December 5, 2014

Rebecca von dem Hagen, Mail Code 6205T Stratospheric Protection Division, Office of Atmospheric Programs Environmental Protection Agency 1200 Pennsylvania Ave. NW. Washington, DC 20460

Subject : Docket ID Number EPA

– HQ

– OAR

– 2014

– 0198

In response to your recent request, this letter provides additional information regarding the U.S. Environmental Protection Agency (EPA) notice of propo sed rulemaking (NOPR) about change s to the listing status for certain substitutes under the SNAP program

. Coca

- Cola believes the SNAP program is
an effective vehicle to reduce f

- gas atmospheric pollutants and address climate protection.

The rulemaking propose s a singular transition date of January 1, 2016 to set HFC

- 134a and other HFC refrigerant blends as unacceptable for new stand

- alone retail food refrigeration and new vending
machines because acceptable alternatives exist [ 79 Federal Register 46126 (August 6, 2014), to amend 40 C.F.R. Part 82]

. However, these acceptable alternatives (R744, R717, R600a, R290, R441 a ) currently
do not have essential system components comm ercially available in all refr igerating capacities to establish efficient equip ment for the full range of equipment sizes

.

The supply chain for a preferred alternative, CO2 refrigerant (R744), is not fully developed at this time. R744 is attractive because it offers the lowest GWP, is a readily available substance , is nontoxic and safe, and provides the best coverage within o ur broad equipment portfolio

. C oca

- Cola believes that R744 has the potential to provide a single refrigerant solution.

R744 solutions will not be available for the full range of retail food refrigeration equipment cabinet sizes by the end of use deadline of January 1, 2016 specified in the NOPR. Components are in development
and /or being prototyped, but are yet to be tooled and scaled

- up for production. The chart of Table 1
below differentiates when the various sizes are expected to be achieved and avai lable for commercial application . Understand that even when the appropriate components become commercially available,
time must still be allocated to develop the new refrigeration system for the appliance, test and optimize it, secure safety certification , and make arrangements for production.

Coca

- Cola recommends that the EPA refine the timetable of the NOPR to reflect what can be realistically achieved as expressed below in this table.

Thank you for soliciting our input . D o not hesitate to request gr eater detail, if needed.

Very Truly Yours

Bruce Karas, V.P., Environmental and Sustainability
Coca

- Cola North America

### Table 1

– Expected d ates for available R744 commercial refrigerators and vending machines

Machine categories Expected Date Comment

A vailable Large countertop visicooler

M edium temperature, self

- contained, transparent door(s), 3

– 7 cu.ft. A vailable

______

Floor standing single

- door visicooler

M edium temperature, self

- contained, one transparent door

, 8

– 28 cu.ft. A vailable

______

Floor standing two

- door visicooler

M edium temperature, self

- contained,

two t ransparent doors, 18

– 4 5 cu.ft. A vailable

______

Solid door zone

- cooled refrigerated beverage vending machine A vailable

______ Near Term Glass door fully

- cooled refrigerated beverage vending machine ~ January 1, 2016 Refrigeration system optimization still ongoing by OEMs. Delayed Commercialization (January 1, 2016 +1 - 2 years) Chest & barrel cooler

M edium temperature, self

- contained,
horizontal transparent door(s), < 6 cu.ft.

~ January 1, 2017 Additional supporting components needed to optimize performance for

En ergy Star, then system optimization

. Floor standing three or more

- door
visicooler Medium temperature, self

- contained,

> 3 transparent doors, > 45 cu.ft. No R744 compressor > 1200 W commercially available until late 2015. Time then needed to develop & optimize systems, tooling, and secure approvals.

Small countertop visicooler

M edium temperature, self

- contained, transparent door (s), < 3 cu.ft. ~ January 1, 2018 No s uitable R744 small compressor (< 300W) commercially available until January 2017. Price increase of 8

- 20% likely. Significant Challenges (January 1, 2016 +3 - 4 years) Supermarket fast

- lane merchandiser

M edium temperature, self

- contained, 2 or more vertical glass doors

, 9

– 18 cu.ft. ~ January 1, 2019 Suitable R744 compressor (i.e., variable

c apacity) to achieve Energy Star not developed . Also, radical system redesign required. Price increase of 8

- 20% likely.

Open

- front cooler (no doors)

M edium temperature, self

- contained,

> 13

- 26 cu.ft.

~ January 1, 2020 Development of cabinets cannot begin until after > 1200W compressor is available, and higher priority sizes are completed.

Open

- front cooler (no doors)

M edium temperature, self

- contained,

> 26 cu.ft. 1600W R744 compressor on drawing board for after commercializing smaller sizes. Not expected before 2019.

Commercially available: Model in the proper electrical voltage for the U.S. power grid, with all regulatory and industry approvals

, produced by at least one manufacturer with production capacity, and available for purchase, shipment and use in the marketplace

.