Scott Lewit 

President 

Comments on EPA SNAP Rule 

August 27,2014 

Structural Composites, Inc. and Compsys, Inc. 

7705 Technology Drive 

W. Melbourne, FL 32904 

slewit@aol.com 

(321) 252-4566 

www.structuralcomposites.com 

www.preforms.com 
Good Morning, 

Thank you for allowing me to speak. I am Scott Lewit, President of Structural 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 of transitioning into the 

broader transportation, infrastructure and building construction market. The technology 

allows for high rate production of lightweight load bearing composites that can support the 

loads of a highway bridge deck or provide superior insulation and structure to trailers, 

buses, rail cars, recreational Vehicles and intermodal containers to just name a few at 

prices in parity with current materials. 

Our technology has recently received national recognition; we won the 2014 National 

Innovation Award, the 2014 Tibbett's Award and three congressional medals of merit for 

our SBIR derived technologies. I am the winner of the 2013 Freeman Lifetime achievement 

Award from the National Marine Manufacturers Association, 2013 TechExpo Technology 

Executive of the Year and a winner ofthe 2010 Small Business Administration's 

Perseverance Award. We are survivors of the great economic downturn and the more 

recent sequestering and government shutdown. 

We have been busy providing leadership and technology to help the nation and in doing so 

we are creating the ground work for a great resurgence in US manufacturing using 

advanced composites. In the DOD we have proven the incredible benefits, lowered 

manufacturing costs, decreased weight creating increased efficiency, performance and 

payload ability using our Navy funded Small Business Innovative Research technology. We 

recently teamed and are a key partner in 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 our concepts. Using a combination of innovative technology, a small 

business centric cost match structure and intellectual protection Structural Composites, 

Inc. was able to commit over 30 million of cost share to the team. While we have not heard 

if we have won, the effort has already caused a critical mass accelerating our technology 

into the transportation segment. 

The core of our innovation is the PRISMA Preform technology, here we take fiber 

reinforcements and cast them into shape using expanding R134A based polyurethane foam. 

A key aspect of our technology is the foam expanding into the inner fabric layer, but leaving 

the outer structural layer free of foam so that reinforcing resins can be applied. You can 

think of it as Lego for composites. The Technology is highly scalable and able to meet the 
large demands of the emerging transportation, infrastructure and building construction 

markets. 

Several years ago we had the daunting task of switching from R-22 to 134A. At that time 

we had 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 our core 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 of which 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 of blowing agent involves much 

work and buy in from our customers 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 proven to 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 of the high volume transportation, 

infrastructure and building construction markets. 

Clearly the efficiency and reduced manufacturing impact our technology makes offsets the 

very small amount of R134a used in our foam. Based on our experience with the R22 to 

134a transition it is not by 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 plant conversion. As we have no alternative at 

this time we ask that the composites industry be exempt from the rule change and remain 

exempt until a viable alternative is available. 

Thank you for your consideration of small businesses and US manufacturing as you 

consider this decision. We will be sending written comments. 
Products Using PRISMA 

ARBOCBus 

US Navy Lightweight RIB