# SNAP: Change of Status Rule Overview/Status Briefing

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# Scope of Briefing

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# Proposed Changes of Status  

# Comments Received  

# Final Rule by Sector

# What Was Proposed (August 2014)

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Change of Status Rule: END Use/ Proposed Date Proposed Change Aerosols January 2016  HFC - 134a unacceptable except for some technical and medical aerosols including MDIs  HFC - 125, - 227ea (except MDIs) unacceptable Motor vehicle A/C Model year 2021  HFC - 134a unacceptable Foams January 2017  HFC - 134a and blends thereof unacceptable  HFC - 245fa and HFC - 365mfc and HFC blends unacceptable in all foam blowing end - uses except for spray foam Supermarket systems: remote condensing units, new (& retrofits from ODS) January 2016  Certain HFCs unacceptable: HFC - 227ea, R -404A, R -407B, R -421B, R -422A, R - 422C, R -422D, R -428A, R -434A, and R - 507A Stand-alone retail food refrigeration, vending machines : new January 2016  Certain HFCs unacceptable: HFC - 134a, R -404A, R -407A, R -407C, R - 507A, other blends Stand-alone retail food refrigeration, vending machines: retrofits from ODS January 2016  Certain HFCs unacceptable: R -404A and R - 507A

# Comments Overview

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## The total number of comments received over 7,700:  

### Form letter #1: 7,022 copies supporting proposed rule, asking EPA to cover additional sectors and implement more rigorous timelines  

### Form letter #2: 436 letters asking EPA to delay timing for floatation foam  

### Form letter #3: 93 letters asking for more flexibility for floatation foam  

### 200+ individual letters 

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## Where additional time was requested, often cited reasons were:  

### Technical challenges with converting manufacturing facilities without additional time, particularly for flammables  

### Awaiting additional technologies or suppliers that will maintain or improve energy efficiency  

### Prefer better alignment of timing with changes to DOE requirements (e.g., 2020 for appliance foams)  

### Building and fire codes may need to be revised

# Changes Between Proposal and Final: Aerosols

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# Commenters concerns:  

## A few applications asked for no change or additional time  

### Some aerosols require testing and certification (e.g., insecticides) 

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## Do not limit MDIs to the treatment of Asthma and COPD  

## Some concerns with capability and/or use of flammables  

# Final rule:  

## July 1, 2016 for most aerosols (e.g., consumer aerosols)  

### Approximately one year from issuing a final rule 

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## 2018: change of status date for uses requiring federal program approval (e.g., FIFRA), functional testing of smoke detectors  

## Broadened medical uses to all MDIs approved by FDA  

## Kept proposed uses where HFC - 134a is acceptable, subject to conditions  

### Added uses on energized circuits, smoke detector sensitivity testing, refrigerant flushes

# Changes Between Proposal and Final: Foams

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# Commenters’ concerns:  

### Retain HFC - 134a for low -pressure spray foam  

### Sub - divide spray foam  

### Need additional time for certain foam types including XPS, appliance, flotation foam  

### Within a few years there will be more suppliers  

### Prefer consistency with DOE timing  

### Newer alternatives coming to market have improved energy efficiency  

### In a few cases indefinite extensions were requested 

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# Final Rule:  

### Maintain 2017: flexible foams, phenolic, polystyrene extruded sheet, integral skin, rigid PU and polyisocyanuarate laminated boardstock  

### 2019: rigid PU slabstock  

### 2020: rigid PU for appliances and floatation, commercial refrigeration, sandwich panels; polyolefin; and XPS boardstock and billet  

### No final action on spray foam in this rule

# Changes Between Proposal and Final: MVAC

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# Commenters’ concerns:  

### Timing: too late, too soon  

### OEMs commented on ‘Run out’ models & exports with HFC - 134a  

### OEMs requested clarity on relationship to the LD GHG rule  

### Some chemical producers concerned with future markets  

### Some supported earlier dates given the uptake of climate - friendly alternatives others requested later dates (or no date) given their HFC - 134a market 

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# Final rule:  

### MY 2021; However, includes a “narrowed use limits” exception until 2025 for HFC 134a MVACs in vehicles destined for countries lacking infrastructure to service MVACs using low- GWP refrigerants

# Changes Between Proposal and Final: Supermarkets and Condensing Units

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# Commenters’ concerns:  

### Timing  

### Supermarket and trade association for supermarkets supported proposal  

### Equipment manufacturers asked for more time to further develop complete line of equipment, allow for already planned new stores (up to 3 years), train contractors, prepare literature  

### No convenience stores commented  

### One system manufacturer identified technical issue with their lower- GWP equipment  

### Questions on “new” and “retrofit” in supermarkets  

### Requests for consistency with DOE timing (where applicable) 

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# Final rule:  

### 2016: retrofit supermarket and condensing unit  

### 2017: new supermarket store construction changing status for same list of refrigerants  

### 2018: new remote condensing units (e.g., cold -rooms)  

### Relevant DOE EE rules take effect 2017

# Changes Between Proposal and Final: Stand -Alones and Vending Machines

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## Commenters’ concerns:  

### More time needed particularly if only available options are flammable  

### Concerns for larger- sized equipment (more refrigerant required) and for low - temperature equipment (limited choice)  

### More time for design & test models, increase availability of alternative refrigerants and equipment components (e.g., CO 2 

### and HFO compressors) 

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## Final rule:  

### New stand - alone equipment (includes reach- in coolers and some walk- in units):  2019: HFC - 134a and GWP HFC blends - smaller sized (e.g., one door reach- in cooler; capacity distinction based on manufacturer’s comment)  2020: similar refrigerants

– larger sized and low - temperature equipment  

### New vending machines:  2018: HFC - 134a and certain high- GWP HFC blends in new equipment  

### Retrofits:  2016: R -404A and R - 507A

# Other Topics

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### SNAP criteria  

### GWPs  

### Imports and exports  

### Additional status changes EPA should consider  

## Interactions with other rules and international developments  

### DOE  

### HCFC phaseout  

### Montreal Protocol  

### EU F -gas rule  

### Climate Benefits:  

### Emissions reductions from NPRM : ~ 38 MMTCO2eq in 2020, ~ 70 MMTCO2eq in 2025  

### Emissions reductions from FRM : 28 - 36 MMTCO2eq in 2020, 53 - 69 MMTCO2eq in 2025

# Discussion

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