## 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.