Statement on behalf of the Natural Resources Defense Council (NRDC) and the Institute for Governance & Sustainable Development (IGSD)

Thank you for the opportunity to be here today. My name is Emily Davis, and I'm here on behalf of the Natural Resources Defense Council and the Institute for Governance and Sustainable Development. I'd like to thank EPA for the opportunity to comment on its proposal to change the listing status of certain substitutes under the Significant New Alternatives Policy and congratulate them on their proposal. EPA's SNAP program has a proud history of collaboration among stakeholders, and NRDC and IGSD are proud of the relationships we have built in the process of implementing past transitions. We are eager to work with industry and other stakeholders as these SNAP rules are finalized and implemented.
HFCs, the chemicals at issue in today's SNAP proposal, were added to the SNAP list because they were an improvernent on the chemicals they replaced, but they are themselves extremely potent chemicals with a very high global warming potential, thousands of times greater than that of carbon dioxide. This means that every ton of HFCs has an impact on the climate many times worse than a ton of carbon dioxide. We also know that HFC emissions are forecasted to almost triple by 2030 if we don't act to reduce their use.
The good news is that safer chemicals exist, and 25 years of experience with the Montreal Protocol and Clean Air Act has shown us that transitioning to safer chemicals works smoothly. In fact, we know more now about safer alternative chemicals to HFCs than we knew at a comparable moment for alternatives to CFCs. When EPA proposed phasing down CFCs and other ozone-depleting substances (ODSs), there were dire warnings that the industry could not survive without these chemicals, but in fact the phase-out of CFCs was successful and thewarnings did not come true. Similar warnings may be repeated now, biut the history of success

and the evidence in support of safer alternatives shows we will be able to succeed in moving away from HFCs as proposed.
EPA's proposed rule is important for several reasons. First and foremost, it is critical because of the reductions in HFC use that will be achieved in the sectors at issue - 31 to 42 million metric tons of carbon dioxide equivalent in 2020, by EPA's estimates. Second, the rule is important because it provides a needed signal to industry that, as safer alternatives are brought to market, dangerous substitutes with high global warming potentials will be removed from the SNAP list. Third, the rule is important because it puts U.S. industry in a leadership position as the global market moves away from high GWP substances.
From an environmental standpoint, if EPA were only taking into account risks to human health and the environment, the Agency would act to ban HFCs immediately. We know that these chemicals are extremely potent agents of climate change, and we know that continuing to use them only exacerbates the climate problem. So in that sense, the very idea of the SNAP program takes into account the technological, feasibility, and business concerns of the regulated community in the very structure of the program itself — by removing harmful chemicals only as safer alternatives come to the market.
However, NRDC and IGSD believe that for some sectors, transition dates can and should be accelerated from the dates in the proposed rule. For example, we believe that the motor vehicle air conditioning sector can transition by 2017. In this sector, the industry already has many vehicle models that use low-GWP alternatives to HFCs, and manufacturers that have signaled that they will develop additional models in the next few years. Adopting a 2017 datealso makes sense because it aligns the U.S. timeline with the European auto market, which is

required to transition away from HFCs completely by 2017, five years earlier than the date EPA has proposed here. We believe that deadlines should be set based on the leaders in the industry, rather than laggards, and setting these accelerated timelines in certain sectors would do just that.
Though we believe that automakers should be able to meet an earlier transition date, NRDC and IGSD are interested in hearing the concerns of automakers and other parties who do not believe they can meet a 2017 deadline, and we would be glad to work with such parties to discuss how such concerns can be addressed.
Securing HFC reductions as quickly as possible is critical to achieving the goals of the President's Climate Action Plan. In addition to accelerating the dates in the proposed rule, we urge EPA to quickly start work on the next SNAP rule. Further progress to replace higher GWP substances can be made in these and other sectors based on the alternatives currently on the market and those that are being developed. Further, such action is critical as a means of reducing domestic emissions of greenhouse gases, making the United States an industry leader in safer chemicals, and paving the way for international action through the Montreal Protocol. Thank
you.