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MEMORANDUM

To: Luke Hall-Jordan, U.S. EPA

Cc: Elizabeth Whitely and David Donaldson, U.S. EPA

From: Becca Shopiro, Christine Gajewski, Derina Man, and Jessica Kyle, ICF International

Date: November 19, 2014

Re: Public Meeting on the Clean Air Act Section 608 and Substitutes for Ozone Depleting 

Substances (EPA Contract Number EP-W-10-031 Task Order 404, Task 2)

On November 12, 2014, EPA held a public meeting on Clean Air Act (CAA) Section 608 and substitutes 

for ozone-depleting substances (ODS) at the Twelve & K Hotel in Washington, DC. The goal of the 

meeting was to hear suggestions from members of the public on potential ways to reduce emissions of 

both high global warming potential (GWP) substitute refrigerants, including hydrofluorocarbons (HFCs), 

as well as ODS refrigerants, during the service, maintenance, repair and disposal of air conditioning and 

refrigeration equipment. EPA also sought feedback on which components of the existing CAA Section 

608 refrigerant management program work well and which components could be improved. 

Of the 54 stakeholders who attended the meeting, 19 individuals shared a public comment. The purpose 

of this memorandum is to summarize the responses and suggestions provided by public commenters.

Specifically, this memorandum is organized as follows: 

 Section 1 provides a list of meeting attendees by organization; and

 Section 2 provides a summary of comments by commenter.

 Attachment 1 is the concept note provided by EPA prior to the meeting
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1. Public	Meeting	Attendees

As shown in Table 1 below, a total of 54 stakeholders attended the meeting from 48 unique organizations. Nineteen 

members of the public provided comment at the public hearing. 

Table 1. List of Public Meeting Attendees by Organization

Count Name Organization Public Comment

1 Charles McCrudden Air Conditioning Contractors of America (ACCA) 

2 Karim Amrane Air Conditioning, Heating, and Refrigeration Institute (AHRI)

3 Kevin Fay Alliance for Responsible Atmospheric Policy



4 Stephen Van Maren

5 Bill Anaya Alston & Bird, LLP

6 Patti Conlan Arkema, Inc.

7 Rob McArver Association of Home Appliance Manufacturers (AHAM)

8 Aaron Lowe Autocare Association

9 Matthew Thiel Bacharach, Inc.

10 Kenneth Welter Baltic Trail Engineering

11 Manfed Staebler BSH Home Appliances Corporation 

12 Ken Ponder Choice Refrigerants 

13 David Calabrese Daikin U.S. Corporation

14 Mark Menzer Danfoss, Inc. 15 Robert Wilkins 

16 Julian de Bullet DeBullet Consulting for Carrier/ McQuay International/FAFCO Thermal Storage Systems

17 Jennifer Thran Department of the Navy

18 Michael Parr DuPont 

19 Brad Kivlan Dynatemp International

20 Ted Gartland E. Gartland & Associates, LLC. 

21 Alan Thornton Environmental Investigation Agency (EIA)



22 Lowell Chandler

23 Jeff Cohen EOS Climate

24 Jerry Weiss ESCO Institute 

25 Stephanie Barnes Food Marketing Institute (FMI) 

26 Lowell Randel Gold Cold Chain Alliance/ IIAR

27 Bill Rietz

Heather Podesta and Partners on behalf of Hudson 

Technologies

28 Jonathan Melchi

Heating, Air conditioning & Refrigeration Distributors 

International (HARDI)



29 Dave Stirpe Honeywell 

30 Damon Stafford

31 Mark Anderson HVAC Investigators (HVACi)

32 Matt Livingston

33 Matt Tieken ICOR International

34 Kevin Washington Illinois Tool Works (ITW)

35 David Wagger Institute of Scrap Recycling Industries, Inc. (ISRI) 
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36 David Rule International Institute of Ammonia Refrigeration (IIAR)

37 William McQuade Johnson Controls

38 Keilly Witman KW Refrigerant Management Strategy 

Count Name Organization Public Comment

39 John Hurst Lennox International

40 Douglas Greenhaus National Automobile Dealers Association (NADA) 

41 Mary Anne Murray National Refrigerants

42 Ben Longstreth Natural Resources Defense Council (NRDC) 

43 Collin Weber Navigant

44 Peter Coll Neutronics



45 Zachary Ziegler

46 Peter Williams New Era Group, Inc. 

47 John Lanier North American Technician Excellence (NATE)

48 Julie Brinster Refrigeration Environmental Protection Association (REPA)

49 Harlan Krepcik Refrigeration Service Engineers Society

50 JP Dalton REPA

51 Darrell Garrison Smart ITI

52 Keith A. Oliver The Kroger Co.

53 Rodrigo Jara UA Training 

54 Nathan Mouw Whirlpool

2. Summary	of	Comments

Below is a summary of the 23 comments and suggestions provided by 19 individual members of public.

Michael Parr, DuPont: Mr. Parr asked about the timing of changing federal preferred purchasing/acquisition regulations. 

EPA responded that they’re moving quickly to provide technical support and tools for Federal agencies. 

David Wagger, ISRI: Mr. Wagger asked whether EPA envisions regulations for GSA related to the recycling center. EPA 

responded that the Office of Federal Environmental Executive would be able to speak to the GSA recycling regulations, 

since EPA was not involved.

Kevin Fay, Alliance for Responsible Atmospheric Policy (the Alliance):

1 With HFCs receiving significant consideration 

under the United Nations Framework Convention on Climate Change and potentially under the Montreal Protocol, it is 

critical to have a comprehensive approach to address their potential climate change contribution, including HFCs already 

in use in the installed equipment base. The Alliance is aware that the majority of refrigerant emissions occur during the 

service, maintenance, repair, and disposal of units. Moreover, that equipment operates most efficiently when properly 

charged and maintained, minimizing energy consumption and related greenhouse gas (GHG) emissions. In January 2014, 

the Alliance submitted a petition for regulatory backing the phase down of HFCs. To this end, the Alliance encourages 

the EPA to move expeditiously to extend the CAA Section 608 regulations to include HFCs, since the regulations have 

already been effective at limiting ODS emissions. In response to the questions EPA posed on the 608 policy changes, the 

Alliance feels that, while it’s important to consider these issues long-term, the Alliance would prefer that EPA move as 

soon as possible on the parts of the proposal that will finalize quickly rather than waiting until all details of 

 

1 Written comment.
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implementation are settled. Once the rule is settled, the Alliance offered to partner in working to resolve any remaining 

details. 

Jonathan Melchi, HARDI:

2 HARDI applauds EPA for holding a public meeting and for exploring the extension of 608 

requirements to cover HFCs. HARDI also appreciates EPA and the Department of Justice (DOJ) for taking strong action 

against Costco and Safeway for violating the CAA and appreciates the outreach by EPA’s Stratospheric Protection 

Division to make public aware of the CAA violations. With regards to Section 608, the regulations should be extended to 

HFCs as well as other substitutes for class I and II. As a company with a large membership base of small businesses, 

HARDI believes that this extension would impose little to no additional burden on small businesses. To answer some of 

the questions posed by EPA, some components of Section 608 are more relevant to HFCs than others; that it would be 

reasonable to apply 608 leak rates to HFCs; that it would it be reasonable to apply the existing standards for recovery 

equipment and reclaimed ODS refrigerants to HFCs; and that HARDI does not have suggestions to improve Section 608’s 

technical certification program but would be open to future discussions. 

Ben Longstreth, NRDC: It is a critically important to reduce greenhouse gas (GHG) emissions, including emissions from 

HFCs. NRDC supports extending the Section 608 regulation to HFCs and believes that EPA has the necessary authority 

under the CAA. EPA should consider tightening 608 rules to ensure leak rates are as low as possible. Currently, leak rates 

are too high. EPA’s suggestions for leak rate repair and recertification requirements make sense; however EPA should

make sure technician certifications are up to date. NRDC encourages EPA to consider other ways to incentivize recycling. 

It makes a big difference if you can sell recycled products. Another related issue NRDC mentioned, which the 

organization included in its comments to the SNAP status change rule, is the idea that EPA should reclassify motor 

vehicle air conditioning (MVAC) as an emission control device.3 HFCs are considered a GHG pollutant under Section 202

of the CAA, and therefore, MVAC systems should prevent leaks and associated emissions. 

Keilly Witman, KW Refrigerant Management Strategy: Ms. Witman clarifies that her comments apply to the 

supermarket sector only. Supermarkets use approximately 4,000 pounds of refrigerant per store and leak approximately 

25%, which is significant. Currently, Section 608 encompasses an array of refrigeration sectors, including commercial and 

domestic refrigeration. Using one set of standards to regulate such a variety of sectors is not logical. Therefore, 

expanding Section 608 to HFCs is just expanding ineffective regulation to cover more substances. If EPA is planning to 

modify Section 608, EPA should consider shifting the emphasis from leak repair to leak prevention. The technician 

certification has also been out of date for decades, and many technicians are often certified in-house. EPA is the least 

qualified organization to determine certification and should outsource to people who know more about leak tightness. 

With regards to recordkeeping, supermarkets are already keeping records for leak repair of all substances, including ODS 

and ODS substitutes. Supermarkets should be keeping records on a corporate level, as opposed to a store-by-store basis. 

EPA should focus on leak rates that are higher than 15%. Section 608 is not effectively enforced and has no teeth. Ms. 

Witman questions why we would spend time talking about a rule that is not enforced.

Alan Thornton, EIA: EIA strongly supports extending Section 608 to cover HFCs and agrees that EPA has the authority to 

do so. HFCs have potent GWPs and emissions are increasing. Regulations will encourage the transition to alternatives 

that align with President Obama’s Climate Action Plan. Alternatives are currently available and are both better for the 

environment and reduce energy consumption. For example, more than 300 CO2 transcritical systems were produced this 

year. The extension is logical and necessary since air-conditioners and refrigerators currently have banks of HFCs, which 

 

2 Written comment.

3

ICF can provide this comment upon request.
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represent a significant unseen contribution to climate change. Addressing banks by controlling ODS production used to 

work, but now applications bank HFCs for years and these banks are increasing. These HFC banks could become a huge 

problem. Section 608 could help regulate the current HFC banks and prevent emissions from contributing to climate 

change through leak prevention and repair and proper recovery or disposal. EPA should consider financial incentives to 

destroy banks. The cost of end-of-life disposal will become a financial incentive to transition to low-GWP alternatives 

and to retrofit existing equipment, which are already on the market. 

Rodrigo Jara, UA Training: Mr. Jara supports the extension of Section 608 to cover HFCs, though believes that, from a 

technician’s point of view, the regulations need to be cleaned up. Some regulations are useless. Specifically, the 

requirement to register recovery equipment was once needed but is now obsolete. With regards to leak rates, EPA 

needs to better communicate the value of leak repair and technical expertise to the consumer. Currently, the companies 

and small businesses with technician training are the main drivers promoting the safe and correct use of refrigerants. To 

this end, EPA should support this effort and educate customers on the importance of safe disposal and leak repairs. EPA 

should inform the consumer so that the consumer can demand environmental responsibility from service technicians. 

Further, there should be a shift in the emphasis of Section 608 regulation from recordkeeping to managing disposal of 

refrigerated systems. EPA has the ability to value not releasing refrigerants into the atmosphere. 

Jerry Weiss, ESCO Institute: If we get rid of recordkeeping, how do we enforce the regulations or know how much our 

equipment is leaking? While recordkeeping should remain mandatory, EPA should evaluate what should be recorded 

and standardized across the industry. For example, Section 608 currently requires leak rate records for equipment as 

opposed to the overall refrigeration system of an establishment. For a hotel, it makes more sense to require records for 

leaks in the overall air-conditioning system rather than individual packaged terminal air-conditioning units in hotel 

rooms. Minor leaks from individual units could seem much more significant if they are quantified across the entire hotel. 

Leak rates are currently high, which also means the equipment is consuming more energy due to the reduced efficiency. 

Incorrect charge wears out the system and increases the need for servicing. To address this, EPA should support 

consumer education. While Mr. Weiss has no objection to extending Section 608 to cover HFCs, the change in regulation 

could be problematic with the number of people certified already. One way to address this would be for EPA to only 

require a supplemental exam for technicians already certified in Section 608, which could be an online, open-book exam 

similar to the Section 609 exam. 

Charles McCrudden, ACCA: ACCA generally supports the Alliance petition and extension of Section 608 regulations to

HFCs; however, ACCA believes that the technician exams need updating. EPA should consider a recertification process to 

allow for contractors and technicians to stay up-to-date. With regards to enforcement, consistent and public 

enforcement is critical for consumer and contractor awareness. There is not enough enforcement for the current 

regulation, particularly in the residential sector. The playing field is tipped towards non-compliant technicians, since they 

can make more money by simply venting. ACCA requests more regulation and believes without enforcement, there is no 

point in having the program.

Ken Ponder, Choice Refrigerants: Choice Refrigerants supports extending Section 608 but believes that the lack of 

enforcement for recordkeeping and leak rates make the regulation ineffective. Although the regulations have good 

intentions, they need more teeth. With technicians typically returning refrigerant into wholesale, and with significantly 

less refrigerant being reclaimed, the difference is most likely vented. Mr. Ponder also voiced confusion about the lack of 

regulations against venting HFCs, to which EPA responded that venting HFCs is prohibited under the current regulations. 
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David Wagger, ISRI: In subpart B of Section 609, the regulations apply to ODS refrigerants and substitutes. Mr. Wagger 

questions why this language is missing from Section 608 and why there are differences between Sections 608 and 609 

for MVACs. EPA responded agreeing that Section 609 has very clear requirements that apply to ODS and substitutes, and 

that Section 608 does not include the same language. EPA is considering whether Section 608 should be revised to be 

more similar to Section 609. 

Rodrigo Jara, UA Training: Mr. Jara notes that, based on his understanding, the Section 608 regulations have never been 

updated. Mr. Jara states that EPA needs to change the goal of the regulations to address global warming, and in 

particular, the climate impacts of HFCs. 

Michael Parr, DuPont: DuPont believes that the Section 608 regulations lay a good foundation, but need to be extended 

to HFCs. Industry is getting more complex, thus there is also the challenge of enforcement and education. DuPont 

believes that Section 608 regulations should apply to all refrigerants and alternatives uniformly, including the venting 

prohibition and safe disposal requirements. Individual technicians should be required to certify that the job was done 

properly. Requiring varying technician certifications places undue burden on the technicians. 

Manfed Staebler, BSH Home Appliances Corporation: Recovery of no GWP, no ODP R-600a doesn’t make sense. You 

have to drive, transport and do detriment on the environment to recover it. Give a clear signal to the tech by equipment 

(i.e. label, red tubes on R-600) letting them know what they can vent.

Robert Wilkins, Danfoss, Inc.: Mr. Wilkins believes that EPA needs to give technicians clearer instruction on what can 

and cannot be vented. Since low-GWP alternatives (e.g., hydrocarbons) pose virtually no harm to the environment, a

venting restriction on hydrocarbons would be unreasonable and would place an undue burden on manufacturers 

looking to sell low-GWP alternatives. Other countries currently do not have venting requirements for hydrocarbons and 

equipment for hydrocarbon refrigerant recovery is not available. Treating all refrigerants the same is ill-conceived. It 

would add cost and would not make sense for some refrigerants. Thus, EPA should tailor regulations as appropriate to 

each refrigerant.

Dave Stirpe, Honeywell: Honeywell believes that compounds that can cause environmental harm should be prohibited 

from being vented. Extending Section 608 to HFCs would demonstrate leadership.

Jerry Weiss, ESCO Institute: To help enforce Section 608, Mr. Weiss suggested to EPA that the Agency could use a 

central, national database to keep track of refrigerant licenses. Through this database, EPA could suspend or revoke 

licenses for regulatory violations. 

Peter Williams, New Era Group, Inc.: New Era Group supports the extension of Section 608 but would recommend 

increasing enforcement of the regulation. Recordkeeping should be required for the reclamation industry. Also, facilities 

claiming to be “separation facilities” are, in reality, venting refrigerant, and to discourage venting violations, EPA needs 

to convey the perception of enforcement. Separation facilities are currently flying under the enforcement radar. Leak 

rates and leak repair should be considered for all systems under the regulation, as opposed to just systems with 50 

pounds of refrigerant or more. Think about how many systems contain less than 50 pounds of refrigerant that are 

leaking. In terms of measuring pressure, taking the equipment down to zero gauge is not enough to mitigate 

environmental impacts. Therefore, the focus of the regulation should be on getting the substance completely out of 

units and the regulation should be supported by proper and visible enforcement. Technicians do not have to worry, so 

no one is complying. EPA should reevaluate the regulations and increase enforcement.
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Ted Gartland, E. Gartland & Associates, LLC.: Mr. Gartland notes that recordkeeping is essential to the regulation, since 

it gives companies an understanding of how much refrigerant they are using and how much money they are saving. A

15% leak rate would be very challenging to meet, as opposed to the industry rate of about 35%. EPA should incorporate 

a concept similar to California requirements where refrigerant additions require documentation that the system was 

fixed down to zero. 

Douglas Greenhaus, NADA: NADA does not feel that low-GWP alternatives should be regulated under most provisions, 

including Sections 608 and 609. If EPA were to have less regulation on these low-GWP alternatives, the agency could 

send a positive message to the industry. Since these substitutes are beneficial to the environment relative to ODS and 

HFCs, they should have less burdensome regulations. The cost of substitutes creates enough incentive to recover and 

recycle the substances without regulation.

Peter Coll, Neutronics: Neutronics noted that the subject of venting low-GWP alternatives, like HFO 1234yf, should not 

be oversimplified to the issues of GWP and ODP. There is currently no way to ensure that only the low-GWP substances 

are vented without venting other substances (e.g., used oil). Neutronics also questioned how well technicians are

educated on venting, and given this scrutiny, the company would support blanket prohibitions on venting. Neutronics 

also corrected an earlier comment that there is equipment available to recover hydrocarbons. Similar to Section 609, 

Section 608 should apply similar specifications for amount of refrigerant of HFO-1234yf that can be left in a vehicle to 

minimize leakage and unintentional venting. To this end, Neutronics recommends somehow streamlining Section 609 

into 608, since MVAC alternatives will probably be used in other equipment in the future. There should not be different 

rules for different sectors. 

Stephanie Barnes, FMI: FMI supports the points made by Keilly Witman. FMI believes that a voluntary program could 

help EPA focus their resources.

EPA closed the meeting by stating that the agency would keep conversations moving forward on a more individual basis. 
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Attachment 1

Concept Note: Public Meeting on Clean Air Act Section 608 and 

Substitutes for Ozone-Depleting Substances

Twelve & K Hotel, 1201 K Street, NW, Washington, DC

November 12, 2014, 9 a.m. ET

Background: Climate Action Plan and Hydrofluorocarbons

In June 2013, President Obama announced the Climate Action Plan (CAP), including a broad set of initial steps 

designed to slow the effects of climate change. Among the many actions called for, the President directed the 

United States to lead through both international diplomacy and domestic action to address hydrofluorocarbons 

(HFCs)4. In the United States, emissions of HFCs are expected to double from current levels of 1.5 percent of 

total annual greenhouse gas emissions to 3 percent by 2020 and nearly triple by 2030.5 HFCs are rapidly

accumulating in the atmosphere. For example, the atmospheric concentration of HFC-134a, the most abundant 

HFC, has increased by about 10 percent per year from 2006 to 2012, and the concentrations of HFC-143a and 

HFC-125 have risen over 13 percent and 16 percent per year from 2007-2011, respectively.

6, 7

Current EPA Efforts to Reduce HFC Emissions

Since the announcement of the Climate Action Plan, EPA has taken a number of steps designed to curb 

emissions of HFCs. Specifically, and consistent with the direction announced in the President’s CAP, EPA has 

used its authority through the Significant New Alternatives Policy (SNAP) Program to encourage private sector 

investment in climate-friendly chemicals for use in specific end uses. EPA has also proposed the prohibition of 

certain uses of the most climate-damaging chemicals. As part of the CAP, the President directed the Federal 

government to lead by example in reducing emissions of HFCs through the purchase of lower-global warming 

potential (GWP) alternatives to HFCs whenever feasible and transition over time to equipment that uses safer 

and more sustainable alternatives. The change to federal procurement practices is led by the Office of the 

Federal Environmental Executive (OFEE), and EPA has been working with OFEE and other parts of the 

Federal government to change existing procurement regulations, improve agencies’ annual GHG reporting of 

HFCs and practices to reduce emissions, and provide current information on low-GWP alternatives listed by

SNAP. These activities are still underway. 

Additional Efforts to Reduce HFC Emissions and Public Meeting

To highlight the broad scope of efforts to address HFCs, the White House announced new private sector 

commitments and executive actions to reduce HFC emissions on September 16, 2014. During the related 

roundtable discussion, participants discussed – and EPA acknowledged – that refrigerant management is an 

important way to reduce climate-damaging emissions from equipment used for air-conditioning and 

refrigeration, and EPA committed to further engage with stakeholders on this issue.

 

4

HFCs were introduced as alternatives to ozone-depleting substances and are commonly used as refrigerants, foam-blowing agents, solvents, and 

aerosol propellants. They do not significantly deplete the stratospheric ozone layer, but are greenhouse gases that contribute to climate change.

Some HFCs have a global warming potential thousands of times greater than carbon dioxide.

5

http://www.whitehouse.gov/share/climate-action-plan

6 Montzka, S.A.: HFCs in the Atmosphere: Concentrations, Emissions and Impacts, ASHRAE/NIST Conference 2012

7

NOAA data at ftp://ftp.cmdl.noaa.gov/hats/hfcs/
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As a next step, the agency is holding a public meeting on November 12, 2014 to discuss opportunities to 

achieve further HFC emissions reductions through enhanced efforts in the area of refrigerant management. The 

primary goal of the meeting is to hear individual suggestions from members of the public on potential ways to 

reduce emissions of both high-GWP substitute refrigerants, including HFCs, as well as ozone-depleting 

refrigerants, during the service, maintenance, repair and disposal of air conditioning and refrigeration 

equipment. 

As noted at the September 16 event, the Alliance for Responsible Atmospheric Policy has petitioned EPA to 

create consistent refrigerant management regulations by applying the same rules that already exist for ozonedepleting refrigerants to HFCs.8 Accordingly, at the public meeting, EPA will seek individual ideas and 

feedback from members of the public on the possible expansion of existing refrigerant management rules to 

HFCs. We will seek feedback on which components of the existing Clean Air Act Section 608 refrigerant 

management program work well, and which components could be improved. We will also seek input on 

whether existing regulatory requirements are appropriate for HFCs. 

To help facilitate a more informed discussion, background information on the existing refrigerant management 

program is available online at www.epa.gov/ozone/title6/608/. In addition, we have developed a list of 

questions that we are considering as we assess potential actions to reduce emissions of ozone-depleting 

refrigerants, HFCs, and other substitutes for ozone-depleting refrigerants:

 Should EPA extend the Section 608 regulations to HFCs?

 Are some components of Section 608 more relevant to HFCs than others?

 Should EPA consider including other climate-damaging substitutes within any Section 608 extension 

(e.g., PFCs)? For all components or only some components?

 Would it be reasonable to apply the 608 leak rates to HFCs?

 Are there other ways to incentivize lower leak rates?

 Would it be reasonable to apply the existing standards for recovery equipment and reclaimed ozonedepleting refrigerants to HFCs?

 How can the Section 608 technician certification program be improved?

 Is there a better way to ensure refrigerant is recovered from small appliances at end-of-life?

 Should EPA consider using this effort as an opportunity to simplify/improve/update the Section 608 

rules? If so, what components might be simplified/improved/updated? 

Participation 

EPA recognizes that a diverse set of stakeholders could be affected by any change to the Section 608 

regulations. We appreciate the importance of stakeholder views, and a primary purpose of this concept note and 

meeting is to share our current approach and to enable stakeholders to provide focused input on the Section 608 

refrigerant management program. We encourage anyone who is interested to provide individual advice and 

suggestions during the meeting. Toward that end, we encourage stakeholders to share this note with others who 

 

8

A copy of the petition is available at www2.epa.gov/sites/production/files/2014-05/documents/alliance-petition-31jan2014-v2-2.pdf
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may be interested in this opportunity. A copy of this concept note will be available at 

www.epa.gov/ozone/title6/608/ and www.regulations.gov (search for EPA-HQ-OAR-2014-0786).

We ask that you please RSVP to Altan Gabbay at gabbay.altan@epa.gov by November 5, 2014, if you plan on 

attending the meeting. The meeting will be held at 9 a.m. ET on November 12, 2014 at Twelve & K Hotel, 1201 

K Street, NW, Washington, DC 20005.