing with the
problem of banks. There are two big problems with an MF approach –
one financial, one legal.
The more important of the two can be summed up with one word:
money. It would cost quite a bit – estimates vary but on the order
of 50-150 billion dollars over 10 years – to deal with the existing
and predicted ODS banks. The MF doesn’t operate with nearly this
large of a budget and so would need substantial additional
resources to take a crack at it. On the other hand, the last time I
checked, that’s about what was being promised on an annual basis
for long-term climate funding to the developing world in 2020. Of
course one might not actually believe that the developed country
parties to the Copenhagen Accord have any intention (or are capable
of making a credibly commitment) to long-term climate finance.
Given that the MF as an institution has demonstrated long-standing
success in assisting (capacity and finance) developing countries
with implementation of relatively complex regulatory programs, it
might then make sense to utilize at least a part of the climate
finance to fund the MF for these activities. This funding would
have the advantage of helping to insure both a rapid reduction in
GHG emissions and a more rapid repair of the ozone layer – a double
dividend of sorts. Further, since the MF operates on a 3-year
budgeting cycle, it would be possible to gradually increase the
scale of funding for bank-related activities as they proved their
success. To sum up, the use of a portion of the funds promised to
2020 for climate to fund an expansion of MF opportunities would be
a highly credible alternative to the current situation where MRV of
both the sources and the uses of climate finance is one of the key
issues at the climate negotiations.
A separate but not unimportant problem is that there is an unclear
legal basis for the MF to engage in abatement of banks. The
Montreal Protocol was never designed to regulate banks – it governs
production and consumption of ODS, not their ultimate fate
post-consumption. One response is to suggest that the MF is not
actually regulating anything – of course it is used to assist
developing countries in complying with their Montreal Protocol
obligations, but so long as this new role did not conflict with its
mandare, then there need not be a problem with a bit of mission
creep. A better response is to argue that the Montreal Protocol has
been amended numerous times – it is a living document. The addition
of control measures aimed at banks after phase-out need not be
unprecedented. Indeed, provided the banks targeted were post-phase
out (eg CFC-11 and -12), then there wouldn’t even be a conflict
with the Montreal Protocol’s method for accounting for consumption
of ODS. One could add an Article that stated that all nations were
responsible for managing their ODS banks post-phase out to the
maximum extent feasible and then provide that Article 5 countries
would be provided agreed incremental cost funding for such
activities via the MF. 
Dispersed ODS projects in developed countries
So what about the United States? Should we use the carbon market or
traditional regulatory measures (command and control) to handle ODS
banks? I think the best answer is probably both. My view is that a
market based approach is appropriate for situations where the
regulator lacks either (1) capacity to get the job done or (2) the
information necessary to identify and abate sources of pollution or
(3) where the market can do the job for a lower social cost than a
more traditional approach. We have evidence from a number of
regulatory programs as to the effectiveness of a traditional
approach to ODS bank management, most notably from Australia. Jeff
Cohen of EOS Climate argues that this program has been ineffective
and has led to widespread venting. People I spoke with both in
government and in academia in Australia beg to differ and regard
the effort as “pathbreaking.” I do not know enough to be able to
comment here, except to say that there is a debate on the issue. 
What seems clear is that some sources will be easier to manage than
others. HVAC systems in large commercial buildings: easier – these
ODSs are already recycled. Insulating foams in residential
refrigerators: harder. Perhaps the right approach would be to phase
in regulatory controls for destruction for the lowest cost most
easily identifiable ODS banks in developed countries (a Montreal
Protocol TEAP study could no doubt identify these quite easily) and
leave the remainder for the carbon market – with periodic updates
to the split between regulatory and market-based efforts. The
effect of this would be to leave to the market what the market does
best – creating incentives to cost-effectively abate hard to
identify or control emissions sources – while leaving to the
regulators what they do best – abating easily identifiable sources
of pollution that are relatively small in number.
Could EPA or CARB implement such a program? Absolutely. The issue
is political will. The road that the Climate Action Reserve has
taken, making all offsets from ODS destruction additional, makes
this mixed outcome, far less likely. (Emphasis added.)
18.	Update for Visual Thinkers by Michael Wara
December 7, 2010 • by Michael Wara •  
I just updated my data for the Climate Action Reserve’s (CAR)
issuance of offsets to reflect activity during the month of
November. November was a relatively slow month with only 158,000
tons of offsets, called Certified Reduction Tons (CRTs), issued by
CAR.  One new state entered the picture, Kansas, with the issuance
of a sizable chunk of offsets from a landfill methane management
project.  As of December 1, 2010, the total offset volume verified
and issued under the CAR protocols comes to 8,407,713 tons. See
figure 1a and 1b for a picture of the developing market for US
offsets.
Figure 1a: CAR Offset Issuance by Project Protocol to December 1,
2010.
 
Figure 1b: CAR Offset Issuance by Project Protocol as a function of
time to December 1, 2010.
 
In an effort to better illustrate and understand the political
economy of the developing domestic offsets market, I created Figure
2, showing the distribution of offsets by state. It helps to drive
home the point that CAR is fast becoming a program of national
scope that should, over time, build constituencies in a number of
states that will push for adoption of federal cap-and-trade
legislation. Offset project owners will do this for no other reason
than that it will increase the value ($/CRT) of their projects.  Of
note, CAR is currently forming working groups to develop two
agricultural offset protocols.  These protocols hold the promise of
both producing significant tons for the California compliance
market, if adopted by CARB as compliance grade protocols, and of
adding a politically significant industry to the emissions trading
constituency.
Figure 2: Origin of CAR Issued Offsets by U.S. State to December 1,
2010.
 
AB 32, Agriculture, California, Climate Action Reserve, Climate
Change, Offsets 

19.	Disposal of Refrigerators – Freezers in the U.S.: State of the
Practice 
http://www.aham.org/industry/ht/a/GetDocumentAction/i/16317   see
map at page 21 of the PDF. (EPA Grant Research Paper).




Attachment www.arb.ca.gov/lists/capandtrade10/1577-lwilliams___azabel_ods_comment_9-26-11.doc
Original File NameLWilliams & AZabel ODS Comment 9-26-11.doc
Date and Time Comment Was Submitted 2011-09-27 03:11:39

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