Thank you for the opportunity to speak at today's hearing . 

### I am Mike Krupa , one ofthe Technical Managers at BASF Corporation . BASF supplies chemicals that are used to make polyurethane foams for insulation and other markets affected by the proposed HFC changes. HFCs are used as blowing agents and act as the main component to improve insulation properties ofthe foam. We have been involved in all ofthe previous blowing agent changes as directed by the Montreal Protocol. During all ofthe blowing agent changes , a great deaf offormulation work is always necessary. In almost every case , a change in the blowing agent requires a major formulation change to provide a productthat works for our customers. The previous changes from CFCs to HCFCs and then to HFCs was not easy and did not occur without a lot of challenges. There was a lot of cost incurred due to trials , production runs , and higher levels of scrap until the formulations could be optimized for each customer. We are also concerned about the availability of the new blowing agents. HFO products are available from Arkoma and Honeywell with another product from DuPont pending TSCA approval. These manufacturers can comment on commercial status and quantities of available products. The indications that we have been given are that the available supply as of 1 January 2017 will be insufficient to meet the needs ofthe affected industries. The alternative low GWP blowing agents that are readily available right now are either flammable or do not provide adequate insulation properties. There is a large capital investment and several years to implement flammable blowing agents for a customer that does not currently have that capability. Timing is our most important concern. The time required to affect the changes discussed here is significant. We estimate that simply introducing and qualifying new products at each of our affected customers will take a full yeaD to complete. Thii doi'S nat

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### year to GeFRI'fele . Many of our customers require agency approval certifications to sell products requiring a flammability rating . These approvals are granted by UL (Underwriter's Laboratories) and FMGiobal (Factory Mutual Insu rance Company) . As the change in blowing agent is wide spread , affecting multiple industries, UL and FMGfobal are likely to run into serious capacity constraints regarding their ability to provide individual product certifications per customer. As the process is often iterative, these delays will have a compounding effect on the industry's ability to change all product formulations in

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## . We have already implemented low GWP blowing agent changes at some of our largest customers. These conversions took approximately 5 years to complete. Conversions at our small customers will likely be last. We simply do not t'l. ave .the time or resources to ensure a smooth transistion to the ,. l., 

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## me f<1.,.., t., new blowing agents.' B ased 'upon the information presented here and what we have learned from our industry partners , BASF would suggest that a delay in the implementation ofthe proposed rule is necessary. We would support a scheduled phase out of 1HFCj34a and HFC 245fa as blowing 

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