Friday, January 11, 2013

Your editorial “Climate change catches fire” (Comment & Analysis, Wednesday) missed the point about Daimler’s objections to the refrigerant HFO-1234yf. Regardless of your view on the evidence of climate change, it is essential to acknowledge the critical role of regulation in signaling industry to make significant investments in new technologies.

In response to the European Union’s Mobile Air Conditioning Directive, passed six years ago, Honeywell made the investments to commercialize HFO-1234yf, which many carmakers then selected as their choice to comply with the directive. Consistent with good regulation, it set a policy standard and allowed the free market to select the path and choose the new technology. Many automakers engineered their vehicles for HFO-1234yf because they saw it as the safest, most cost-effective and environmentally friendly solution. Their selection was backed by comprehensive testing conducted over a three-year period under the Cooperative Research Program of SAE International, sponsored by 15 global automakers, including all leading German automakers. SAE’s study concluded that HFO-1234yf is safe for use in automobile applications.

In contrast, the Daimler testing was conducted without the participation of any reputable third party and without consultation with others in the industry, and it happened just a little more than three months in advance of the Mobile Air Conditioning Directive’s implementation. The automotive industry has actively worked and invested to meet these regulations. Even stories in leading German publications have questions about Daimler’s motives in pushing back on the regulation so late, suggesting the resistance now may be cost- or publicity-related. Despite Daimler’s objections, no other original equipment manufacturers have raised concerns with HFO-1234yf, according to SAE International.

At issue here is not whether climate change is real but whether the European Union has a level commercial playing field. When the rule of law is not enforced, it removes incentives for businesses like Honeywell to invest in the innovative materials needed for the cars of the future.

TERRENCE HAHN

Vice president/general manager

Honeywell Fluorine Products

Morristown, N.J.

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