UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Crista LeGrand 

Executive Director 

Fire Suppression Systems Association 

360 1 E. Joppa Road 

Baltimore, MD 2 1236 

Dear Ms. LeGrand: 

DEC 2 2 2015 

OFFICE OF 

AIR AND RADIATION 

I am writing in response to your letter to U.S. Environmental Protection Agency (EPA) 

Administrator Gina McCarthy of December 2, 2015, in which you shared some of the concerns 

of the Fire Suppression Systems Association (FSSA) related to recent petitions submitted to EPA 

on further potential actions that EPA's Significant New Alternatives Policy (SNAP) program 

could consider, including changing the status of certain hydrofluorocarbons (HFCs) used in the 

fire suppression sector. The letter references the petitions to EPA from the Natural Resources 

Defense Council (NRDC), Institute for Governance and Sustainable Development (IGSD), and 

Environmental Investigation Agency (EIA). 

EPA appreciates its long-standing cooperation and engagement with this sector through 

participation in industry meetings and conferences, presenting at association meetings, and 

having staff serve on codes and standards technical committees. The fire suppression industry, 

including organizations such as FSSA and the Halon Alternatives Research Corporation (HARC) 

for which FSSA is also a member, took some of the earliest actions in response to the 1994 

phaseout of production under the Clean Air Act of potent ozone-depleting halons, once widely 

used in many specialty fire suppression applications. We recognize the significant efforts ofthis 

industry to avoid unnecessary emissions of these agents as well as to initiate voluntary reporting 

and tracking of emissions. SNAP determinations on alternatives listed for this sector have been 

informed by industry to understand the criti cal property and life protection benefits for these 

specialty systems. 

To meet the goals ofthe President's Climate Action Plan to reduce emissions ofHFCs, EPA 

published a final rule on July 20, 2015, that changed the status from acceptable to unacceptable 

for certain high-global warming potential HFCs in the aerosols, foams, and refrigeration and air 

conditioning sectors, where safer alternatives were currently or potentially available. Following 

the publication of that rule, EPA received the petitions from RDC/IGSD and EIA. With regard 

to both petitions, EPA is currently reviewing the information provided for the fire suppression 

sector. 

Internet Address (URL) • h!lp //www epa gov 

Recyc led/Recy clable • Pnnted w1th Vegetable Oil Based Inks on 100°'· Postconsumer Process Chlonne Free Recycled Paper 
EPA values input from all stakeholders; therefore, on September 11, 2015, EPA hosted a broad 

SNAP stakeholder meeting where the Agency provided information on potential end-uses and 

sectors it was considering, including fire suppression, with regard to both adding to the list of 

acceptable alternatives as well as changing the status of certain listings. On December 2, 2015, 

EPA held a SNAP workshop specifically for the fire suppression sector, which was attended by a 

representative from FSSA. During the workshop, we discussed some of the potential actions 

SNAP was considering. With regard to HFCs, we discussed an effort to improve our 

understanding of HFC use in this sector. Your information with regard to the uses of HFC-23, 

HFC-227ea, HFC-236fa, and HFC-125 are particularly helpful to our broad understanding of 

these uses and the availability of alternatives. 

I appreciate your interest and information with regard to these uses of HFCs in the fire 

suppression sector. I look forward to your continued cooperation in our efforts under SNAP. If 

you have further questions about your submission, please contact Cindy Newberg, Chief of the 

Alternatives and Emission Reduction Branch at (202) 343-9729 or newberg.cindy@epa.gov. 

Drusilla Hufford, Direc r 

Stratospheric Protecti ~ tston 

Office of Atmospheric P grams