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EPA SNAP Comments Wednesday August 27, 2014 Good Morning. Thank you for the opportunity to be here 

### today. My name is Kenny Owen. I am Vice President of Engineering for Master Bilt Products. Master-Bilt is a small manufacturer of 

### commercial refrigeration equipment with manufacturing located in New Albany, MS. Master-Bilt employs approximately 400 people.

Master-Bilt manufacturers over 215 models of self-contained and remote refrigerators and freezers. It also imports over 50 models of commercial refrigerators and freezers. Master-Bilt also manufactures walk-in coolers and freezers and associated 

### refrigeration units that go with these walk-ins. We manufacture over 700 condensing unit models, 400 evaporator models as well as custom designed multi circuit racks, parallel racks, and Secondary loop parallel racks. Every single product we manufacture uses an HFC that EPA plans to ban. Every single one. AII refrigeration units use either R134a or R404a. R245fa is used for all foam blowing. My company is not opposed to converting to more 

### environmentally friendly refrigerants and blowing agents butEPA must provide a more realistic time than is currently

proposed. When we converted from CFC refrigerants to HFC refrigerants in the mid 1990's drop in replacements were readily available. So were the components for using these new refrigerants such as compressors, and expansion valves. At this time no commercially available drop-in replacement for R134a, R404a, or R245fa exists. This makes this transition for Master-Bilt infinitely more difficult. Since the non-drop-in alternatives available and proposed by EPA have many bad characteristics such as flammability, toxicity, and poor energy efficiency, much more testing is going to be required than was required with the switch from CFCs to HFCs. Also many proposed alternatives have restrictions on use which may prohibit their use in our larger capacity equipment. Every one of our 1300+ models will have to be redesigned. Every one of our 1300+ models will have to be retested and relisted for UL Safety, CSA safety, NSF Sanitation, DOE energy, and EPA Energy Star requirements (when applicable). This testing can take as long as 18 weeks per model. Even if performed concurrently by our small engineering staff, we estimate that it will take us working non-stop for over three years; and this at the expense of new product development.We estimate that this conversion will cost in excess of 1.8

million dollars. And we can't begin the conversion until the components are available from our suppliers. I'm sure you will hear from component manufacturers or have already from them the challenges and time frame required to design and manufacture these components. Before Master-Bilt can sell these newly redesigned products to our customers, many things must take place. Among them are: 1) our factory will have to be upgraded with many new pieces of equipment since our current equipment is not compatible with the alternative refrigerants. This will be a very large expense to my company and many other small businesses. 2) Our service technicians have to be trained to work on flammable, toxic, or extremely high pressure systems. 3) Our customers will have to be convinced that it is OK to have flammable and/or toxic refrigerants in their facilities and near their employees and customers and around their food products 4) Our agency testing companies, UL, CSA, and Intertek, will have to add a lot of new test facilities since every company in the commercial refrigeration industry willbe redesigning their products and all will require the

retesting. 5) Building codes will have to be updated to allow flammable and toxic refrigerants. These are just a few of things that have to happen. I'm sure that many others will be necessary. Regarding blowing agents for polyurethane foam, replacements are available to replace R245fa. But these blowing agents are not drop in replacements for our current foam system. AII are either unable to pass Class 1 burn tests which are required by building codes, or they are less energy efficient. Less efficient foam will cause standard walk-in panels to go from 4" thick to 5" thick to meet the R value required by DOE. This means our manufacturing costs go up and our customers will have to pay

u lfTiYM Given the facts of the situation, Master-Bilt does not see any way we can comply with the 2016 and 2017 deadlines proposed. We feel that better alternatives to the currently available refrigerants must be developed and made commercially available. We think that the proposed phase out of the HFC's should be put off until at least 2025 to allow enough time for all of the above mentioned things to happen. I hope that his brief overview of the situation will help you understand the urgency of the matter. Master-Bilt will submitdetailed comments to EPA before the comment deadline, which we request be extended by 60 days. Thank you again for the opportunity to be here today.