### Summary	of	Interagency	Working	Comments	on	Draft	Language	under

EO12866	Interagency	Review.		Subject	to	Further	Policy	Review. **Comments on Environmental Protection Agency’s “**  **Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives**  **Policy Program ”**  **, RIN 2060 -**  **AS18** Executive Summary
 Suggest including the estimated costs and benefits be included up front in the summary to frame wh y we are doing this rulemaking. Please see the OMB memo from January 12, 2012 describing what should be included in an exe cutive summary : http://www.whitehouse.gov/sites/default/files/omb/inforeg/for
- agencies/clarify ing
regulatory
- r equirements_executive
- summaries.pdf Compliance Dates
 Commenter had sent a comment in a previous round asking about the date in mobile air conditioning, and whether it could be earlier than MY 2021 for HFC
- 134a. Since that time , the G
- 7 agreed to language that we put forward agreeing that, “...We will also continue to take action to promote the rapid deployment of climate
- friendly and safe alternatives in motor vehicle air
- conditioning...”. Isee that we are requesting comments on the MY 2017 and MY 2 019 dates, so that’s appreciated, but just wanted to flag that I tend to think that 2021 is not something other countries would view as ‘promoting the rapid deplo ym ent’. Is there an y way to propose MY 2019, and ask for comments on 2017 and 2021 instead of this approach? Itwould also be good to solicit comments on a later date of MY 2025.  Considering the developmental status of our current space flight programs and evolving hardware requirements, we do not anticipate having viable replacement foams by the proposed 01/01/2022 deadline. We recognize that EPA may want to set a challenging deadline to help drive substitution as much as possible, but we deem it unlikely that we will be able to identify , qualify , and implement an alternate blowing agent by that date. Will we be able to request an extension?  Suggest that EPA add an overarching comment that requests input from the public regarding earlier and later compliance dates than those proposed? There are a few places in the preamble where this is flagged f or specific cases, but it would be a good idea to request comment so that the agency can consider any

new information along with what is currentl y known.  As a general matter, we think EPA should propose an aggressive but realistic rule that pushes the market forward toward climate
- friendl y alternatives. In that context, we are concerned about the comments we see on what CSPA say s is needed. We understand CSPA is a trade association, and the comments seem to suggest where industry would like an exception that we should try to accommodate. We encourage careful consideration of all changes. If EPA deems it necessary , then OK, but we need to be very careful not to simply

put in exemptions for all comers.  Has EPA considered having an extension of the comp liance date for small production lines

– for all uses? You can cost - effectivel y perform R&D on large production line, but for a small line, it may

not pay to continue the line. Such a line may be salvaged b y an

### Summary	of	Interagency	Working	Comments	on	Draft	Language	under

EO12866	Interagency	Review.		Subject	to	Further	Policy	Review. ext ension of time for compliance. This ty pe of flexibility

is often employed by

the air office for manufacturers of equipment, such as lawn mowers or boats with diesel engines, and I believe for wood stoves for the same reason. Perhaps we should develop a proposal with an additional two y ears for product lines involving less than a specific quantity of CO2 Equivalents. There are man y thousands of product lines involved in this rule

– from the very large (auto manufacturing) to the very small (refrigerants, foam uses). Program Flexibility
 Please confirm that the credits earned under the GHG/CAFE vehicle rule s would still be valid even if this rule were finalized. W ould automakers still be able to use the credits they have previously

earned under this new rulemaking? Does this rule have an y affect on those credits such as reducing their value, expiration date, tradabilit y, etc?  One commenter suggested that EPA should consider creating some t ype of set
- aside for specialty vehicles. The idea would be to allow for comp liance flexibility for some of the very unique cases that might arise during implementation. EPA could create some ty pe of petitioning process and a limited pool of credits. How would the agency recommend that it would be implemented?  Commenter asked whether proposals could be made for domestic refrigeration (on the refrigerant side specifically) and for small AC units. It could be I have missed this, but I don’t see a response in the document. I get the sense EPA may view this as a next step rather than something to do here, but wondering if that needs to be reflected somehow.