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### 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. Thisprogram, 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 leaveAHRI'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 intoaccount, 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 forAHRI'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 minimumenergy 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.