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REPORT
Acting on Many Fronts
Incentives and Regulations to Phase-down HFCs in India
20 March, 2019 | Sustainable Cooling
Shikha Bhasin, Apurupa Gorthi, Vaibhav Chaturvedi, Torgrim Asphjell

Suggested Citation: Bhasin, Shikha,  Apurupa Gorthi, Vaibhav Chaturvedi, and Torgrim Asphjell. 2019. Acting on Many Fronts: Incentives and Regulations to Phase-down HFCs in India. New Delhi: Council on Energy, Environment and Water. 

Overview

This report provides insights on creating an ecosystem for India's successful transition away from hydrofluorocarbons (HFCs), maps the global regulatory options that could be adopted, and emphasises on the need for policy certainty. The report, published in collaboration with the Norwegian Environment Agency, is based on in-depth interviews with more than 60 industry stakeholders including primary refrigerant consumers, refrigerant manufacturers and suppliers, component manufacturers and suppliers, industry association representatives, and commercial users of products

As part of the Kigali Amendment to the Montreal Protocol, 197 countries committed to lower consumption and production of HFCs with high global warming potential (GWP). Under the Kigali deal, India agreed to curtail its HFC emissions by 85 per cent before 2047.

Sectoral mix of industry stakeholders interviewed

Source: CEEW compilation, 2019

How can India successfully transition away from HFCs?

  • Focus on policy certainty
    Policy certainty is key to realising India’s international commitments to phasing down HFCs. This will help create supply-chain readiness and encourage extensive investments that are necessary.
  • Impose a medium-term upper limit on GWPs
    Almost 70 per cent of the stakeholders we interviewed found this to be the most impactful and preferred policy choice for India. This entails imposing a GWP limit on refrigerants for each specific application, based on the two or three lowest GWPs existing in the market for each application or equipment. This would be supported by a financial incentive to the end user who will receive a rebate on the price of low-GWP products.

Source: Satish Kumar

  • Meticulous checks at each level of transition
    It is critical to have regular checks in the implementation of a refrigerant-focused policy for a successful HFC phase-down in India. These include institutionalising measurement, review, and verification (MRV); controlling stockpiling, and regulating the availability and pricing of refrigerants to avoid market manipulation.
  • Foster awareness about refrigerant transition
    This will play an essential role for all stakeholders involved in the process - for consumers to change their purchasing behaviour and demand, for industry to prepare for the impending refrigerant transition, and service sector technicians to ensure safety and maintenance.
  • Formulate policies supporting HFC phase-down
    Policies that support domestic competitiveness in manufacturing and in R&D, to subsequently limit reliance on non-certified and imported components and products would support India’s HFC phase-down strategy.

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Senior Programme Lead
"Over a hundred stakeholder meetings to understand technologies, challenges, and policies that will enable India’s contributions to potentially avoid 0.5 degrees of warming - this was an exhilarating research opportunity! India is home to so many development aspirations, and if we can crack our cooling and HFC challenge, we can contribute to jobs, industrial growth, productivity, health, and sustainability."

Executive Summary

Limiting global warming upto a two-degree celsius temperature increase requires significant ambition and action. At the current rate, even if all global pledges made under the Paris Agreement are met, the world is set to warm by at least 2.7°C by the end of the century.i In this warming world, remaining safe, healthy, and productive has become even more challenging. Our rapidly urbanising population continues to find refuge in artificially cooled oases. This cooling, largely based on hydrofluorocarbons (HFCs), is an Achilles heel.

HFCs are far more potent than carbon dioxide as greenhouse gases. A transition away from these highglobal warming potential (GWP) fluorinated gases holds the key to 0.5°C of global warming.ii In October 2016, 197 countries committed to the Montreal Protocol’s Kigali Amendment, agreeing to lower consumption and production of HFCs with high global warming potential (GWP), in recognition of the role of HFCs in contributing to global warming.iii

The Government of India agreed to a timeline of curtailing national HFC emissions by 85 per cent by 2047, as part of the Kigali Amendment. India negotiated for an extended phase-down period, allowing it a window of opportunity to learn from global best practices, and to recalibrate domestic strategies and plans to successfully meet its international commitments while ensuring that gains on other domestic frontlines, such as industrial productivity, jobs and skilling, manufacturing capacity, technology improvements and R&D, energy efficiency, and others, are optimised.

The sectors that will lie at the heart of this refrigerant transition - residential air conditioning (RAC), mobile air conditioning (MAC), commercial air conditioning (CAC), and commercial refrigeration (CR) - are poised for significant growth that will add to India’s GDP and job creation potential.iv,v Moreover, these sectors will also be central to India’s development imperatives, including providing thermal comfort against heat stress to ensure well-being and productivity, minimising food losses through cold chain development, and enhancing energy savings as a result of efficient appliances and equipment.

In response to this international environmental and national development imperative, in 2018, the Government of India released a consultative draft of its National Cooling Action Plan (NCAP), the first country to do so.vi It also created and signed a memorandum of understanding (MoU) to enhance servicing technicians’ training,vii as well as initiated efforts to update standards for some refrigerants that can be used as alternatives to HFCs.viii,ix,x The government has also recently announced a ‘Global Cooling Prize’ to encourage innovation for climatefriendly cooling.xi A snapshot of international and domestic policy drivers that are increasing the momentum towards climate-friendly cooling in India have been captured in the following page.

Continuing its efforts to research pathways to phase-down HFCs and transition to alternative refrigerants, CEEW signed an agreement with the Government of Norway in November 2017 to study incentives and regulatory approaches to enable the HFC phase-down in India.xii This research project, funded by the Government of Norway, has been undertaken in collaboration with the Norwegian Environment Agency (NEA). It intends to inform policymakers on the expected challenges and the role of regulations and policies in phasing down HFCs in sectors where these refrigerants are already in use, and where they could come into use in the near future.

It is widely accepted that the air conditioning and refrigeration sectors, as a whole, need to be overhauled to successfully transition away from HFCs. This will encompass changes and challenges for all parts of the supply chain, including: refrigerant and component manufacturers and suppliers; commercial users of these refrigerants and equipment; original equipment manufacturers (OEMs); research and testing labs; technology providers; standards authorities; educational and training institutions; operating, maintenance, and sales personnel.

 

Accomplishing this transition, as a result, will depend on the collaboration and cooperation of many actors. It will require calibrated and coordinated efforts all along the supply chain. Multiple governing agencies will also need to be actively involved, including ministries responsible for industry and commerce, human resource development, agriculture, health, buildings, automobiles, heavy industry, power, consumers, as well as the Ozone Cell of the Ministry of Environment, Forest and Climate Change.

Each of these actors has their own rationale, and their own barriers preventing them from moving forward. This research study is based on an effort to understand their challenges, and prioritise actions to address the rationales of different stakeholder groups.

For this study, the authors focused on stakeholder groups within industry, the main protagonist in the execution of India’s Kigali commitments. The research methodology included desk research, study trips to countries with policies to phase-down HFCs, and a series of interviews with private-sector stakeholders across the RAC, MAC, CAC, and CR supply chains, supplemented by consultations with experts from academia and government.

The information gathered from these studies and discussions has been used to understand policy preferences, the challenges in undertaking an HFC phase-down, and the larger elements of the entire ecosystem that must be made ready for India’s successful transition away from HFCs. Moreover, this study addresses India’s transition imperatives in achieving HFC phase-down commitments internationally, while enhancing its industrial and economic value to meet its growing aspirations for adequate cooling and a better quality of life.

In an effort to bridge the research gap impeding India’s policy discourse on phasing down HFCs, this report presents specific responses to the following research questions.

1. What policies and regulations do other countries use to phase-down emissions from HFC consumption and production?

2. Who are the different stakeholders in India (for example, HFC producers, equipment manufacturers, commercial building managers, service sector and waste collection personnel, etc.)?

3. What are the challenges for stakeholders, and what actions will they need to undertake, in order to move towards low-GWP refrigerant alternatives, and to reduce the operational and end-of-life emissions of high-GWP HFCs?

4. What policy incentives and regulatory approaches can propel the actions of different stakeholders towards an accelerated transition away from highGWP HFCs?

Research findings arising from an attempt to answer these questions have been highlighted below. To this end, this report is an attempt at introducing policy choices that can support India’s transition away from HFC gases. Key findings, on challenges and policy prescriptions, have been tabulated in the following spreadsheet ahead

A. Learning from global regulations

Although the Kigali Amendment to the Montreal Protocol was formalised only in 2016, many countries have already established regulations, policies, and incentive structures to phasedown the use of high-GWP refrigerant gases. The authors undertook an extensive literature review to map out global regulations and policies affecting HFC consumption and resultant emissions. They supplemented this with a study trip to understand the regulatory framework of Norway and the European Union (EU), including policies and mandates spanning the supply chain, servicing standards and trainings, refrigerant technology references, leakage and operational management of equipment, as well as end-of-life disposal. Key lessons for India from global policies are listed below.

The critical role of industry and markets

  • Firms remain the most significant stakeholders in implementing commitments made internationally to phase-down HFCs, and regulations should attempt to incentivise such actions.xiii,xiv
  • Voluntary industry actions dissipate the need for imposing strong regulatory measures on industry.xv, xvi, xvii
  • The purpose of regulations in this sector is to direct market behaviour, as evidenced in several studies.xviii
  • Some of the key qualifiers for the success of the Montreal Protocol include: (1) having a broad international agreement mandating global markets to move in a particular direction, thereby opening up a large market for companies offering non-CFC refrigerant-based products; (2) domestic regulations imposed on ozone-depleting substances (ODSs), to incentivise the use of alternative refrigerants; and (3) ensuring the representation of companies and industry in policy and technical discussions, encouraging them to find alternative technological solutions.xix, xx, xxi

HFC phase-down is a multi-institutional regulatory challenge

  • A successful transition requires tackling the HFC phase-down through a regulatory framework that is based on systematic stakeholder engagement.xxii
  • Different regulations have been employed for phasing down HFCs across the world, addressing HFC refrigerant use in terms of the supply side, demand side, service sector, and/or end-of-life disposal. xxiii, xxiv
  • For a smooth transition to alternative refrigerants, it is imperative to establish regulations for safety and technology standards, national phase-down targets, operational emissions, and end-of-life disposal policies.xxv
  • The success of the Montreal Protocol is largely attributed to regulations working in tandem with the private sector.xxvi Drawing on this, a successful HFC phase-down in India will need in-depth and broad-based stakeholder interactions between the government, scientific community, and industry.
B. Key stakeholders for India’s HFC phase-down

As highlighted above, the HFC phase-down in India will require the participation of various stakeholders, both within and outside the government.

Based on literature, existing networks, consultations with experts, and the snowballing method, an estimation was made of the broad base of institutions, sectors, and supply chains impacted by, or influencing, India’s Kigali Amendment commitments. Specific to this study, we identified key stakeholder groups in India, as detailed in the table on the following page.

Stakeholders to enable India's HFC phase-down

Source: CEEW compilation

C. Industry challenges and policy responses to propelling the phase-down of HFCs

Using the above mapping, industry stakeholders were identified across supply chain roles, and 60 mid- to senior-level respondents were interviewed for this study. These interviews were based on semi-structured questionnaires aimed at developing an understanding of industry’s policy needs and regulatory preferences with regard to taking forward the challenge of transitioning away from HFCs in India.

The interviewees belonged to the RAC (23 per cent), MAC (14 per cent), CAC (8 per cent), and CR (15 per cent) sectors. Close to 40 per cent of the stakeholders were involved in two or more of these major sectors. In terms of supply chain roles, primary refrigerant consumers constituted the largest percentage of stakeholders, followed by component manufacturers/ suppliers, consultants and service providers, refrigerant manufacturers and suppliers, and commercial users of products. The authors also interviewed four industry associations representatives from the RAC, CAC, and CR sectors. The study also covers stakeholders from small, medium, and large enterprises, which are classified according to their annual turnover, representing 20 per cent, 27 per cent, and 46 per cent of the stakeholderbase, respectively. Associations were not classified in terms of enterprise size.

Sectoral mix of industry stakeholders interviewed

Source: CEEW compilation, 2019

Barriers to transition: policy uncertainty

In order to empirically understand and record the challenges and opportunities anticipated by stakeholders in enabling or undertaking HFC reductions, and the ways in which regulations or policy incentives could respond to them, we used qualitative data from interviews to construct a ‘grounded theory’. Based on this qualitative analysis, we found that the largest drawback that unanimously came through in all interviews was the policy uncertainty, preventing companies from making adequate changes in preparation for phasing down HFCs in India.

The key reasons why this lack of policy certainty emerges so consistently as an impediment can be understood from the perspective of both supply chain readiness, as well as the investments that HFC phase-down would require.

Supply chain readiness

Alternative refrigerants’ applicability

Stakeholders spoke of the need to know definitively which alternatives to high-GWP HFCs would be viable and available, before investing accordingly. While several natural and synthetic refrigerants have been identified and are being deployed globally as alternatives to HFCs, their application is contingent on several factors, including standards, charge limits, levels of energy consumption, safety aspects, as well as performance. For smaller players,xxvii these factors constrain future strategy and planning, especially given the lack of policy certainty around the phase-down in general, and the alternatives’ standards and applicability in India. The lack of government-initiated pilot programmes to measure and test alternatives also contribute to this information gap.

Alternative refrigerants’ affordability and availability

Sourcing affordable and adequately available alternative refrigerants is a huge anticipated challenge for industry. In India’s previous refrigerant transition, the prices of refrigerants rose dramatically, and in smaller cities and towns there was a recorded shortage as well as price hike. This, in turn, led to the creation of an unorganised black market that sold the refrigerants, many of them uncertified blends, at an even higher price. The policy framework for any phasedown must include checks and balances, such that refrigerants are readily available in the market, and illegal market capture through imports and shortage-induced price manipulations are kept in check. Policy measures to consider while creating a regulatory framework to phasedown HFCs in India may include measures to monitor refrigerant availability by reporting national production; transparent and diligent testing of imports; minimising leakage during operations and at the end-of-life of the refrigerant; as well as indicating a ‘maximum retail price’ of various refrigerants.

Alternative refrigerants’ standards and benchmarks

Several industry stakeholders have been working closely with the Bureau of Indian Standards (BIS) on reforming and updating standards for various low-GWP refrigerants; however, progress has been slow on multiple fronts in this regard. The lack of government-authenticated performance and safety benchmarks for alternatives discourages their uptake, and lowers investments towards R&D to optimise these refrigerants’ applications in India. A fast-track window to develop or update different refrigerants’ standards may be a way to indicate intent towards a low-GWP transition. More significantly, it may facilitate a fairer competition between various refrigerants in the market, rather than inadvertently picking winners based on a few established standards. India would also benefit by undertaking a life-cycle assessment of all alternatives coming into the market, given that several alternatives in use globally are being found to have negative environmental impacts.

Component availability and readiness

Some degree of change is required in components and system design for integrating any alternative refrigerant, even in the case of retrofitting replacement gases. In order to invest in such changes in systems and components, a clear timeline of how a phase-down will affect each sector (and thereby each company) is required, so that component manufacturers and suppliers can ready themselves. If this is not planned adequately as an opportunity for Indian industries to upgrade their supply chains, factories and companies will be forced to rely on imports and international suppliers, rather than encouraging innovation and investments among Indian component suppliers.

Service sector readiness

If the quality and safety of servicing practices are to remain intact, a minimum threshold for trainings has to be established by way of updated curricula, and more significantly, certifications for service technicians. Many countries prohibit non-licensed or non-certified service technicians from installing, servicing, or repairing air conditioners, or handling refrigerants. With such certifications, social welfare and security can also be enabled through targeted insurance and repeated trainings. Investments and a blueprint for undertaking such a formalisation of the service sector will be necessary to create an ecosystem in which several refrigerant gases can exist in the Indian market. Moreover, training and the fomalisation of the service sector need to be accompanied by a policy instrument that mandates leak tests (in large and mobile applications especially) and establishes standardised professional servicing practices. Good policy-directed practices that have already been brought out in India, such as the banning of disposable cylinders, also need to be implemented effectively.

End-of-life disposal

In India, there is no mandate to recover, reclaim, or destroy refrigerant gases effectively. Even where facilities exist for the disposal of gases, the recovery and transportation costs act as a huge disincentive, so there is often a need for incentives or regulations to ensure recovery. This part of the value chain in India remains severely constrained and inadequately understood. Convenient and functional infrastructure, accompanied by policy mandates, is crucial to ensure safe and effective end-of-life management of gases. For India to meet its HFC phase-down targets, end-of-life disposal of refrigerants is important, as is reducing emissions during the operational life cycle. Given the lack of infrastructure, policy, and business action in India on this front, there is a need to identify and understand different business cases for effective policy implementation to minimize operational and end-of-life emissions.

Investment decisions

Any policy to phase-down HFCs will affect significant parts of the value chain; the transition will require investments in, and upgrading of, industrial supply chains in the heating, ventilation, and air conditioning (HVAC) sectors. For any change that the manufacturing or adoption of an alternative refrigerant will require, a company will need to pay for associated costs. Investments will be directed towards safety on factory floors, infrastructure modulations, technology training, the cost of new manufacturing facilities, updating systems to adapt to the new refrigerant, and other verticals, in addition to the new cost of manufacturing or procuring the refrigerant itself. As highlighted above, even gases that can be substituted for HFCs through retrofitting will still require some degree of component change. There is a need for clear policy directives to guide the timing of such an investment, especially given the cost-competitive market that India already is. Moreover, a strategic policy framework can propel investments towards R&D and increased manufacturing in these sectors, and provide a fillip to key policy initiatives of the Government of India, such as Make in India and Doubling of Farmers’ Income.

Policy coordination and effective implementation

Given that refrigerant change will not occur in isolation, stakeholders across government agencies must cooperate to ease the transition, rather than imposing multiple mandates on industry. This will require policy cohesiveness between the Ozone Cell and other government agencies. A coordinated effort to meet India's HFC phase-down commitments can also benefit strategic industrial growth in cold chain development, enhanced energy efficient appliances, etc. Similarly, development and implementation of building norms, accompanied by the roll out of alternatives to HFCs for cooling needs, must be considered. Furthermore, misuse or noncompliance with guidelines and norms set by the government, sale of spurious or substandard components and gases, and the use of equipment that is in direct violation of regulations must be checked. Ineffectiveness in policy implementation is a huge challenge for India, and is not limited to this sector.xxviii

Consumer awareness

For the supply side to deliver effectively, demand must also be created and assured for this transition. To aide policy in this direction, it is important to identify the role of information and awareness on consumer behaviour. Suggestions from industry with regard to policy interventions on this front include labelling systems for products which indicate environmental performance or ‘goodness’. This awareness must also be reflected in larger training interventions for retail suppliers and sales teams. Given the challenges faced by industry in phasing down HFCs, their expressed policy preferences, and their proven potential for leadership in this endeavour, there is a clear need for a robust regulatory framework supporting industry in the transition away from HFCs. The next section of this study, therefore, highlights the stakeholders’ perceived preferences for specific HFC phase-down regulations and policies and their expected impact, as applicable in the Indian context.

D. Regulatory options for phasing down HFCs in India

Five policy options employed to lower HFC consumption in different parts of the world were handpicked in consultation with senior India experts from civil society, industry, and the Government of India’s Ozone Cell. These were then assessed based on stakeholders’ responses to them during the interviews. Interviewees were requested to rank these policies, as well as to indicate their preferences and the anticipated impact across two Likert scales, ranging from least to most desirable, and least to most impactful, respectively.

Responses on policy choices were evaluated at a macro-scale, following which data was reassessed to examine any trends emerging in policy choices based on sector (RAC, CAC, MAC, and CR) and enterprise size (small, medium, and large).

At the macro-level, a subsidy-based policy instrument emerged as the top policy choice, followed closely by the GWP limit policy instrument. This was based on a policy receiving the highest number of ‘most impactful’ and ‘most desirable’ ratings from stakeholders. The subsidybased policy would be directed at users of refrigerants, so as to encourage demand creation for low-GWP alternatives to high-GWP HFCs; and the GWP limit policy suggested mandating medium-term targets on the maximum GWP value applicable on refrigerants in specific applications, based on current commercial viability.

On aggregating Likert scale values into negative (‘not’ and ‘least’) and positive (‘mildly’ and ‘most’) responses for policy preference and impact, we observed a slightly different trend. The GWP limit policy instrument emerged as the top choice in terms of preference and impact, followed by the subsidies-based policy instrument. Further, the GWP limit was ranked fifth (the lowest preference) by 18 per cent of the stakeholders, while 25 per cent of the stakeholders ranked the subsidies-based policy instrument, fifth. The third-highest ranked policy choice was cap and phase-down.

Comparison between preference* and impact* of the policy options based on Likert scale evaluation

Trends in policy choices based on sector and enterprise size

The top three policy choices at the macro-level, based on a sector-based classification (RAC, CAC, MAC, and CR) and on enterprise size (small, medium, and large) were: the GWP limit, subsidising low-GWP-based products, and the cap and phase-down approach.

In terms of positive impact and desirability, GWP limit was the top policy choice for all sectors, except MAC. 38 per cent of MAC sector stakeholders indicated subsidies for using low-GWP refrigerant products as their top policy choice, still, 25 per cent of MAC sector stakeholders also chose GWP limit.

Sectoral trends: Top policy choices based on impact* and preference*

Source: CEEW compilation, 2019

Medium-sized enterprises and associations unanimously selected GWP limit as the top policy choice in terms of preference and impact. Among large enterprises as well, the GWP limit emerged as the top policy choice in terms of impact and desirability. In terms of positive preference and impact, about 89% of small enterprises placed the GWP limit at the top.

GWP limit was the top policy choice across enterprises of different sizes based on impact* and preference*

Source: CEEW compilation, 2019

Thus, based on the 60 stakeholder interviews, we find that the most popular and feasible policies according to industry were: (i) placing of GWP limits, (ii) subsidising low-GWP-based products, and (iii) the cap and phase-down approach. Among these, the GWP limit - based policy instrument emerged as the most popular, with a few deviations observed under specific conditions. At the macro-level, the aggregate positive responses for preference and impact were noticeably higher for the GWP limit option than for the subsidies-based policy instrument. Given that this policy choice was also validated as a key outcome of a closed-door industry roundtable that the research team hosted to share initial research results, the authors are able to conclude that a policy placing a medium-term GWP limit on refrigerant-based applications, based on current commercial viability, is the most preferred industry option for establishing India’s HFC phase-down strategy

Conclusion

India has a lot at stake in how industry in the RAC, MAC, CAC and CR sectors moves forward, from a domestic development perspective as well as from a global good, or environmental preservation, perspective. Despite the data that asserts the criticality of a timely and adequate transition to low-GWP refrigerants, research has yet to put forward the various policy elements that a regulatory framework in India must incorporate to achieve this end. This report is an attempt at bridging this research gap.

This report presents policy prescriptions based on the responses gathered from key stakeholders in Indian industry. The study empirically establishes that policy certainty is key to achieving India’s international commitments to phasing down HFCs. This factor is most relevant for industry to initiate this transition, as it is crucial to enabling supply chain readiness and justifying the necessary investments.

Among the policies discussed with stakeholders to enable a refrigerant transition in India, the most preferred policy involved putting a medium-term limit on the GWP value of HFC refrigerant gases for each application, based on current commercial viability. A supplementary incentive for the end-user to promote low-GWP products would be an ideal policy package directed at discouraging high-GWP HFCs. Furthermore, checks and balances to implement these policies are critical to their success in India.

In addition to the above, ancillary policies to facilitate other refrigerant-management strategies should form an important part of India’s phase-down strategy. These management practices could address servicing standards and the certification of service sector professionals as a way to limit operational leakages, as well as regulate the end-of-life recovery and disposal of refrigerants. There is an industry inclination towards the impending HFC transition, but the ‘ecosystem’ of the supply chain, policy directives towards end-of-life disposal, as well as service sector training and certifications, must be readied adequately for it to have an impact. This would also include institutionalising measurement, review, and verification (MRV) systems and agencies, in order to control stockpiling and the emergence of a second-tier black market, regulate the availability and pricing of refrigerants to avoid market manipulation, and bring out clear standards and safety mandates for all refrigerants to be able to compete in the Indian market.

Finally, access to information regarding the refrigerant transition has to be systematically organised and widely diffused. This is important for consumers (to change purchasing behaviour and demand), for industry (to prepare itself for the impending refrigerant transition), and for service sector technicians (to ensure safety and maintenance).

iClimate Action Tracker (2017) “Improvement in Warming Outlook as India and China Move Ahead, but Paris Agreement Gap Still Looms Large,” Climate Action Tracker, November, available at https://climateactiontracker.org/publications/improvement-warming-outloo.... accessed 12 January 2019.

iiVelders, Guus, David Fahey, John Daniel, Stephen Andersen, and Mack McFarland. (2017) “Climate Impacts of Montreal Protocol and Kigali Amendment,” paper presented at the IO3C 30th anniversary MP Symposium, Paris, 28 March, available at http://www.montreal30.io3c.org/sites/ montreal30.io3c.org/files/pictures/20%20matin/Velders_30MP_Symposium_Paris_Sept2017.pdf; accessed 12 January 2019.

iiiIndia committed to reducing 85 per cent of its average production/consumption of HFCs compared to its baseline years (2024–2026). See Chapter 1 for more details

iv Bhasin, Shikha, Lekha Sridhar, and Vaibhav Chaturvedi (2017) “Developing an Ecosystem to Phaseout HFCs in India: Establishing a Research and Development Platform,” CEEW, September, available at https://www.ceew.in/publications/developing-ecosystem-phase-out-hfcs-india; accessed 12 January 2019.

v Chaturvedi, Vaibhav, Mohit Sharma, Shourjomoy Chattopadhyay, and Pallav Purohit (2015) “India’s Long Term Hydrofluorcarbon Emissions,” CEEW-IIASA Report, May, New Delhi.

vi Press Information Bureau (2018) “World Ozone Day 2018,” Press Release, MoEFCC, Government of India, 17 September, available at http://pib.nic. in/newsite/PrintRelease.aspx?relid=183506; accessed 12 January 2019.

vii UNI (2018) “MSDE Inks MoU with Environment Ministry for Upskilling in AC Sector,” United News of India, 2 August, available at http://www. uniindia.com/msde-inks-mou-with-environment-ministry-for-upskilling-in-ac-sector/business-economy/news/1307899.html; accessed 12 January 2019.

viii According to industry experts, BIS has created a panel to consider amendments to refrigerant standards for wider use of HC 290, a low-GWP, flammable refrigerant.

ix CSE (2016) “Safety Issues and Standards for HC-290 in Room Air Conditioners,” Shakti Foundation, available at http://shaktifoundation.in/wpcontent/uploads/2017/06/CSE-2016-Safety-iss... accessed 12 January 2019.

x According to industry experts, BIS has created a panel to consider amendments to refrigerant standards for wider use of HC 290, a low-GWP, flammable refrigerant.

xi For more information, please see https://globalcoolingprize.org/

xii Royal Norwegian Embassy. 2017. “Cool Alternatives.” The Royal Norwegian Embassy in New Delhi, News and Events, December 4, 2017. available at https://www.norway.no/en/india/norway-india/news-and-events/new-delhi/ne... accessed 12 January 2019.

xiiiBergeson, Lynn L. (2017) “The Montreal Protocol Is Amended and Strengthened,” Environmental Quality Management 26(3): 137–41.

xivDeSombre, Elizabeth R. (2000) “The Experience of the Montreal Protocol: Particularly Remarkable, and Remarkably Particular,” UCLA Journal of Environmental Law and Policy 19(1): 49–81.

xvConsumer Goods Forum (2018) “Refrigeration,” available at https://www.theconsumergoodsforum.com/initiatives/environmental-sustaina... accessed 12 January 2019.

xviSamuelson, Shiela (2010) “Voluntary Reporting of Carbon Emissions: How and Where?” Triple Pundit, available at https://www.triplepundit. com/2010/05/voluntary-reporting-carbon-emissions/; accessed 12 January 2019

xviiSchwarz, Winfried, Barbara Gschrey, Andre Leisewitz, Herold Anke, Sabine Gores, Irene Papst, Jurgen Usinger, et al. (2011) “Preparatory Study for a Review of Regulation," (EC) No 842/2006 on Certain Fluorinated Greenhouse Gases, European Environment Agency, available at https://www.eea. europa.eu/data-and-maps/indicators/emissions-and-consumption-of-fluorinated-2/preparatory-study-for-a-review; accessed 12 January 2019.

xviiiMolina, Mario, Durwood Zaelkeb, K. Madhava Sarmac, Stephen O. Andersend, Veerabhadran Ramanathane, Donald Kaniaruf (2009) “Reducing Abrupt Climate Change Risk Using the Montreal Protocol and Other Regulatory Actions to Complement Cuts in CO2 Emissions,” Proceedings of the Natural Academy of Science 106(49): 20616-20621

xixOye, K. A, and Maxwell, J H. (1995) "Self-Interest And Environmental Management", in Local Commons and Global Interdependence: Heterogeneity and Cooperation in Two Domains 191,198 (Robert O. Keohane & Elinor Ostrom, eds., 1995)

xxGreene, Owen (1998) The System For Implementation Review In The Ozone Regime, In the Implementation and Effectiveness of International Environmental Theory and Practice 89, 97-8 (David G. Victor et. al., eds. 1998)

xxiHoerner, J. A, (2000) "Taxing Pollution, In Ozone Protection in the United States, 39-54.

xxiiUNEP. 2016. “OzonAction Factsheet: The Kigali Amendment to the Montreal Protocol: HFC Phase-Down.” UNEP. http://wedocs.unep.org/bitstream/ handle/20.500.11822/26589/HFC_Phase-down_EN.pdf?sequence=1&isAllowed=y; accessed 12 January 2019.

xxiiisee for example Zaelke, Durwood, Nathan Borgford-Parnell, and Stephen O Andersen (2018) “Primer on HFCs,” Institute for Governance and Sustainable Development, available at http://www.igsd.org/wp-content/uploads/2018/01/HFC-Primer-v11Jan18.pdf; accessed 12 January 2019.

xxivBrack, Duncan (2017) “National Legislation on Hydrofluorocarbons,” Institute for Governance & Sustainable Development, available at http://igsd.org/ documents/NationalLegislationonHydrofluorocarbons_9.11.15.pdf; accessed 12 January 2019. xxv Based on learnings from study trip and literature review. Refer to Annex I and Annex II of the main report for details.

xxviDeSombre, Elizabeth R. (2000) “The Experience of the Montreal Protocol: Particularly Remarkable, and Remarkably Particular,” UCLA Journal of Environmental Law and Policy 19(1): 49–81

xxviiBergeson, Lynn L. (2017) “The Montreal Protocol Is Amended and Strengthened,” Environmental Quality Management 26(3): 137–41.

xxviiiThis is beyond the scope of the study at hand; hence, no policy recommendations are being indicated here

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