EXTRUDED POLYSTYRENE FOAM ASSOCIATION 

Statement of the Extruded Polystyrene Foam Association (XPSA) 

John Ferraro, XPSA Executive Director 

750 National Press Building 

529 14th Street, NW 

Washington, DC 20045 

Phone: (202) 591-2466 

Fax: (202) 591-2445 

Website: www.xpsa.com 

August 27, 2014 

Re: Proposed Rule on Protection of Stratospheric Ozone: Change of Listing Status for Certain 

Substitutes under the Significant New Alternatives Policy Program 

My name is John Ferraro and I am Executive Director of the Extruded Polystyrene Foam Association 

(XPSA). XPSA is the trade association representing manufacturers of extruded polystyrene foam (XPS) 

insulation products and the industry's raw material suppliers. XPSA's regular members of Dow, Owens 

Corning, and Pactiv Building Products collectively manufacturer more than 95 percent of all XPS destined 

for use in the North American market. 

XPS insulation applications include external walls, foundations and basements, commercial roofs, plus 

other uses. XPS is an excellent thermal insulation product due to its high R-value to thickness ratio and 

plays a critical role improving the energy efficiency of buildings by lowering heating and cooling costs for 

building owners and occupants. 

XPS insulation maintains thermal and structural integrity during the building service life. With the trend 

to longer building lifetimes, the use of thermal insulation only increases the net savings in energy and 

greenhouse gas emissions. The use of thermal insulation for increased energy efficiency is important to 

reduce global warming and plays an important role in meeting EPA's challenge to reduce carbon 

emissions. First year energy savings for XPS far exceeds energy consumed in the manufacturing process. 

Emissions of blowing agents in foams, such as HFC-134a, are significantly offset by energy savings over 

the life of the building. 

As currently proposed, the removal of 134a from foam blowing agents is scheduled for January 1, 2017 

which is unrealistic, unreasonable, and inconsistent with the gradual phasedown approach proposed by 

EPA within the Montreal Protocol. 

When EPA SNAP evaluated HCFCs, XPS manufacturers essentially had a 14-year window to move from 

CFCs to the current zero ozone depleting HFC technologies. With each conversion, all of our 

manufacturers used approximately 7 years to insure the safety, mechanical performance, and integrity 

of our products met the expectations of the industry and our customers. At the time, it was 

acknowledged by EPA that it would take manufacturers significant time to convert based on the aged 

thermal testing to be conducted, the need to obtain emission permits, make required modifications to 

existing plant designs, order and install equipment to optimize worker safety and efficiency, and finally 
the need to approve and certify these new formulations to comply with required industry standards and 

state and local codes. 

If this proposed rule is not finalized until early 2015, manufacturers will have a less than 2-year period to 

perform the conversion; additionally, because it takes several months for sufficient depletion of the 

supply channel, it is realistically an even shorter timeframe. In addition to these timing considerations, 

there are also questions as to the volume of commercially-viable replacements to HFCs and their 

availability in the United States. Suppliers do not currently have an alternative that is both functional 

and cost equivalent. 

Several alternatives being proposed for our industry are flammable which could result in significant 

changes to manufacturing and product performance. One of the newer technologies being offered is not 

currently available in the U.S. in commercially certified quantities. In 2015, we only anticipate that one 

supplier from one location in the US would be available to supply this technology to the XPS industry in 

the U.S. 

An evaluation of XPSA members has suggested the cost of this material would significantly increase the 

cost of our products. A responsibility of the SNAP rule is to assess cost effectiveness and we do not 

believe this was adequately conducted for XPS insulation. Therefore, this may actually lead to less 

greenhouse gas emission savings from in use foam insulation contributions due to more expensive 

insulations required to insulate buildings, which would result in less insulations being used. 

We urge you to reconsider the conversion timelines for 134a foam insulation technologies or consider 

narrow use exemptions for high performance insulation using 134a until the new technologies are 

understood and widely available. 

XPSA appreciates the opportunity to share its thoughts on the proposed rule and looks forward to 

working with EPA in a constructive manner. Thank you for your consideration of our comments.