2111 Wilson Boulevard Suite 500 Arlington VA 22201-3001 USA 

Phone 703 524 8800 1 Fax 703 562 1942 

www.ahrinet.org 

AIR-CONDITIONING, HEATING, 

& REFRIGERATION INSTITUTE 

we make life better'° 

Oral Statement of 

Karim Amrane 

Air Conditioning, Heating, and Refrigeration Institute 

Before the 

Environmental Protection Agency 

On 

Protection of Stratospheric Ozone: Change of Listing Status for Certain 

Substitutes Under the Significant New Alternative Policy Program 

Docket ID No. EPA—HQ— OAR-2014-0198, 

As published in the August 6, 2014 Federal Register 

August 27, 2014 

Washington, D.C. 
AHRI's Oral Statement on Change of Listing Status of Certain Substitutes 

EPA Hearing, August 27, 2014 

Page 2 

The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) appreciates the 

opportunity to appear before you and provide input on the notice of proposed 

rulemaking (iVOPR) regarding the change of listing status for certain substitutes 

under the Significant New Alternative Policy Program (SNAP). AHRI is the trade 

association representing manufacturers of heating, coofing, water heating, and 

commercial refrigeration equipment. More than 300 members strong, AHRI is an 

internationally recognized advocate for the industry, and develops standards for 

and certifies the performance of many of the products manufactured by our 

members. In IVorth America, the annual output of the HVACR industry is worth 

more than $20 billion. In the United States alone, our members employ 

approximately 130,000 people, and support some 800,000 dealers, contractors, 

and technicians 

AHRI has a long history in support of environmental issues. We supported the 

phase out dates in the Clean Air Act for refrigerants that deplete the ozone layer. 

We have worked very closely with the Environmental Protection Agency on 

issues related to climate change, refrigerant purity, recovery/recycle equipment, 

and technician certification. AHRI has been the recipient of 5 EPA stratospheric 

ozone protection awards including the "Best of the Best" award for its leadership 

in helping the air-conditioning and refrigeration industry move away from ozone 

depleting substances. 
AHRI's Oral Statement on Change of Listing Status of Certain Substitutes 

EPA Hearing, August 27, 2014 

Page 3 

AHRI has been an industry leader in researching alternative refrigerants. In the 

1990's, our alternative refrigerant evaluation program (AREP) successfully led to 

the identification of substitute refrigerants to ozone depletion substances. Three 

years ago, we started a similar program to identify low-GWP alternatives. This 

program, called the Low-GWP Alternative Refrigerants Evaluation Program (LowGWP AREP) has evaluated 38 alternatives in various air conditioning and 

refrigeration applications. Results for the first phase of the program are available 

on the AHRI website. A second phase was initiated this year to evaluate 

additional low-GWP refrigerants. 

AHRI supports an amendment to the Montreal Protocol that would achieve a 

gradual phase down of HFCs to allow for the development of low global warming 

potential (GWP) alternative technologies. EPA supported the North American 

Amendment Proposal to the IVlontreal Protocol which calls for a similar gradual 

phase down of HFCs. However, provisions of the proposed rule that are 

modifying the listing of certain HFC refrigerants and foam blowing agents by 

January 1, 2016 or 2017 are inconsistent with the EPA stated position at the 

Montreal protocol. 

AHRI is ver/ concerned with the proposed rule and its potential negative impact 

on commercial refrigeration equipment manufacturers. We believe that the 

proposed change of status of R-404A, R-507A, R-134a and other HFC blends in 

stand-alone commercial refrigeration equipment is premature and will leave 
AHRI's Oral Statement on Change of Listing Status of Certain Substitutes 

EPA Hearing, August 27, 2014 

Page 4 

manufacturers with no viable alternatives. Most of the SNAP listed low-GWP 

refrigerants for this application will result in less efficient products and will 

increase overall greenhouse gas emissions, which is contrary to the stated 

objectives of the rule. It should be noted that direct refrigerant emissions 

represent on average less than 10% of the overall life cycle climate performance 

(LCCP) of stand-alone commercial refrigeration systems. Taking this fact into 

account, EPA should accept additional alternatives for this end use, including R407A and R-407F. 

However, for all commercial refrigeration end uses, the proposed transition 

effective date of January 1, 2016 is unrealistic, unfeasible and inconsistent with a 

gradual phase down of HFCs that EPA is advocating internationally. Similarly, 

the January 1, 2017, transition date for foam blowing agents is impractical. 

Manufacturers will need a significant amount of time to test new alternatives and 

get the necessary safety listings from agencies such as UL and ETL. There is 

currently not enough laboratory testing facilities in the U.S. to accommodate all 

the testing that would be required in the amount of time that EPA is 

contemplating. Furthermore, the use of most of the alternatives that EPA 

believes could be implemented in a short period of time is severely restricted by 

all major mechanical, fire and building codes in the U.S. Although work has 

already started to amend these codes to accommodate the alternative 

refrigerants, the process will take several years to complete. Complicating 

further the matter are new federal minimum energy conservation standards for 
AHRI's Oral Statement on Change of Listing Status of Certain Substitutes 

EPA Hearing, August 27, 2014 

Page 5 

commercial refrigeration equipment and walk-ins that are expected to take effect 

in 2017. The Department of Energy (DOE) has adopted very aggressive 

standards that may not be achievable with the current alternatives, potentially 

forcing manufacturers not to comply with the law. Taking all these issues into 

account, we believe that a more realistic implementation date would be around 

year 2020 at a minimum. 

Finally, we would like to express our concern with the lack of coordination 

between EPA and DOE on rulemaking activities impacting the same industry. As 

previously mentioned, DOE has set very aggressive new federal minimum 

energy conservation standards for commercial refrigeration equipment and walkin coolers and freezers, and has based its entire analyses on refrigerants and 

foam blowing agents that EPA is now proposing to list as unacceptable. The 

proposed SNAP rulemaking has significant energy efficiency implications, and 

EPA has an obligation to ensure that the alternatives it proposes result in 

products with equal or less energy consumption that are affordable to 

consumers. 

Thank you for the opportunity to present our views. We will provide more 

detailed comments in writing.