Comments by 

Dave Stirpe 

Manager, Regulatory Affairs 

Honeywell International 

EPA SNAP Stakeholders Meeting 

August 27, 2014 

Good morning. My name is Dave Stirpe and I am Manager, Regulatory Affairs at 

Honeywell. Thank you for the opportunity to address EPA's Proposed Rule to change the listing 

status for certain substitutes under the Significant New Alternatives Policy (SNAP). 

Honeywell supports changes in the listing status of certain high-GWP substances in 

applications where alternatives are technically and economically feasible, and commercially 

available. Honeywell has developed such alternatives that produce overall environmental 

benefits in all of the sectors addressed by the rule, and in areas the rule has not addressed, such 

as commercial chillers and spray foam. The SNAP proposal addressed by President Obama in 

his June 2013 Climate Action Plan can succeed due to the availability of these alternatives; and 

we are ready to work with EPA on the implementation of the President's goals. 

Honeywell .is a global leader in providing energy efficient technologies and 

innovations that can help the world solve its energy and environmental challenges. We are a 

recognized leading innovator in the development of environmentally preferable fluorocarbons for 

use as refrigerants, blowing agents, solvents, propellants, and other uses. Since the 1990s, we 

have helped businesses replace ozone-depleting substances in these applications with alternatives 

that are more energy efficient, have less impact on the stratospheric ozone layer, and have less 

impact on global climate change. 

Honeywell is a strong supporter of EPA's commitment to reducing the use of 

substances with a high Global Warming Potenti al (GWP). We support EPA's use of the SNAP 

program to transition the industry to low-GWP alternatives and have been working diligently to 

develop technologies to further those goals. Honeywell has invested significantly in a new 

platform of low- and lower-GWP compounds for use by equipment and product manufacturers 

worldwide. 

We are working with manufacturers today to evaluate and implement these new 

compounds in their products and equipment. Regulatory incentives and drivers such as this 

SNAP status change regulation will lead companies to commercial adoption of new compounds 

that reduce the risk to human health and the environment. 

Last December, Honeywell and its suppliers announced plans to invest $300 million in 

building a new faci lity in Geismar, Louisiana to produce HFO- l234yf, a new refrigerant for 

motor vehicle air conditioning with a GWP of less than l - lower than carbon dioxide. The plant 

is expected to be operational by the end 20 16. Nearly two million cars in the world will use 

HF0-1234yf by the end of 2014, including many in the United States. While the CAFE credit 

program that EPA has offered US automobile manufacturers to meet the tailpipe emissions 
standards has helped to drive adoption of low-GWP refrigerants, there is still a large percentage 

of the US automobile fleet that does not need the CAFE credits gained from adopting low-GWP 

refrigerants. The proposed change of listing status would help accelerate the low-GWP 

refrigerant conversion of the remaining US automobile fleet. 

In January, Whirlpool Corporation announced that it has implemented the use of 

Honeywell's Solstice Liquid Blowing Agent (LBA) into the foam insulation used in its US made 

household refrigerators and freezers. This compound has a GWP approximately 1000 times 

lower than the most common foam blowing agents in use today. It is also nonflammable and 

VOC exempt by EPA. The conversion is expected to be complete by the end of 2014- resulting 

in a global warming impact equivalent to removing more than 400,000 cars annually from the 

road. Solstice LBA has also been commercial in the US for more than a year in spray foam. 

Commercialization of Solstice LBA has also occurred in Japan, EU and even in China for a 

variety of foam applications, including appliance, panel and spray foam. A commercial-scale 

plant for this compound has begun operations in Baton Rouge. 

Honeywell has completed construction of another commercial-scale plant in Baton 

Rouge to produce HF0-1234ze - a low-GWP compound for use as a refrigerant, extruded 

polystyrene (XPS) foam blowing agent, and aerosol propellant. It is nonflammable, VOC 

exempt by EPA and California, and has a GWP of 1. We are working with companies to replace 

HFC-134a in extruded polystyrene foam, consumer and technical aerosols, and chillers. In fact, 

HF0-1234ze has been sold commercially since 2009 in a variety of consumer and technical 

aerosol applications in Europe, Asia, and the US, as well as for one-component foams and 

extruded polystyrene foam applications in Europe. 

We will elaborate on these comments in writing before the October 6 deadline. Thank 

you for consideration of these comments.