### ScottLewit President 

# Comments on EPA SNAP Rule August 27,2014

Structural Composites, Inc. and Compsys, Inc. 7705 TechnologyDrive W. Melbourne, FL 32904 slewit@aol.com (321) 252-4566 www.structuralcomposites.com www.preforms.comGood Morning, Thankyou for allowing me to speak. I am Scott Lewit, President ofStructural Composites and Compsys, Inc

.; small businesses both located in Melbourne, Florida. We formed in 1987, currently we employ 40 people from Ph

.D. to high school graduates. Our companies supply the composites industry with cutting edge technology and products that affordably improve efficiency. Our PRISMA Preform Technology is a game changing technology broadly deployed in the marine industry and in the process oftransitioning into the broadertransportation, infrastructure and building construction market. The technology allows for high rate production oflightweight load bearing composites that can supportthe loads ofa highway bridge deck or provide superior insulation and structure to trailers, buses, rail cars, recreational Vehicles and intermodal containers to justname a few at prices in parity with current materials

. Our technology has recently received national recognition; we won the 2014 National Innovation Award, the 2014Tibbett's Award and three congressional medals ofmerit for our SBIR derived technologies. I am the winner ofthe 2013 Freeman Lifetime achievement Award from the National Marine Manufacturers Association, 2013 TechExpo Technology Executive ofthe Year and a winner ofthe 2010 Small Business Administration's Perseverance Award. We are survivors ofthe great economic downturn and the more recent sequestering and government shutdown

. We have been busy providing leadership and technologyto help the nation and in doing so we are creating the ground work for a greatresurgence in US manufacturing using advanced composites. In the DOD we have proven the incredible benefits, lowered manufacturing costs, decreased weight creatingincreased efficiency, performance and payload ability using our Navy funded Small Business Innovative Research technology. We recently teamed and are a key partnerin the Composites NOW! Team. Here we are competing for a 170 Million Industry and DOE funded effort to use composites for clean energy in transportation, wind energy and compressed gas storage
. The Composites NOW! Team, embraced ourconcepts
. Using a combination ofinnovative technology, a small business centric costmatch structure and intellectual protection Structural Composites, Inc. was able to commit over 30 million ofcost shareto the team. While we have not heard ifwe have won, the effort has already caused a critical mass accelerating ourtechnology into the transportation segment. The core ofour innovation is the PRISMA Preform technology, here we take fiber reinforcements and castthem into shape usingexpanding R134A based polyurethane foam. Akey aspect ofour technology is the foam expanding into the inner fabric layer, butleaving the outer structural layer free offoam so thatreinforcing resins can be applied. You can think ofitas Lego for composites. The Technology is highly scalable and able to meet thelarge demands ofthe emerging transportation, infrastructure and building construction markets. Several years ago wehad the daunting task ofswitching from R-22 to 134A. At that time wehad the 134A material available and had run ample trials to determine that it could be adapted. The EPA granted a time extension to allow for this transition. We made it, but it was costly for this small business and it sucked resources from ourcore mission

. Ladies and gentleman, this proposed change to ban 134a is widely unknown to the impacted industry. We have no alternative system to 134a, all systems we have tried to date have been unable to meet the requirements for our preforming process. This same R134a is key to several industries, some ofwhich we supply, such as the Coast Guard approved foam which is widely used in the recreational marine industry

. Here foam provides both structure and flotation, thus the change ofblowing agent involves much work and buy in from ourcustomers to the regulatory agency's such as the US Coast Guard, American Bureau ofShippin& American Boat and Yacht Council and the DOD depending on the application

. We ask for balance, our PRISMA technology is provento provide significant weight, performance and cost advantages. The efficiency is dramatic, from DOD craft that are 40% more payload fuel efficient to refrigerated trailers that are over 25% more thermally efficient and 15% lighter and will have far extended service performance. These are not pie in the sky, these are projects with proven metrics. For the future, we are advancing and scaling the technology to meet the demands ofthe high volume transportation, infrastructure and building construction markets

. Clearlythe efficiency and reduced manufacturing impact ourtechnology makes offsets the very small amount ofR134a used in ourfoam. Based on our experience with the R22 to 134a transition itis notby any means a SNAP, Once a proven alternative is available we will need 4-6 years for transition, this would include time for plant evaluations, customer acceptance trials, agency certifications and plantconversion. As we have no alternative at this time we ask that the composites industrybe exemptfrom the rule change and remain exemptuntil a viable alternative is available. Thankyou for your consideration ofsmall businesses and US manufacturing as you considerthis decision. We will be sending written comments.Products Using PRISMA ARBOCBus

US Navy LightweightRIB