Alliance of Automobile Manufacturers 

Testimony on the Proposed Rulemaking to Change Listing Status for Certain 

Substitutes Under the Significant New Alternatives· Policy Program 

August 27,2014 

Good morning. My name is Julie Becker, and I am the Vice President of Environmental Affairs 

for the Alliance of Automobile Manufacturers (Alliance), a trade association of twelve car and 

light truck manufacturers comprised of BMW Group, Chrysler Group LLC, Ford Motor 

Company, General Motors Company, Jaguar Land Rover, Mazda, Mercedes-Benz USA, 

Mitsubishi Motors, Porsche Cars, Toyota, Volkswagen Group and Volvo Cars. Together, 

Alliance members account for 75% of the new vehicles sold in the U.S. each year. 

Automakers supported the development of the groundbreaking Single National Program 

governing light-duty vehicle greenhouse gas emissions and fuel economy. Our industry was the 

first to commit to significant greenhouse gas reductions, and has invested billions to achieve the 

goals of the Single National Program. 

One measure of this effort is the introduction of new models achieving higher fuel economy. In 

2006, 69 models of light-duty vehicles achieved 30 MPG or better highway fuel economy. 

Today- just eight years later- consumers now can choose from 450 vehicles that offer this level 

of fuel economy, an increase of over 552%. In addition, consumers can choose from diverse 

technologies to improve their fuel economy, including 51 hybrids, 35 clean diesels, 7 plug-in 

hybrids and 11 battery electric vehicles, according to www.fueleconomy.gov. And the latest 

reports demonstrate that fuel economy is improving for all types of light-duty vehicles. 

As part of their commitment to improve fuel economy and reduce greenhouse gases, automakers 

support transitioning as quickly as possible to refrigerants with a lower GWP. To do this, current 

models will need to be redesigned and a reliable supply of the new refrigerants established. 

In addition to investing heavily into research on alternative refrigerants, automakers have worked 

to improve the efficiency of refrigeration systems to prevent leakage. EPA projected that 

automakers will achieve a net-zero greenhouse gas impact from leakage by 2021. 1 And reports 

on refrigerant system performance, such as the Minnesota refrigerant leakage reports, 

demonstrate that leakage rates of refrigerants are being reduced. By reducing leakage, we reduce 

the emissions oftoday's refrigerants and save consumers the cost of expensive refills. Going 

forward - as EPA notes in the NPRM - these improvements will reduce the motivation to 

improperly refill with HFC-134a an A/C system designed for HF0-1234yf. 

The key question today is not whether to transition to low-GWP refrigerants; it's when the SNAP 

rule should take effect and how it should be structured. As to when, we would propose the rule 

take effect at the end of2025. Simply put, doing so would preserve the integrity of the Single 

National Program for GHG emissions and fuel economy without threatening the program's 

greenhouse gas reductions. 

1 77 Fed.Reg. 62624, 62806 (Oct. 15, 20 12) ("EPA believes that a total phase-in of alternative refrigerants is likely to begin in 

the near future and be completed by no later than MY 2021...") 
An integral part of that program is the earning of credits for transitioning to the new refrigerants, 

and we appreciate that EPA is not proposing to change those credits. However, a second key 

element of the Single National Program is that each manufacturer be able to determine, modelby-model, when to transition to low-GWP refrigerants. There is no "drop in" solution here; the 

transition to low-GWP refrigerants will only occur as models undergo major redesign or new 

models are introduced. This is why, when it set the GHG standards, EPA predicted that 

manufacturers would transition to low-GWP refrigerants by 2021 but allowed any manufacturer 

that fails to do so to make up the difference by finding other ways to achieve the equal GHG 

reductions. EPA now proposes to take away that valuable flexibility. Given that there is no 

measurable environmental impact at stake, we think that the best way to preserve the integrity of 

the Single National Program is to allow the use of HFC 134a until the end of 2025. 

Our second major concern is how exports are addressed. Auto manufacturing is a cornerstone of 

the U.S. economy, supporting eight million jobs across the country. Exports - a bright spot in the 

U.S. economy- represent about one-fourth of U.S. auto manufacturing. That's two million jobs! 

U.S. assembly plants export to over 130 countries around the world/ including many that have 

not begun creating the infrastructure for servicing and refilling mobile air conditioning systems 

with the new refrigerants, let alone updating their regulations governing transport and handling 

of new refrigerants. If the U.S. is any example, this process could take up to a decade. 

We understand that EPA is reluctant to make an export exception, but this is an exceptional 

situation. For appliances like refrigerators, manufacturers could unilaterally produce and export 

products that met all the EPA Use Conditions for safe operation, without the need for significant 

supporting actions by foreign governments and extensive new service support programs by 

independent overseas companies and industries. In this instance, however, satisfying the 

necessary Use Conditions in export markets cannot be unilaterally achieved by the automobile 

manufacturers. Automobiles are different than other appliances considered in past SNAP 

decisions on exports, since automobile air conditioners have much higher lifetime service and 

maintenance needs. 

Absent changes in the SNAP rule, both the lack of infrastructure and the fact that alternative 

refrigerants may not be approved for use in some nations would effectively prevent 

manufacturers in the US. from exporting vehicles to some markets. 

The Alliance therefore recommends that EPA adopt provisions consistent with what the EU has 

done, that limit the SNAP rule to vehicles intended for the U.S. market. 

In conclusion, we urge EPA to adopt the following in the final rule: 

• The change of listing status should take effect no earlier the end of 2025. 

• The change oflisting status should apply to vehicles intended for the U.S. market. 

• EPA should state clearly and unequivocally in the Final Rule that EPA is committed to 

continuing the A/C credits through MY 2025 and beyond. 

Thank you for this opportunity to testify. Of course, we also plan to provide in-depth written 

comments on a variety of issues raised by the NPRM. 

2 http://www.autoalliance.org/index.cfm?objectid=44A096CO-B3F5-ll El-A8A9000C296BA 163