## EXTRUDED POLYSTYRENE FOAM ASSOCIATION

Statement ofthe Extruded Polystyrene Foam Association (XPSA) John F erraro, XPSA Executive Director 750 National Press Building 529 14thStreet, 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 underthe Significant NewAlternatives 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 manufacturermorethan 95 percent ofall XPS destined for use in the NorthAmerican 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 acritical role improving the energy efficiency ofbuildings 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 ofthermal insulation only increases the net savings in energy and greenhouse gas emissions. The use ofthermal 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 ofthe 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 finallythe need to approve and certify these new formulations to comply with required industry standards and state and local codes. Ifthis proposed rule is notfinalized 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 ofthe newertechnologies 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 ofXPSA members has suggested the cost ofthis 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 workingwith EPA in aconstructive manner. Thank you foryourconsideration ofour comments.