EPA Public Hearing Outline – August 27, 2014

 Intro ‐ Provide a bio on Hussmann – how long in business, more than 5,000 employees (we are

not a small business), products, and four manufacturing locations in North America.

 Reinforce that Hussmann supports energy efficiency products and the clean air policies

 Provide a summary of Hussmann’s mission to “Enable Excellence in Food Retailing”, thereby we

review and assess regulatory trends and proposed legislation from our Customer’s vantage

point.

o Customer Focus areas – Reliability, Energy Efficiency, Performance and Food Safety,

Product Quality, and Cost of  Ownership

o Overall store efficiency is key to our customer, which is in line with the EPA and DOE

agendas.

 Reiterate Hussmann and Industry’s early efforts to discuss our concerns with EPA

o Public meeting in Nov 2013 and Feb 2014

o Private meetings via NAFEM and AHRI

 Impact on our customers

o Only options for self‐contained merchandisers are HC and transcritical CO2 ‐ not always

favorable for our customers and results in cost increase.  Limited to R‐407’s for

supermarket cases.

o Use of alternative refrigerants and construction permits ‐ local mechanical, fire and

building codes need to be updated, which could take several years.  

o Reduced new product development – OEM and testing resources will be dedicated to

compliance... Retailer’s Innovation at the Speed of Retail will be greatly diminished in

the Industry!!!

o Fewer and less efficient options due to combined EPA/DOE effect

o Added Complexity of Regulations for Retailers.... (Example – remodeling and/or

expansion) – explain a typical scenario (switching out cases or adding an additional line

up) and how it is not defined in the NOPR.

o Additional testing, additional development add up to increased costs – these costs

ultimately are passed on to the retail consumer through food inflation.

 Impact on Hussmann

o Explain the development and testing timeline required for technology to catch up with

new refrigerants (it takes 8 – 18 months for a compressor model line to be tested for

performance and then be listed with UL/Intertek.  After the listing the commercial

refrigeration manufacturer must repeat a similar process to get the display case listed.  

Assuming no problems during the test it would take Hussmann three weeks to test one

new display case and then a minimum of six weeks to obtain a UL listing for just that

one case.)
o For self‐contained, the EPA acknowledges they consulted previous petitions when they

delisted HFC 134a but no drop in replacements were added to the listing.  The result is

increased development, testing and cost.

o Unnecessary capital spend to purchase blending equipment for HFC replacements due

to lack of pre‐blended supply of HFC‐free blowing agent foams ($2 million in capital

which may not be needed once a pre‐blended replacement is available)

o “Potentially Available”  impact to a listing – because a non‐HFC refrigerant option is

potentially available does not mean the refrigeration systems are developed  

o Finite testing resources – strain on the system due to DOE and EPA.  Resources typically

used for innovative customer development would need to instead focus on compliance

needs.

 Closing Remarks

o Hussmann requests the EPA to offer negotiated rulemakings when this type of

legislation is developed.  Transparency will allow the industry to develop a timetable

that would benefit our customers and consumers.