Huh. Just went and checked the EPA GWP references and found that I was misremembering something else, not the HFO GWPs. No time to track it down, or why I think the US program is trending into mediocre territory, but I'm clearly wrong about something. Thanks for poking me on this.

https://www.epa.gov/climate-hfcs-reduction/technology-transitions-gwp-reference-table