Com me nt s by 

### Dave St irp e Mana ge r , Reg ulato ry Affairs Ho ney w e ll In ternational EPA SNAP Stake holders Meeting A ugust 27, 2014 G ood m o rnin g. My name is Da ve Stirpe and I am Ma n age r, Reg ul atory Affairs at Honeywell
. Thank you for the opportunity to a ddress E PA's Proposed Rule to change the li s tin g s tatus fo r certain s ub stitutes und e r the Significant New A lt ernatives Policy (SNA P )
. Ho neywell s upp o rts changes in th e li s tin g sta tu s of certain hi g h-G WP substances in app li cations where a lte rn atives are technically a nd economically fea s ibl e, and commerciall y avai l ab le
. Honeywell has developed s uc h alternatives that p ro du ce overal l envi ro nmen ta l benefits i n all of the secto rs addressed by th e rule , and in are as the rul e ha s not addressed , s uch as co mme rcial c hill ers and s pray foam. The SNAP proposal addressed by Pre si dent Obam a in h i s June 2 01 3 Climate Actio n Pl an can succeed due to t h e availabi li ty o f these a l ternat ives; and we are ready to wo rk with EPA o n the implementation of the Pre s i dent 's goa ls. Honeyw e ll
. is a globa l leader in pr ov iding energy e ffi c ie nt tech nologies and innovations that ca n he lp the world so lv e its e ne rgy and environm e nt a l c h a lle nge s . We are a recognized leadin g inn ovator in the devel o pm en t of e nvironmentall y prefe rable fluorocarbons for use as re frig e r ant s, bl owi ng age nts, so l vents , propellants, and other u ses. S in ce the 1990 s, we have he lp e d bus i ne sses replace ozone -d e pl e t ing s ub st ances in these applicatio n s wi th alternatives that are more energy effic i e nt , have less i mpact o n t h e st r atos ph eric ozone laye r , and ha ve l ess impact on g l o bal clim ate c h ange. Honeyw e ll is a s tro ng s upporter of EPA's commi tment to reducing the u se of s ubs tan ces w ith a hi g h G loba l Warming Pote nti a l (G WP )
. We suppo rt EPA's u se of the SNAP prog ram to tran s ition th e indu s try to low -G WP al ternatives and have b ee n w o rking diligently to deve l op techno l og ies to further those goa l s. Ho neywell has invested s ig nifi cantly in a new pl atform of low- and lower-GWP compound s for use by eq uipment and product manufacturers world w ide
. We are w o rking with manufacturer s today to eval uat e a nd implement these new compo und s in their prod ucts and e quipm e n t. Regu l atory incentives and drivers s uch as thi s SNAP stat u s change regulation will l ead companie s to commercial adopt io n of new comp o und s th at re duce the ri s k to human health and the e nvir o nment. Las t D ece mb er, Honeywell and it s s uppli ers announced plan s to in ves t $300 milli o n in building a new faci l ity i n Geismar, L ou is iana to pr od uce HFO

- l 234yf, a new refrigerant for motor ve hicl e ai r co nd iti o nin g w ith a GWP of less than l - lower th an carbo n di oxide. The plant is expected to be o p erat io n al by the e n d 20 1 6. Nea rl y two milli o n cars in t h e worl d will u se HF0-1234yf by the end of 2014, i nclu din g many in the U nited States. While the 

### CAFE credit program that EPA ha s offe red US aut omobi le manufacturers to meet the ta il pipe emiss io n sstandards has helped to drive adoption of low-GWP refrigerants, there is still a large percentage of the US automobile fleet that doe s not need the CAFE credits gained from adopting low-GWP refrigerant s. The proposed change of listing status would help accelerate the low-GWP refrigerant conversion of the remaining US automobile fleet. In January, Whirl poo l Corporation announced that it has implemented the use of Honeywell's Solstice Liquid Blowing Agent (LBA) into th e foam in su lation used in its US made household refrigerators and freezers. This compound has a GWP approximately 1000 ti mes lower than the most common foam blowing agents in u se today. It is also nonflammable and VOC exempt by EPA. The conversion i s expected to be complete by the end of 2014- resulting in a g lobal 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 sp ray foam. Commercialization of Solstice LBA has also occurred in Japan, EU and even in China for a variety of foa m applications, including appliance, panel and spray foam. A commercial-scale plant for this compound has begun operations in Baton Rouge
. Ho neywell has comple ted const ruction 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 nonflammab le, 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 s ince 2009 in a variety of consumer and technical aerosol applications in Eu rope, 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 .