October 20 , 2014 Ms. Rebecca von dem Hagen U.S. Environmental Protection Agency Stratospheric Protection Division Stratospheric Program Implementation Branch (6205J) 1200 Pennsylvania Ave, NW Washington, DC 20460
**RE: Honeywell International Inc. Comments on Proposed Rule: Protection of**  **Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the**  **Significant New Alternatives Policy Program (Docket no.**  **EPA**

– **HQ**

– **OAR**

– **20 14** 

– **0198 )** 
Dear Ms. von dem Hagen , Honeywell International Inc. (“Honeywell”) submits these comments in response to the Environmental Prote ction Agency’s proposed r ule “ Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program” (proposed r ule) . We appreciate the opportunity to provide input into EPA’s process to transition from high

- g lobal

- warming

- potential (GWP) p roducts to more environmentally beneficial alternatives and a pplaud the Agency ’s efforts in designing a proposed r ule that pav es the way for low

- GWP substitutes across the fluorochemical industry.
**I. INTRODUCTION**  Honeywell is a global leader in providing energy efficient technologies and innovations that can help the world solve its energy and environmental challenges. Our Fluorine Products business is a recognized leading innovator in the development of environmentally preferable fluorocarbons for use as refrigerants, foam blowing agents, solvents, propellants, and other uses. Since the 1990s, we have helped businesses replace ozone

- depleting substances in these applications with alternatives that are more energy efficient and have less impact o n the stratospheric ozone layer and global climate change. Honeywe ll supports EPA’s actions under the Clean Air Act and its commitment to transitioning the industry to alternatives with low

- GWP and reduced

- GWP substances. As a leader in fluorine technology, Honeywell has been at the forefront of the industry’s efforts t o develop low

- GWP products. In general, Honeywell supports EPA’s proposal to change the listing status from ac ceptable to unacceptable for many high

- GWP substances

. W e believe the EPA’s proposal to list as unacceptable high

- GWP substances will quickly yield carbon dioxide equivalent emissions ( CO 2 e) reductions

— setting an example for other countries around the world to follow

. We believe that low

- GWP and reduced

- GWP solutions are available or will be available to replace the s e soon - to

- be unacceptable substances . We also believe that there will be sufficient time to comply with EPA’s proposed timelines

. Across end

- use sectors , Honeywell believes EPA should use the most up

- to

- date GWP values. EPA’s proposal references GWP values from the Intergovernmental Panel on Climate2 Change (IPCC) Fourth Assessment Report (AR4). Some of those GWP values differ from the GWP values listed i n the more accurate IPCC Fifth Assessment Report (AR5). The u se of out

of

- date GWP values in such an important rule can cause confusion, especially among those trying to evaluate and compare low

- GWP technologies. Therefore, EPA should adopt the IPCC AR5 GWP values in the final rule. According to EPA, the proposed rule could result in emissions reductions between 31 and 42 million metric tons of carbon dioxide equivalent (MtCO 2 e) annually by 2020. 1 Honeywell estimates that listing HFC

- 134a as unacceptable for use in motor vehicle air condition ing could result in emissions reductions of approximately 10 million MtCO 2 e annually. Adopting our proposal in the condensing unit and supermarket system secto r could result in emissions reductions of up to 3.6 million MtCO 2 e per year or 14 million MtCO 2 e from 2016

- 2020. In foam applications, Honeywell projects there are significant additional emission reductions that could be made. We estimate that EPA could re duce emissions by approximately 35 million MtCO 2 e per year in 2020 from the foam sector alone, including spray foam, whi ch could result in 7 million Mt CO 2 e per year or about 20% more emissions reductions than the actions EPA proposes. Adoption of Honeywell technologies in the aerosols sector in the U.S. could reduce greenhouse gas emissions by more than 6 millio n MtCO 2 e per year in 2016

. We offer detailed comments on EPA’s proposal for specific application s and end

- uses with respect to the availability of alternatives, including supply, the ease of transition , and the environmental benefits of substitutes

. A list of alternatives adopted in each application and specific end

- us es follows our comments in an A ppendix. Our views are also summarized in the following tables.

1 http://www .epa.gov/ozone/downloads/SAN_5750_SNAP_Status_Change_Rule

- Fact_Sheet_070714.pdf3 **Table 1. SUMMARY OF HONEYWELL POSITION** 

— **REFRIGERATION**

**End**
**- Use**  **Product EPA**  **Proposal Honeywell**  **Position Supporting Information**  **Supply of Alternatives**

**Motor Vehicle Air**  **Conditioning (**  **MVAC )**  HFC

134a Unacceptable starting model y ear 2021 Unacceptable starting model y ear 2018

Alternatives: HFO

- 1234yf CO 2 HFC

- 152a x 28 auto brands selling approximately 60 models that use HFO

- 1234yf

x EU Directive prohibits HFC

- 134a by Jan 1, 2017

x Only minor equipment modifications needed

x Many OEM s are already implementing HFO

1234yf and have plans to implement further

x SNAP

- approved; GWP = .31 x HFO

- 1234yf commercial scale production today in China

x Mid

- 2015 commercial scale plant to be commissioned in Japan

x End of 2016 world scale plant in Geismar, Louisiana to be commissioned

**New Retail Food**  **Refrigeration and Vending**  **Machines (stand** 
**- alone)**  HFC blends R

507A, R

- 404A

HFC

134a Unacceptable Jan 1, 2016 Unacceptable Jan 2017

GWP limit of 600 for HFC

134a replacements; GWP limit of 1,5 00 for R

404/R

- 507 replacements
Alternatives: HFO

- 1234yf, HFO

- 1234 ze , R

- 450A , R

- 513A, R

- 448A, R

- 449A x SNAP application s for HFO s are under review ; expect decision by early 2015, after which full industry evaluation will occur

x HFOs could provide optimal balance of safety,

performance and GWP improvement

x Adoption of hydrocarbons and CO 2 requires

costly redesign ; limited components are available for CO 2 systems x Propane, R

- 744a supply available, subject to component availability

x R

- 450A SNAP

- approved , supply soon to be available

x Commercial quantities of HFO

1234yf and HFO

- 1234 ze available today, subject to SNAP approval

**New Retail Food**  **Refrigeration (Condensing**  **Units and Supermarket**  **Systems)** 9 HFC Blends Unacceptable Jan 1, 2016 Support and suggest GWP limit of 1,5 00 (Using AR

- 5 values) x Multiple HFO blend options being evaluated via numerous field trials, including R

- 448A and R

449A. They offer excellent performance and lower energy consumption compared to R

- 404A

. x R

- 448A close to being qualified with numerous

manufacturers

x Oak Ridge National Labs evaluation of R

- 448A

showed excellent performance x R

- 448A and R

- 449A currently being evaluated in extensive field trials

**Retrofit Retail Food**  **Refrigeration (Condensing**  **Units and Supermarket**  **Systems)** 9 HFC Blends Un acceptable Jan 1, 2016 Support and suggest GWP limit of 2,000 (Using AR

- 5 values) x Multiple options exist today including R

- 407A and R

- 407F which have been used successfully in thousand of retrofits

x Extensive field trials now occurring with R

- 448A x R

- 407A and R

- 407F widely available and SNAP

- approved

x R

- 448A currently being evaluated in extensive field trials4 **End**
**- Use**  **Product EPA**  **Proposal Honeywell**  **Position Supporting Information**  **Supply of Alternatives**

**Chillers**

– **New and Replacement**  HFC

134a n/a Unacceptable Jan 1, 2019

Alternatives: HFO

- 1233zd(E) , R

- 450A HFO

- 1234ze(E) , R

- 513A HFO

- 1234yf x HFOs have much lower GWP s
x HFOs offer c omparable or better energy

efficiency

x Time needed to al low for changes to UL

standards, building codes and industry training to handle mildly flammable refrigerants

x There are multiple OEMs that have adopted HFO

alternatives into their equipment x Chillers are available today using both 1233zd and 1234ze

x HFO

- 1233zd(E) and HFO

1234ze(E) are being produced in commercial quantities today

x HFO

- 1233zd(E) and HFO

1234ze(E) are SNAP

- approved for chillers

x R

- 450A SNAP

- approved , supply

available soon5 **Table 2. SUMMARY OF HONEYWELL**  **POSITION**

— **FOAM**
**End**
**- Use**  **Product EPA**  **Proposal Honeywell Position**  **Supporting Information Supply of Alternatives** 

**Polyurethane Foams (all)**  HFC

- 227ea and blends n/a U nacce ptable 60 days after publication of the final rule x Highest GWP of all molecules used in PU foam

x GWP of HFC

- 227ea = 3220 , which is 225% that of HFC

134a

x Non

- flammable s olutions with 3000x lower GWP in use

x Rule would spur industry to develop l ow - GWP products

x Limited use in industry; only recently approved x HFO

- 1233zd(E)

– March 13 , 2 May 2014 3

x HFO

- 1336mmz

– 2 nd half 20 16 2

x HFC

- 245fa, HFC

- 245fa/365

blends 2 (current proposal exempts spray) **High**

– **pressure spray**  **polyurethane foams**  HFC

- 143a, HFC

- 245fa, HFC

365mfc and blends n/a Unacceptable Jan 1, 2018 x Significantly lower GWP alternatives SNAP

- approved

x Quickest (6

- 18 months) and easiest application

x Improved performance (energy efficiency) and lower

cost (raw material yields)

x Additional savings of 7 million MtCO 2 e per year over

EPA proposal x Water

x HFO

- 1233zd(E)

x HFO

- 1336mzz

x Hydrocarbons

**XPS** HFC

- 134a and blends Unacceptable Jan 1, 2017 U nacceptable Jan 1, 2016 x Numerous alternatives approved by SNAP and in use

x EU and Japan largely do not use HFC

- 134a

x HFO

- 1234ze(E) offers both low

- GWP and high energy

efficiency (even better than 134a)

x Low cost of transition

– 5

- 9% higher board costs; HFC

134a prices increased due to preliminary anti

- dumping rulings against Chinese imports x CO 2
x Butane

x HFC

- 152a

x HFO

- 1234ze(E)

– 2008 , 1

August 2014 2

**Polyurethane (all**  **applications)** HFC

- 134a and blends Unacceptable Jan 1, 2017 U nacceptable Jan 1, 2016; low

- pressure 2

- component spray foam unacceptable on Jan 1, 2017 x Low

- GWP o ne - component foam commercial since 2008

x Low

- pressure low

- GWP t wo - component pour foam

systems commercially available

x Low

- pressure two

- component spray foam

– technical

solutions being developed and optimized x HFO

- 1234ze(E)

x HFO

- 1233zd(E)

x Methyl formate

x HFO

- 1336mzz

**Exceptions** All HFCs Aerospace and military Support
No other exceptions necessary x Numerous solutions are SNAP

- approved

x Technology and approvals similar or less than those

applications that are already commercial

x No new exceptions required x HFO

- 1234ze(E)

x HFO

- 1233zd(E)

x Methyl formate, methylal

x HFO

- 1336mzz
**Products containing**  All HCFCs, HFCs All Products All products except refrigerator containers/ trailers x Allow transit of refrigerated containers/trailers manufactured with unacceptable substitutes before status change date and sold after the date x All HCFCs, HFCs
**Open cell/ Flexible foam**  Methylene chlori de n/a List as unacceptable 60 days after final rule x U nacceptable, consistent with NESHAP ruling of Aug. 15, 2014 x CO 2 , acetone, water, HFO

1233zd(E) , others

2 Small scale plant 3 Large scale, world

- scale plant to supply global needs6 **Table 3. SUMMARY OF HONEYWELL POSITION** 

— **AEROSOLS**

**End**
**- Use**  **Product EPA Proposal**  **Honeywell Position**  **Supporting Information**  **Supply of Alternatives**

**Consumer Aerosols**  HFC

134a Unacceptable Jan. 1, 2016 for 18 different applications , including tire inflators and novelty aerosols Support x Multiple/wide

- ranging low

- GWP commercial products and/or shelf

ready prototypes currently available (see table of commercial products in Appendix III ) x Larg e, commercial

- scale plants for low

- GWP alternatives in operation to supply global demand (Hydrocarbons, HFC

152a, HFO

- 1234ze(E) , CO 2 )

**Technical Aerosols**  HFC

134a Unacceptable Jan. 1, 2016 including

x Safety dusters for energized electrical e quipment

x Refrigerant flush

______________________________ Acceptable in the Following:

1. Cleaning products for r emova l of grease, flux, soils from electrical equipment or e lectronics 2. Lubricants for electrical equipment or
e lectronics 3. Sprays for aircraft m aintenance 4. Duster sprays for photographic negatives, semiconductor,
m icroscopes 5. Lubricants and cleaners for spinnerettes for synthetic fabrics 6. Mold r elease 7. Pesticides for us e near electrical wires 8. Pe sticides for use in an aircraft 9. Pesticides in total release insecticide foggers 10. Document preservation sprays Support

__________________________ 1. Unacceptable by Jan. 1, 2016

2. Support
3. Unacceptable by Jan. 1, 2016 4. Unacceptable by Jan. 1, 2016

5. Support
6. Unacceptable by Jan. 1, 2016 7. Unacceptable by Jan. 1, 2017 8. Unacceptable by Jan. 1, 2017 4 9. Unacceptable by Jan. 1, 2017
10. Support x Multiple/wide

- ranging low

- GWP commercial products and/or shelf

ready prototypes currently available (see table of commercial products)

x It is industry practice to

remove flushing agents from lines, etc. by blowing them dry with nitrogen or co mpressed air after flushing; no risks from residual flushing agents are posed by welding lines after flu shing x Large, commercial

- scale plants for low

- GWP alternatives in operation to supply global demand (Hydrocarbons, HFC

152a, HFO

- 1234ze(E) , CO 2 )

4 SPRAY Magazine, May 20127 **End**
**- Use**  **Product EPA Proposal**  **Honeywell Position**  **Supporting Information**  **Supply of Alternatives**

**Medical Aerosols**  HFC

134a Unacceptable Jan. 1, 2016 ( including freeze spray for t issue )

______________________________ Acceptable in the f ollowing:

1. MDI 2. Wound care s prays 3. Topical coolant sprays for pain 4. Liquid b andages 5. Bandage adhesive r emover 6. Anti

- fungal s prays Support

__________________________ A cceptable in the f ollowing:

1. Support 2. Support 3. Unacceptable Jan. 1, 2018 4. Support 5. Support 6. Support x For freeze sprays for pain r elief, long

- term exemption is not required since customers are already evaluating/prototyping low

- GWP alternatives x Larg e, commercial

- scale plants for low

- GWP alternatives in operation to supply global demand (Hydrocarbons, HFC

152a, HFO

- 1234ze(E) , CO 2 )

**All Aerosols Applications**  HFC

- 125 Unacceptable Jan. 1, 2016 Support x Multipl e/wide

- ranging low

- GWP commercial products and/or shelf

ready prototypes currently available (see table of commercial products) x Larg e, commercial

- scale plants for low

- GWP alternatives in operation to supply global demand (Hydrocarbons, HFC

152a, HFO

- 1234ze(E) , CO 2 )

**All Aerosols Applications**  HFC

- 227 Unacceptable Jan. 1, 2016 , except in m etered dose inhale r s Support x Multiple/wide

- ranging low

- GWP commercial products and/or shelf

ready prototypes currently available (see table of commercial products) x Larg e, commercial

- scale plants for low

- GWP alternatives in operation to supply global demand (Hydrocarbons, HFC

152a, HFO

- 1234ze(E) , CO 2 )8 **Table 4. SUMMARY OF OTHER APPLICATIONS THAT SHOULD BE INCLUDED** 

**End**
**- Use**  **Product EPA**  **Status H**  **oneywell Position**  **Supporting Information Supply of**  **Alternatives**

**Chillers**

– **New and Replacement**  HFC

- 134a Acceptable Unacceptable Jan 1, 2019

Alternatives: HFO

- 1233zd(E) , R

- 450A HFO

- 1234ze(E) , R

- 513A HFO

- 1234yf x HFOs have much lower GWPs

x HFOs offer c omparable or better energy efficiency

x Time needed to al low for changes to UL standards,

building codes and industry training to handle mildly flammable refrigerants

x There are multiple OEM s that have adopted HFO

alternatives into their equipment x HFO

- 1233zd(E) and HFO

1234ze(E) are available today

x HFO

- 1233zd(E) and HFO

1234ze(E) are being produced in commercial quantities today

x HFO

- 1233zd(E) and HFO

1234ze(E) are SNAP

- approved for chillers

x R

- 450A SNAP

- approved, supply

available soon

**Polyurethane Foams (all)**  HFC

- 227ea and blends None; not yet evaluated under SNAP Unacceptable 60 days after publication of the final rule x H ighest GWP of all molecules used in PU foam

x GWP of HFC

- 227ea = 3 , 220 , which is 225% that

of HFC

- 134a

x Non

- flammable s olutions with 3000x lower GWP

available

x Rule would spur industry to develop low

- GWP

products

x Limited use in industry; only recently approved x HFO

- 1233zd(E)

– March 13 5 , May 2014 6

x HFO

- 1336mmz

– 2 nd half , 20 16 2

x HFC

- 245fa, HFC

- 245fa/365 blends 2

(current proposal exempts spray)

**High**

– **pressure spray**  **polyurethane foams**  HFC

- 143a, HFC

- 245fa, HFC

- 365mfc and blends Acceptable Unacceptable Jan 1, 2018 x Significantly lower GWP alternatives SNAP

approved

x Quickest (6

- 18 months) and easiest application

x Improved performance (energy efficiency) and

lower cost (raw material yields)

x Additional savings of 7 million MtCO 2 e per year

over EPA proposal x Water

x HFO

- 1233zd(E)

x HFO

- 1336mzz

x Hydrocarbons
**Open cell/ Flexible foam**  Methylene chloride Acceptable List as unacceptable 60 days after final rule x Unacceptable, consistent with NESHAP ruling of August 15, 20 14 x CO 2 , acetone, water, HFO

1233zd(E) , others

5 Small scale plant 6 Large scale, world

- scale plant to supply global needs9 **II. DETAILED COMMENTS BY APPLICATION &**  **END**
**- USE** 
We submit the following detailed comments on EPA’s proposal by application and end

use
. **A. MOTOR VEHICLE AIR CONDITIONING**  EPA proposes to allow continued use of HFC

- 134a in motor vehicle air conditioning systems through model year 2020 vehicles. Listing HFC

- 134a as unacceptable in this application could result in emissions reductions of approximately 10 million MtCO 2 e annually. Honeywell believes the transition to low

- GWP alternatives can happen by model year 2018 vehicles based on the following

.

x Major suppliers of mobile air conditioning systems have already developed systems to accommodate alternatives to HFC

- 134a, including HFO

- 1234yf, a widely available substitute. This is demonstrated by the fact th at 28 different automobile brands are selling approximately 60 different models designed to use HFO

- 1234yf. U.S.

- based companies , including Ford, GM, Chrysler, and Tesla are manufacturing more than a dozen models using HFO

- 1234yf

. 7

x In t he EU , the Motor Vehicle Air Conditioning Directive prohibits use of HFC

- 134a in
n ew vehicles by January 1, 2017. In response, global auto manufactur ers have already made plans to transition to non

- HFC

- 134a alternatives.

x While some auto manufacturers for U

. S

. car production have s tated that their designs for new vehicles are locked

- in until model years 2016 or 2017, they have time today to make plans to transition vehicles to adapt to low

- GWP refrigerants by model year 2018. Given manufacturers’ experience in the EU and U

. S

. there is a lready an understanding and capability to transition vehicles for U

. S

. car production.

x Ford, General Motors , Chrysler , and Tesla are already selling 17 models using HFO

1234yf systems.

x Adequate refrigeration solutions exist. The EPA has already SNAP

- a pproved HFO

1234yf, HFC

- 152a, and CO 2 (R

- 744) for motor vehicle air conditioning systems and, as noted above, low

- GWP motor vehicle systems are currently in widespread use in the U.S. and Europe.

x There is one commercial scale HFO

- 1234yf production plant operating today in China, a second one is expected to be commissioned in the first half of 2015 in Japan via a strategic supply relationship between Honeywell and Asahi Glass Company Ltd, and a third world

- scale plant will be commissioned by Honeywell by t he end of 2016 in Geismar, Louisia na. As part of its justification for a long timeline for transition out of HFC

- 134a in the motor

7 This data is from a list compiled by the Institute for Governance and Sustainable Development (IGSD) (Oct. 12, 2014) (Sources include Deutsche Umwelthilfe, Mobile Air Conditioning Society (9/19/2014) , EU Stakeholder Meeting (11/2013) and IGSD communication with MVAC experts.10 vehicle air conditioning application, the proposed rule states that auto manufacturers may need more time to ensure systems u sing HFC

- 152a and HFO

- 1234yf are safe, since both substances are classified as flammable. While i t is true that systems using HFC

- 152a may require a secondary loop through the passenger cabin to adequately address the flammability risks of HFC

- 152a, EPA’s rationale is not justified with respect to HFO

- 1234yf. The American Society of Heating, Refrigeration, and Air Cond i tioning Engineers (ASHRAE) has assigned HFO

- 1234yf a flammability rating of A2L, mildly flammable. HFO

- 1234yf systems safely utilize the same architecture as HFC

- 134a systems , as documented by the Society of Automotive Engineers (SAE) study CRP1234, which adequately protects against any flammability risks. Using HFO

1234yf does not require a secondary loop design. The proposed rule also mistakenly states that HFO

- 1234yf has “measurably lower energy efficiency” than HFC

- 134a. To the contrary, auto manufacturers that have tested and used HFO

1234yf in their vehicles have found that systems designed for the properties of HFO

- 1234yf are at least as efficient as those using HFC

- 134a, and in some cases systems using HFO

- 1234yf were found to be more efficient. We understand some concerns have been raised regarding vehicles that are produced with HFO

- 1234yf in the U.S. and then subsequently expor ted to other countries that do no t have similar low

- GWP requirements and therefore appear not to be prepared to service car s with low

GWP refrigerants. We believe that t his is not a valid concern since this issue is not unique to refrigerants; i t is the same for other vehicles parts. If a vehicle is sold in another country, the vehicle servicing infrastructure must be available to perform all types of services and repairs and therefore all of the unique parts includi ng body panels, engine parts, transmissions, refrigerants , etc. must be available. It is the responsibility of the vehicle manufacturer to ensure that their authorized dealers in those countries are able to provide all the necessary service to these expor ted cars, especially since they will be required to provide warranty service f or a period generally ranging from three to seven years after first sale. In addition, Honeywell has already developed an extensive network of distributors that are capable of su pplying HFO

- 1234yf globally. Lastly, the proposed rule appears to be using preliminary GWP values for HFO

- 1234yf derived from research papers, which conclude that HFO

- 1234yf has a 100

- year GWP of 4. We submit that the IPCC’s AR5, the latest extensively peer - reviewed evaluation , should be used instead. That report concludes that HFO

- 1234yf has a 100

- year GWP of just 0 .31.

**B. REFRIGERATION**  1. New Retail Food Refrigeration and Vending Machines (stand

- alone equipment) EPA proposes to list as unacceptab le as of January 1, 2016 HFC

- 134a and HFC blends , including R

- 507A and R

- 404A, among other substances, for use in new retail food refrigeration and vending machines. Honeywell believes this proposal is too restrictive because it would limit the industry’s option s to only a few SNAP

- approved alternatives that are either highly flammable such as R

- 290 or R

- 600a , or less energy efficient, like R

- 744, which would negate the lower

GWP benefits of R

- 744.11 For larger stand

- alone units, it is not possible to adopt hydrocarbons (R

- 290 or R

- 600a) without completely redesigni ng the system to accommodate two separate refrigeration circuits that would meet EPA’s charge size limits. This could nearly double the cost of the refrigeration system to accommodate the use of hydrocarbons. Adopting R

- 744 would require a comple te redesi gn of prevailing stand

- alone and vending machine systems. Currently there is very limited availability of the mechanical components necessary to implement such R

- 744 system redesigns. Overall analysis done by Honeywell and many of its equipment partners indicate that transitioning to R

- 744 requires a higher equipment cost than transitioning to oth er alternatives such as an HFO or HFO blends

. HFO s and HFO blends could realistically offer an excellent balance of safety, performance, and cost. 8 Furthermore, Honeywell recommends setting GWP limits , based on the IPCC AR5 values , for systems that have been designed to be used with medium pressure refrigerants, such as HFC

- 134a, and systems that have been designed to be used with higher pressure refr igerants such as HFC

- 404A.

x For systems currently designed for HFC

- 134a , we recommend limiting acceptable substitutes to those with a GWP of 600 or less. Such substitutes could include HFO

1234yf (GWP <1), HFO

- 1234ze(E) (GWP <1), R

- 744, R

- 290, R

- 600a, and H FO blend R

- 450A (GWP = 546) . ASHRAE recently designated R

- 450A as non

- flammable. Commercial supply quantities exist today for HFO

- 1234yf and HFO

- 1234ze(E)

.

x For systems currently designed for R

- 404A , we recommend limiting accep table substitutes with GWP of 15 00 or less. Such substitutes could include R

- 744, R

- 290, R

600a, and HFO blends R

- 448A ( GWP = 1 270 ), R

- 450A (GWP = 546), and R

- 513A (GWP = 572 ) (provisional ASHRAE designation). Both R

- 448A and R

- 450A are ASHRAE designated non

- flammable. In light of the above comments, Honeywell believes the effective date for listing HFC

134a and higher

- GWP HFCs and HFC blends as unacceptable should be January 1, 2017. This will allow proper time to accommodate significant equipment redesigns to incorpor ate the use of hydrocarbons and CO 2 . In addition, HFOs and HFO blends could be adopted and ultimately provide the industry with low

- GWP solutions in these applications that are energy efficient , low

cost, and safe

. EPA proposes to continue to allow exis ting equipment to be serviced with R

- 404A and R

- 507A indefinitely. Honeywell urges EPA to consider disallowing the use of these high

- GWP substances for servicing no later than January 1, 2022 , to further encourage transition to lower

GWP alternatives. EP A should continue to allow recycled and reclaimed R

- 404A and R

- 507A to be used for servicing to encourage reclamation and make the transition to lower

- GWP substances less disruptive.

8 EPA recently signed a final rule listing R

- 450A, a blend of HFC

- 134a and HFO

- 1234ze(E), as acceptable for use in retrofit and new retail food refrigeration and retrofit vending machines. ( See EPA SNAP Notice 29, at http://www.epa.gov/ozone/downloads/Notice29.pdf.)12 2. Retrofit Retail Food Refrigeration and Vending Machines (stand

- alone equipment) Honeywell supports EPA’s proposal in this application.
3. Condensing Units and Supermarket Systems (new and retrofit) Honeywell generally supports EPA’s proposal to find un acceptable by January 1, 2016 nine HFC blends, including R

- 404A and R

- 507A, for new and retrofit condensing unit and supermarket system applications. Today there are multiple red uced

- GWP refrigerants available that are near drop

- in solutions for this appl ication and provide improved energy efficiency and ease of adoption. This is clear and there numerous examples in place today. 9
To aid EPA in it s goal to drive down the GWP of refrigerants as low as possible, Honeywell recommends bifurcating new and re trofit unacceptable recommendations in the following manner:

x Retrofit: List all HFC Blends with GWP greater than 2000 , based on the IPCC AR5 values, as unacceptable by January 1, 2016. We believe the proposal is not aggressive enough because it would allow the use of substances with a GWP above 2000 when there are various acceptable substitutes with GWPs less than 2 000, such as R

- 407C (GWP = 1624), R

- 407F (GWP = 1674 ), and R

- 448A (GWP = 1273 ) in wide use today or nearing commercialization. These substitutes are also more energy efficient than higher

- GWP refrigerants currently used in these applications and there is ample supply refrigerant to serve this application . In addition to fin ding certain refrigerants unacceptable for retrofitting condensing units and supermarket systems, we suggest that EPA consider finding unacceptable the use of high

- GWP HFC blends for servicing of existing R

- 404A and R

- 507 systems at some date in the futur e.

x New Units and Supermarket Systems: List all HFC Blends with GWP greater than 1500 , based on the IPCC AR5 values, as unacceptable by January 1, 2016. There are multiple options that have been developed with lower

- GWP refrigerant solutions which are in early commercialization (e.g., R

- 448A and R

- 449A) that are highly efficient and near drop

- in replacemen ts to existing widely used HFC b lends like R

- 404A, R

- 407A, R

- 407F, and R

- 507. EPA can draw a bright line b y distinguishing new units and systems from retrofits and begin the process to transition all supermarkets to low

- GWP substitute s
. Adopting this proposal could result in emissions reductions of up to 3.6 million Mt CO 2 e per year or 14 million MtCO 2 e from 2016

- 2020. EPA asks whether listing some currently acceptable substances as unacceptable creates
a n unintended incentive to continue to use old leaky equipment, especially HCFC

- 22

- based systems. Honeywell does not believe such an incentive will be created for the following reasons: (1) the availability of HCFC

- 22 will be limited under EPA’s allocation regulations, (2) the price will likely be sufficiently high er because of the progressively limited supply , and (3) alternatives to HCFC

- 22 are available. Th us, EPA should finalize its proposal to list as unacceptable high

GWP substances in the applications described above.

9 See Appendix I.D.13 **C. CHILLERS**  EPA’s proposal does not include any change in status for refrigerants used in chillers, such as HFC

- 134a. Honeywell encourag es EPA to list HFC

- 134a a s unacceptable in new chillers effective o n Janua ry 1, 2019 because alternatives such as HFO

- 1233zd(E) , and HFO

1234ze(E) are both commercially available, SNAP

- approved , and have comparable or higher efficiencies to HFC

- 134a and much lower GWPs. It should be noted that several chiller manufacturers have recent ly introduced chillers with low

- GWP refrigerants. Specifically, this
summer Trane introduced a line of high

- efficiency chil lers based on HFO

- 1233zd(E) that are available in capacities ranging from 740 to 3,500 tons. In addition , several other man ufacturers currently offer high

- efficiency chillers based on HFO

- 1234ze(E) in sizes ranging from tens of tons to hundreds of tons. Please see Appendix I

. C

. for a select list of commercially

- launched chil lers that utilize HFO

- 1234ze(E)

. It is worth noting that these chillers using HFO

- 1234ze(E) have largely been launched in the EU where th e formal promulgation of the F

- g as regulation has motivated manufactures to develop and comm ercialize these units. We believe that finding HFC

- 134a unacceptable for this use would similarly accelerate commercial development in the U.S

.
*** As shown in the table below listing select customer announcements, the motor vehicle air condition ing, commercial refrigeration , and chiller industries are already transitioning to low

GWP substances. Table 5. Announcements from Customers Adopting Low

- GWP Alternatives in Air Conditioning and Refrigeration Applications
**MOTOR VEHICLE AIR CONDITIONING Company**  **Date Headline**  General Motors July 23, 2010 GM First to Market Greenhouse Gas

- Friendly Air Conditioning Refrigerant in U.S. Chrysler Oct. 30, 2013 Chrysler Rolls Out R

- 1234yf

**COMMERCIAL REFRIGERATION Company**  **Date Headline**  K

- VA

- T Food Stores, Inc. (Food City) July 2014 Genetron Performax® LT (R

- 407F) “Makes Se nse” for New Supermarkets U.S. Department of Energy April 2014 Working Fluids: Low Global Warming Potential Refrigerants
Les Salaisons du Mâconnais Jan. 2014 Performax® LT / R

- 404A : a life

- size confirmation of achievable energy savings Emerson Climate Technologies Sept. 2013 Refrigerants Update14 GEA Bock Compressors Sept. 2012 The Low GWP Refrigerant R407F

– For highly efficient and environmental friendly refrigeration systems with Bock compressors Emerson Climate Technologies Sept. 2012 Copeland Discus Compressor Line Approval with R

407F ASDA (Walmart Subsidiary) March 2012 Innovative Refrigerant Helps Lower Carbon Footprint and Energy Costs Super U June 2011 Super U adopts Performax LT for its refrigeration system Bitzer June 2011 Interest in HFC

- 407F Grows Sprouts Farmers Market April 2011 Supermarkets Make Strides

**CHILLERS Company**  **Date Headline**  Trane July 25, 2014 Trane First with 1233zd Centrifugal Chiller Cofely Aug. 1, 2014 Cofely Refrigeration Announces Quantum G Star Refrigeration Dec. 12, 2013 Star Launches Energy Efficient HFO Chiller
Airedale Dec. 2, 2013 Airedale First To Market With Production Range of Low GWP Chillers Danfoss Sept 25, 2013 Danfoss Turbocor releases TG310 compressor running with HFO

- 12 34ze(E) Klima

- Therm Jan. 1, 2012 World

- First HFO Chillers Installed in South London

**D. FOAM**  Honeywell supports EPA’s proposal for foam applications, but believes the transition to low

- GWP substitutes should be expanded to include new applications like spray foam . We also believe that in some cases the transition can occur more quickly than EPA proposes

. We agree with EPA that history shows that the foam industry can convert quickly to alternatives with very limited equipment changes and capital expenditures, especially when near drop

- in solutions are available, as they are now. EPA states that during the last transition “the foam industry was able t o convert from HCFC

- 142b and HCFC

- 22 to other acceptable substitutes” in 16 months. This is not the first the time industry is tr ansitioning to new foam blowing agents. I n fact, several low

- GWP foam solutions are already available today and customers have already transitioned, as noted below. Many of the available solutions are close to drop

- in and while reformulation work and testing are typically involved in any new foam (such is true of every previous transition or even improvements with existing gener ations), the technology is sufficiently advanced that the time for reformulation and testing is shorter than the timelines suggested by EPA for transition. Recently, several customers across many applications15 have already tr ansitioned from high

- GWP to low

- GWP foam blowing agents

. B elow is a select list of customers across various foam applications that are already selling products commercially, and for whom reformulation and testing time ha ve not delayed commercializ a tion :

x Extruded polystyrene ( XPS )

— Jackon, Abr iso, Knauf, Fibran ;
x Appliances

— Whirlpool, Midea, Haier, Festivo ;
x Spray foam

— Lapolla, West Developmen t, Elastochem, Toyo, Asahi, BIP ;
x Panel

— Kingspan, All Weather Panel ;
x Comm ercial refrigeration equipment

— Porkka, Okamura ;
x Refrigerated trailers

— CIMC China ; and

x One

- component foam

— Dow, Fomo, Soudal

. Across most applications , many additional customers globally are in various stages of commercial development. Some customers have only recently started trials and our expectation is that thes e customers will be able to reach commercial solutions with in the timelines proposed by EPA. Customers have several available SNAP

- approved options from Honeywell and manufacturers . According to EPA even more options will become available in the near future. This year Honeywell started operating large

- scale manufacturing plants for HFO

- 1233zd(E) and HFO

- 1234ze(E) , which are replacements for HFC

- 134a, HFC

- 245fa, and HFC

- 365mfc. DuPont announced that full

- scale production of HFO

- 1336mzz (a substitute f or HFC

- 245fa, HFC

365mfc , and blen ds thereof) would be available in the second half of 2016. 10 As noted above, several customers in the U.S. and abroad have adopted substitutes for HFC

- 245fa, HFC

- 134a, HFC

- 365mfc and blends thereof. Strong regulatory actio n will continue to drive conversions away from high

- GWP HFCs to products with much lower climate impact. EPA estimates t he emissions reductions from the proposed unacceptability listings in all sectors could be between 31 and 42 million Mt CO 2 e in 2020

. 11 By taking the actions noted here in the foam sec tor we estimate that EPA could reduce CO 2 e emissions by approximately 35 million Mt CO 2 e per year in 2020, including spray foam , which alone could result in 7 million Mt CO 2 e per year or about 20% more emissions reductions than the actions EPA propose s
. Further, in many instances customers are seeing benefits of better performance, energy efficiency, non

- flammability, and better product yields (less foam for the same performance), making solutions not just lower in climate change impact but al so better in other attributes. For example, refrigerators made with HFO

- 1233zd(E) are 8

- 10% more energy efficient than those manufactured from flammable hydrocarbons and 2

- 4% more efficient than those that use HFC

245fa, so appliance manufacturers can either reduce foam thickness or improve energy efficiency at the same foam thickness. Similar energy efficiency benefits are being seen across spray foam and other foam applications as well, offering customers bet ter performance and/or lower cost alternatives across a range of applications.

10 http://www.gupta

- verlag.com/general/news/industry/14939/dupont

- fluorochemicals

- announces - world

s - first

- full

- scale

- production

- of

- hfo

- 1336mzz/pdf

. 11 http://www.epa.gov/ozone/downloads/SAN_5750_SNAP_Status_Change_Rule

Fact_Sheet_070714.pdf16 Many low

- GWP substitute solutions, such as HFO

- 1233zd(E) for polyurethane (PU) foam or HFO

- 1234ze(E) for extruded polystyrene (XPS) , are similar or better on a life

- cycle analy sis basis. They are of similar or better energy efficiency than the HFCs they are replacing and significantly l ower in GWP. Hence their life

- cycle impact is order(s) of magnitude better tha n the HFCs they are replacing. For example, a thorough life cycle a nalysis of HFC

- 245fa and HFO

- 1233(zd) (E) in closed

- cell spray foam 12 showed that the impact of using HFO

- 1233zd(E) improved the GWP payback by up to 90% compared to HFC

- 245fa. Therefore, in addition to offering direct GWP savings, several substitutes for HFC s are expected to dramatically reduce the CO 2 e emissions on a life

- cycle basis as well. Honeywell believes that the proposed rule can be expanded to cover mor e applications since solutions ar e already in commercial use. I n some cases, EPA could list substances as unacceptable earlier than proposed.
1. HFC

- 227ea and Blends Containing HFC

- 227ea EPA should list HFC

- 227ea and blends containing the same as unaccep table for use in all foam applications quick ly , beginning sixty days after publication of the final rule. Since EPA proposes to list HFC

- 134a and other high

- GWP molecules as unaccepta ble, we recommend that EPA list HFC

- 227ea (the molecule and its b lends) as unacceptable for the reasons detailed below. Honeywell is supportive of EPA’s approach to target the specific molecule, since in the foam industry, it is possible to blend the molecule with other substances, e.g., water (which is also a blowing agent) , and reduce the GWP. Listing HFC

- 227ea as unacceptable immediately could prevent use of a material that has a GWP 225% greater than HFC

- 134a, while having minimal impact to foa m customers

.

x HFC

- 227ea has an extr emely high GWP , 225% of HFC

- 134a : HFC

- 227ea has a GWP of 3 , 220

- 3 , 350 , which is the highest GWP of all molecules used in PU foam . In other words, it is 225% the GWP of HFC

- 134a. Since EPA proposes to list HFC

- 134a as unacceptable across all foam applications due to its high GWP , it makes good sense t o also list HFC

- 227ea and its blends as unacceptable.

x HFC

- 227ea is not an effective blowing agent : HFC

- 227ea, by itself, is not listed under SNAP as acceptable or unacceptable as an alternative blowing agent in foam applications. It is listed as accep table when blended with HFC

- 365mfc. As the industry knows well, HFC

- 227ea is not an effective blowing agent when used on its own. Its primary purpose is to reduce the flammability of other HFCs, primarily HFC

- 365mfc, by blending the two substances togeth er.

x Several other non

- HFC

- 227ea, non

- flammable solutions are available to customers : HFO

- 1223zd(E) has a GWP 3000 times lower th an HFC

- 227ea , is non

- flammable, and has been approved by SNAP for over 2 years . HFO

- 1233zd(E) has been commercial in spray foam for 18 months. Moreover, EPA has already approve d HFC

- 365/245fa blends, which are non - flammable and also much lower in GWP than

12 Bogdan and Pascual, Environmental assessment of next gen eration blowing agent technology using Solstice LBA in ccSPF, Polyurethane Magazine, 5 (2012).17 using 227ea, allowing customers to choose from several lower

- GWP options even without HFC

- 22 7ea. Honeywell’s HFO

- 1233zd(E) large

- scale plant started up in May 2014 in Baton Rouge, Louisiana. Spray foam customers will have yet another low

- GWP option as DuPont has announced they will begin commercial production of HFO

- 1336mmz in the second half o f 2016

.

x Small to no current impact on foam industry of listing HFC

- 227ea a s unacceptable : S ince EPA listed HFC

- 227ea/365mfc blends as acceptable in May 2013, it has gained very limited use in the U.S . Listing HFC

- 227ea and blends containing HFC

- 227ea as unacceptable would thus have little negative impact to foam customers.

x Enable industry resources and time to be spent on much better, lower

- GWP solutions : L isting HFC

- 227ea as unacceptable quickly w ill send a clear signal to customers not to formulate with a product that is as much as 3000+ times more harmful than other solutions like HFO

- 1233zd(E) that are commercially available and being adopted by companies like Lapolla, West Development Group, an d Elastochem in the past 18 months. Customers could then spend their technical resources a nd time on formulating with low

- GWP alternatives rather than formulating with the much more environmentally harmful HFC

- 227ea. Listing HFC

- 227ea as unacceptable will also reduce the demand on testing labs to test products made with HFC

- 227ea, which will have the side benefit of helping to decrease the testing time for much lower

- GWP solutions. Given the ultra

- high GWP of HFC

- 227ea ( 225% hi gher than HFC

- 134), the availability of several substitutes, and limited impact on customers, EPA should list HFC

- 227ea and blends containing HFC

- 227ea as unacceptable in all foam applications, including spray foam, sixty days after the issuance of the fin al rule.
2. HFC

- 134a in Foam Applications EPA proposes to list HFC

- 134a as unacceptable for use in foam applications as of January 1, 2017. Honeywell is ready to support the transition starting January 1, 2016. Honeywell believes solutions are available across a wide range of applications and that the relative cost of transitioning to substitutes is not significant , especially given the recent ly rising price of HFC

- 134a imported from China due, in part, t o prelim inary anti

- dumping rulings against Chinese imports by the Department of Commerce and the International Trade Commission . A December 2013 preliminary determination by the U.S. International Trade Commission 13 is proposing significant duties on imports of HFC

- 134a from China, and prices of HFC

- 134a have been increasing to pre

- dumping levels. This means that solutions for HFC

- 134a are not only available but the relative cost of transition away from HFC

- 134a to lower

- GWP alter natives could be significantly reduced. Honeywell ’s position on EPA’s proposal with respect to XPS and PU foam, two large users of HFC

- 134a, are detailed below.

13 http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2013/tetrafluoroethane_from_ china/preliminary/PDF/FR_ITC_Determinations_Prelim.pdf18 a. HFC

- 134a in XPS A pplications For XPS users, several solutions are already available, listed as acceptable under SNAP, and have been in use globally for some time. For example, in Europe, approximately 80% of the industry uses solutions other than HFC

- 134a, including CO 2 , HFC

- 152a, isobutane, and HFO

1234ze(E) . Similarly, in Japan, all XPS is produced with alternatives to HFC

- 134a, such as isobutane and HFO

- 1234ze(E) . All of the above solutions are listed under SNAP as acceptable and are available to U.S. customers, some of w hom are already using these low

- GWP technologies in other parts of the world. HFO

- 1234ze(E) has been commercial since 2008, and is being used by customers in Europe and Japan. Honeywell is now running a large, world

- scale commercial plant in Baton Rouge, Louisiana, whic h started operating in September 2014. Honeywell is ready to support an unacceptability listing date of January 1, 2016

. Energy efficiency and cost are t wo important factors to consider in evaluating alternatives . First, with respect to energy efficiency, the table below shows that HFO

- 1234ze(E) is an excellent foam

- blowing agent and results in energy efficiency properties that are comparable and in some instances better than HFC

- 134a. Vo and Fox from The Dow Ch emical Company pub lished a peer

- reviewed study, which noted, “... [T]hermal insulation performance of foams obtained with HFO

- 1234ze(E) and co

- blowing agents is very similar to those blown with HFC

- 134a produced today.” 14 Jackon has been selling boards in th e EU with energy efficiency that is bett er than HFC

- 134a since mid

- 2011 and four other EU customers are using HFO

- 1234ze(E) commercially. A major Japanese producer has also been commercially been selling boards made with HFO

- 1234ze(E)

.
Table 6

. Comparison of Energy Efficiency Performance of Foam Blowing Agents 15 **Blowing Agent CO**  **2 HFC** 
**- 134a**  **HFO**
**- 1234ze(E)** 

Aged lambda (lower = better) 34

- 38 29

- 30 27

- 30 % improvement over CO 2 — ~12

- 15% ~12

- 20%

In addition to HFO

- 1234ze(E) , which offers comparable or better energy efficiency as HFC

- 134a in XPS, companies like The Dow Chemical Company have commercialized other solutions to improve energy efficiency with CO 2 . For example, Dow’s XENERGY technology, according to Dow , is the “[t]hermal insulation of the future. X ENERGYTM combines proven features of STYROFOAMTM with up to 20% higher insulating properties made possible by a

14 Vo and Fo x, Assessment of hydrofluoropropenes as insulating blowing agents for extruded polystyrene foams , J OURNAL OF C ELLULAR P LASTICS , 49, 423 (2013). 15 Honeywell analysis based on customer information.19 new manufacturing process using CO 2 and reflecting particles in the foam cells. The result: reduced heating costs

- increase efficiency, comfort a nd sustainability. ” 16 Cost is another important criterion. The economics of boards produced with HFO

- 1234ze are also reasonable compared with boards produced with HFC

- 134a, especially as the cost of HFC

- 134a has risen recently due, in part, t o preliminary anti

- dumping rulings against Chinese imports by the Department of Commerce and the International Trade Commission. Honeywell estimates that XPS board made with HFO

- 1234ze(E) is likely to be no more than 5% to 9% more expensive than a comparable board made out of HFC

- 134a. b. HFC

- 134a in PU A pplications HFC

- 134a is also used ex tensively in PU foam in rigid applications, such as continuous and discontinuous panels, commercial appliance s , and spray foam. Honeywell is ready to support a transition date of January 1, 2016 for all PU applications except for two

- component low

- pressure spray foam, where we suggest the EPA finalize its proposed date of January 1, 2017. Across the various appli cations, a variety of solutions are available, including hydrocarbons, methyl formate, formic acid, methylal, HFO

- 1234ze(E) and HFO

- 1233zd(E) , and HFO

- 1336mmz. Both HFO

- 1234ze(E) and HFO

- 1233zd(E) have large

- scale U.S. manufacturing plants: Honeywell’s HF O

- 1233zd(E) plant began operating in May 2014 and HFO

- 1234ze(E) plant started up in September 2014. DuPont announced plans to start its HFO

1336mmz plant in the second half of 2016. Several customers in a variety of industries, including construction and commercial appliances have trialed HFO

- 1233zd(E) and HFO

1234ze(E) and are in various stages of transitioning to those substances. They are seeing benefits of not only significantly lower climate impact but also improved thermal insulation performance. HFC

- 134a is used in three main PU foam applications, each of which is described below (and further described in comments by the Center for Polyurethanes Industry (CPI) and the American Chemistry Council):

x Low

- pressure one - component foams : Honeywell’s HF O

- 1234ze(E) has been commercially sold in the EU in low

- pressure one - component foam since 2008 by companies like Dow, Fomo, Saudal. Hydrocarbons are also used extensively in these applications.

x Low

- pressure two

- component foams used in commercial appliance and other pour app lication s : Customers have several solutions that are low

- GWP and acceptable under SNAP, including Honeywell’s HFO

- 1233zd(E) and HFO

- 1234ze(E)

.

x Low

- pressure two

- component spray foams : Honeywell’s HFO

- 1233zd(E) and HFO

1234ze(E ) product and blends thereof are being technically proven in this application by several customers, several of whom are optimizing the product.

16 http://www.dow.com/products/market/construction/product

- line/xenergy

- extruded

- polystyrene

insulation/20 Overall, across all foam applications, including XPS and PU foams, customers have either commercialized non

- HFC

- 134a solutions or have technically feasible solutions ready for commercialization, and there are sufficient number of SNAP

- acceptable solutions to enable customers to transition to low

- GWP substances relatively quickly. The relative cost of transition to low

- GWP substances compared to continued use of HFC

- 134a has decreased dramatically, due in part to the rising costs of HFC

- 134a imported from China. Thus, Honeywell supports listing HFC

- 134a as unacceptable by January 1, 2016, rather than January 1, 2017 , for all foam applications, except low

- pressure two

- component spray foam. For low

- pressure two

- compo nent spray, we support EPA ’s proposal to list HFC

- 134a as unacceptable, effective on January 1, 2017. 3

. High

- P ressure Spray Foam Ap pl ications for PU F oams Currently, EPA does not propose to list as unacceptable any substances used in high

pressure spray foam applications, such as HFC

- 143a, HFC

- 245fa, HFC

- 365mfc and blends thereof. In Honeywell’s view, this is the easiest and quickest application to transition, as demonstrated by transitions by several customers noted below. For example, high

- pressure spray foam was one of the last applications that Hone ywell started to commercialize with customers, but the first low

- GWP product commercialize d in the U

. S

. was in a spray foam application with West Development Group . Honeywell strongly supports listing HFC

- 143, HFC

- 245fa, HFC

365mfc and blends there of as unacceptable in high

- pressure spray foam. Including high

- pressure spray foam will offer additional savings of 7 million MtCO 2 e per year , which is approximately an additional 20% in CO 2 savings before 2020 compared to what is included in the proposed rule. Several low

- GWP and non

- flammable alternatives have been listed as acceptable under SNAP for use in spray foam applications. Honeywell has been selling HFO

- 1233zd(E) commercially in this application since March 2013 in the U.S. and globally. HFO

- 123 3zd(E) was also successfully trialed in Philippines by UNIDO in 2012, almost two years ago . In the U.S., several customers, including small businesses such as Lapolla industries, West Development Group and Elas tochem, have commercialized low

- GWP spray foa m formulations containing HFO

- 1233zd(E)

. There have been several case studies, attached to these comments as Appendix IV, demonstrating the capabilities of HFO

- 1233zd(E) in spray foam applications. I n Japan, spray foam made with HFO

- 1233zd(E) has been commercialized by numerous customers including Toyo, Asahi , and BIP. In our experience, in the U

. S

. , it took just 6

- 18 mo n ths from start of development to a formulated system that was technically and commercially saleable, with all the requisite regulatory approvals . Further, several U

. S

. customers are close to commercial system s and will be undergoing product certification shortly. We expect the commercialization timelines to continue to shorten. The supply chain of additives (catalysts, surfa ctants) has also developed substantially, so customers have a wide variety of components to formulate with HFO

- 1233zd(E)

. As another proxy for how quickly spray foam can transition, recently, when new materials such as HFC

- 365mfc blends have come to marke t, the industry has indicated that it can transition rapidly, typi cally in less than six months.
L ow - GWP alternatives in spray foam applications are high performance, low cost, and in ample supply. C ustomers who have already commercialized low

- GWP spray foam based on HFO

- 1233zd(E) are seeing benefits of better energy efficiency as well as reduced cost. HFO

1233zd(E) has demonstrated better yields (more foam per pound of liquid component) by as21 much as 10

- 12%, which results in large cost savings. I n addition, these foams have shown 4 % to 8% improved energy efficiency, which means that customers can either improve the energy efficiency for the same thickness of foam or reduce the th ickness to further bring down cost. On a total life

- cycle analysis ba sis, which includes both direct and indirect GWP, foams with HFO

1233zd(E) are shown to reduce CO 2 e life

- cycle emissions by up to 90%. 17 EPA should thus include spray foam applications in this rule. These alternatives are available to supply the U.S. market. Honeywell’s HFO

- 1233zd(E) larg e - scale plant started up in May 2014 and DuPon t announced plans to start its HFO

- 1336mmz plant in the second half of 2016. 18 Given the availability of low

- GWP solutio ns, the ability of the industry to transition easily and quickly, and the b enefits that go well beyond low

- GWP , such as better energy efficiency and lower costs, H oneywell urges EPA to list high

- GWP compounds such as HFC

143a, HFC

- 245fa, and HFC

- 365mfc, an d blends thereof, as unacceptable in spray foam applications beginning January 1, 2018. Inclusion of high

- pressure spray foam in the rule will offer additional savings of about 7 million MtCO 2 e per year. 4

. Other Applications (Transport, Marine, S pe cialized refrigerators, etc.)/Exemptions For P U F oam T he EPA proposed rule is expansive with respect to foam applications, except for a few applications like military and aerospace. In Honeywell’s experience, the ava ilable solutions, including HFO

- 1233zd(E ) , HFO

- 1234ze(E) and others that are acceptable under SNAP have been commercializ ed in a number of applications such as spray, panel, appliance, etc. The formulation knowledge from those applications is easily transferable to other applications such
as marine, road and sea transport, continuous or discontinuous panels, integral skin, flexible foam, etc. EPA might receive comments from customers and industries in more niche applications, such as medical refrigerators and boats, which typically do not en gage in serious product development until after regulatory actions are near final . We do not believe that the technical and approval requirements of these industries present any serious challenges, and in fact, in some cases, such as flotation foams for bo ats, the technical requirements may be much simpler than other industries in which customers are already transitioning. We do not believe that any new exemptions, other than those already identified by EPA above for aerospace and military are necessary. 5

. Products Containing HCFCs and HFCs EPA proposes to extend its unacceptability determinations to foam blowing agents contained in the cells of closed

- cell foams and to foams and products containing them, as well as the use of the foam blowing agent in manufacture of those products. Honeywell supports EPA’s p roposal, but would like to the A gency to further define and specify its position on the

17 Bogdan and Pascual, Environmental assessment of next generation blowing agent technology using Solstice LBA in ccSPF, Polyurethane Magazine, 5 (2012). 18 http://www.gupta

- verlag.com/general/news/industry/14939/dupont

- fluorochemicals

- announces - world

s - first

- full

- scale

- production

- of

- hfo

- 1336mzz/pdf

.22 refrigerated containers and trailers industry. Refrigerated containers and trailers are used to transport food, medicine, other perishables, and may be manufactured with products that are classified as acceptable today but unacceptable in the future. The se refrigerated containers and trailers travel through country borders and are used in service from 5

- 10 years, and then sold at the end of their life for use as storage, living, or other applicat ions. Honeywell would like EPA to clarify in the final rule that refrigerated containers and trailers containing unacceptable blowing agents that were manufactured before the status change date are allowed to be in transi t and are to be sold in the U

. S

. (for example at the end of their life) after the status chang e date. In addition, EPA is also proposing to prohibit import of products containing foams blown with unacceptable substitutes, such HCFC

- 141b, 60 days after the issuance of the final rule. Honeywell strongly supports EPA’s position, since prohibiting imports of products containing foam blown with HCFCs will not only benefit the environment by reducing use of an ozone depleting substance , but also to maintain U.S. jobs and improve the competitiveness of U.S. companies who will not have to compete with i mports of products made with substances that are not only ozone

- depleting, but also less expensive . Honeywell believes it would be helpful for EPA to clarify the timing of prohibition as it would apply to products containing HCFCs and HFCs further in Sect ion 2c of Foam Blowing Agents or elsewhere. Our understanding is that: a) imports of products containing foams with HCFCs would be prohibited 60 days after the issuance of the final rule; and b) imports of products containing foams with HFCs would be prohi bited on the effective date of the unacceptability listing for those HFCs.
6

. Open Cell F oams/ Flexible foams EPA also seeks comment on whether it should consider the unacceptability determinations for foam blowing agents to apply to open cell foam and pro ducts containing open cell foam. Honeywell is aware of only one open cell application that uses a blowing agent other than water: flexible polyurethane. The most widely used blowing agents are CO 2 , acetone and methylene chloride. On review of the various SNAP approval tables through the past transitions (CFCs to HCFCs and HCFCs to HFCs), it is not clear whether or not methylene chloride is approved under SNAP. Honeywell supports EPA’s current position in the proposed rule to list select HFCs as unacceptable but also recommends that EPA list as unacceptable methylene chloride, consistent with the August 15, 2014 Nation al Emission Standard for Hazardous Air Pollutants final rule , 19 disallowing methylene chloride in flexible foams because it is a hazardous air pollutant. Our belief is that methylene chloride is not widely used in foam blowing applications in the U.S., but it is used to a large extent abroad, particularly in China, in the manufacture of flexible po lyurethane products subsequently exported to the U.S. Honeywell believes EPA should list methylene chloride and products containing foam blown with methylene chloride as unacceptable, starting 60 days after the issuance of the final rule.

***

19 79 Fed. Reg. 48073 National Emission Standards for Hazardous Air Pollutants Residual Risk and Technology Rev iew for Flexible Polyurethane Foam Production (Aug. 15, 2014) (available at http://www.gpo.gov/fdsys/pkg/FR

- 2014

- 08

- 15/pdf/2014

- 18734.pdf).23 As shown in the tables below, foam customers are already transitioning away from high

GWP substances, and are seeing benefits in addition to lower climate impact, including higher energy efficiency and lower cost. Table 7 . Announceme nts from Customers Adopting Low

- GWP Alternatives in Foam Applications
**APPLIANCE FOAM**  **Company Date**  **Headline** Whirlpool Aug. 15, 2012 Whirlpool Corp. Leaps Ahead of Industry Standards, Committing to Use Honeywell’ s Solstice Liquid Blowing Agent Whirlpool (WHR Release) Aug. 15, 2012 Whirlpool Corporation and Honeywell Introduce Most Environmentally Responsible and Energy Efficient Insulation Available into U.S. Made Refrigerators Midea Nov. 5, 2013 Midea to Adopt Honeywell’s Next

- Generation Insulating Materials in Energy Efficient Refrige rators Whirlpool (WHR Release) Jan. 22, 2014 Whirlpool Corporation Partners with Honeywell, Announces Use of Next Generation Solstice® Liquid Blowing Agent in U.S. Refrigerators Midea July 8, 2014 Honeywell Will Help Reduce Climate Impact of Refrigerators and Freezers in China BASF (BASF Release) July 24, 2014 BASF, Honeywell and Whirlpool bring the first commercial polyurethane insulation system using HFO blowing agent to market Haier Sept. 18, 2014 World’s Largest Appliance Manufacturer to use Honeywell’s Low

- Global

- Warming

- Potential Insulating Material in Energy

- Efficient Refrigerators

**SPRAY FOAM**  **Company Date**  **Headline** West Roofing Sept. 19, 2013 Honeywell’s Solstice Liquid Blowing Agent Used in New, Highly Durable Roof for Cleveland Airp ort Achillles Feb. 24, 2014 Leading Japanese Company to Use Honeywell’s L ow - Global

- Warming

- Potential Blowing Agent for Spray Foam Insulation Lapolla July 28, 2014 Lapolla Industries is the First Globally to Incorporate Honeywell’s Solstice Liquid Blowing Agent for Spray Foam Wall Insulation Whirlpool, Lapolla Sept. 12, 2014 Honeywell’s Low

- Global

- Warming Material Insulates Net

- Zero Energy Home Project at Purdue University

**PANEL FOAM Company**  **Date Headline**  Kingspan May 20, 2014 Leading Insulation Company to use Honeywell’s Low

- Global

- Warming

- Potential Blowing Agent24 **E. AEROSO**  **LS** Honeywell supports EPA’s proposal for aerosol applications, but believes it can be strengthened by (1) closing potential loopholes, (2) further restricting the sell

- through period, and (3) expanding the proposed rule to include additional applica tions for which preferable, low

GWP alternatives are already readily available. EPA proposes to list some HFCs as unacceptable in targeted aerosol applications by January 1, 2016. Honeywell agrees with EPA that history shows the aerosols industry can convert qu ickly to alternatives with very limited equipment changes and capital expenditures, especially when drop

- in replacements are available, as they are now. Customers have several options from Honeywell and others that are listed as acceptable under SNAP and are currently available. A significant number of customers in the U.S. and internationally (in both Europe and across Asia) have already adopted HFO

- 1234ze(E) , and have commercialized products or have shelf

- ready prototypes. 20 Strong regulatory action wil l continue to drive broad conversion to available lo w - GWP alternatives in the U.S. Adoption of Honeywell technologies in the aerosols sector in the U.S. could reduce greenhouse gas emissions by more than 6 million M t CO 2 e per year in 2016

. 1. Supply Honeywell has invested signif icant capital ($33 million) at its Baton Rouge, Louisiana manufacturing facility to ensure high

- volume manufacturing capability for HFO

- 1234ze(E)

. 21 , 22 As announced on September 16, 2014, construction of the plant has been compl eted and commercial operations began in Q3 of 2014. 23 The investment provides more than sufficient capacity to m eet growing demand for this low

- GWP product and would support the actions and timelines proposed by EPA.
2. Flammability The proposed rule state s that “at slightly higher temperatures (30oC or 85oF), HFO

1234ze(E) exhibits lower and higher flammability limits and could catch fire under specific conditions of concentration and in the presence of a high energy spark or flame.” While it is accurate to say that HFO

- 1234ze(E) may exhibit vapor flame limits at elevated temperatures, that is only one of many properties that must be taken into consideration when characterizing HFO

1234ze(E) and its usefulness in formulating non

- flammable aerosol products. 24

20 See Appendix III to these comments. 21 http://honeywell.com/News/Pages/Honeywell

- To

- Invest

- $33

- Million

- In

- Louisian a - Facility.aspx 22 http://honeywell.com/News/Pages/Honeywell

- Announces

- Investments

- Of

- $200

- Million

- In

- Louisiana

Facilities

- Backed

- By

- Tax

- Incentive

- Framework

- Agreement.aspx 23 http ://honeywell.com/News/Pages/Honeywell

- To

- Increase

- Production

- Of

- Low

- Global

- Warming

Materials

- Reduce

- Hydrofluorocarbon

- HFC

- Production

- By

- Nearly

- Half.aspx 24 It bears noting that HFO

- 1234ze(E) is not the first fluorochemical product to exhibit flammability characteristics under certain conditions and still be used safely. HFC

- 134a, a widely

- used aerosol propellant, can become flammable when pressurized with air and exposed to strong ignition sources.25 HFO

- 1234ze(E) is classified as a UN 2.2 non

- flammable liquefied gas. That determination is based on testing by ASTM E 681 and ISO 10156:2010 standards. It has also been tested by the EC testing method A 11 (Flammability of Gases) and found to be non

flam mable. HFO

- 1234ze(E) does not meet the National Fire Protection Association ( NFPA ) definition of a flammable gas or flammable liquefied gas found in NFPA 55. (NFPA does not specifically define a non

- flammable liquefied gas.) HFO

- 1234ze(E) was also tested to determine its minimum ignition energy (MIE). MIE is the minimum spark energy required to ignite a substance under the test conditions. The standard test is run at room temperature. HFO

- 1234ze(E) could not be ignited in that test. At a t emperature of 130 0 F, the MIE was greater than 61,000 millijoules. That is considered to be a very high value. For comparison, the MIE of propane is 0.25 millijoules and HFC

- 152a is 0.38 millijoules. A static electric discharge, from a person for example, will typically not exceed 10 millijoules. In addition to tests carried out on neat HFO

- 1234ze(E) , aerosols containing HFO

1234ze(E) have been tested using the standard aerosol flammability test methods

– flame extension, ignition distance , and enclosed spa ce ignition (closed drum test)

– and found to be
non - flammable by all of those methods. Honeywell has also carried out some non

- standard tests such as spraying a HFO

- 1234ze(E) aerosol, both liquid and vapor, into a red

- hot crucible at a temperature of grea ter than 900 0 F. No ignition, flash , or other activity was observed. The aerosol flammability tests described so far were conducted internally or at outside laboratories using HFO

- 1234ze(E) aerosol samples prepared by Honeywell. Honeywell has also had flam mability tests run on products provided by customers. One example is an aerosol used in a product known as a “blast bag .” The product consists of an inflatable bag containing an aerosol can of propellant with a total

- release valve. Blast bags are used in mining to seal a bore hole and provide a stable, effective deck for loading explosives. The valve is activated and the bag is lowered into the bore hole. Aerosol cans from blast bags were submitted for enclosed space ignition testing. This example is relev ant because the cans contained only HFO

- 1234ze(E) and because the enclosed space ignition test is particularly sensitive. The results showed the samples to be non

- flammable. One likely use of HFO

- 1234ze(E) is in aerosol tire inflators. Because of past acci dents traced to the use of flammable tire inflators, there is great concern over demonstrating that there is no flammability hazard associated with servicing a tire containing a “non

- flammable” tire inflator. This requires a different type of testing to cr eate the conditions that exist within an automobile tire (temperature, pressure, etc.) and to utilize the likely ignition sources that may exist during servicing. The two that are most often identified are a torch applied to the rim of the tire and a spark within the tire created by a metal reaming tool scraping a steel belt in the tire. Testing was carried out by a third party laboratory using commercial

- quality, HFO

- 1234ze(E) tire inflators supplied by a filler/marketer of those products. The test matrix was designed to include normal and worst

- case scenarios. The HFO

- 1234ze(E) tire inflators were found to be
non - flammable. HFO

- 1234ze(E) aerosols are currently being filled in the U.S., Europe , and Asia. Honeywell is not aware of any plant or equipment modifications related to flammability concerns undertaken by fillers in converting from HFC

- 134a to HFO

- 1234ze(E)

. Furthermore,26 we note that there are non

- flammable HFO

- 1234ze(E ) aerosol products already commercially available or shelf

- ready in many categories, including, but not limited to: dusters, freeze sprays, tire inflators, horns, defluxers, party string, and smoke alarm testers. In a testimonial discussing a new line of HFO

- 1234ze(E) dusters and freeze sprays, Ms. Jade Bridges, a technical support specialist at HK Wentworth Ltd., noted that the non
- flammable qualities of HFO

- 1234ze(E) , along with its environmental properties, made it a viable alternative to HFC

- 134a. 25
3. Vapor Pressure EPA states in the proposal that the vapor pressure of HFO

- 1234ze(E) is lower than that of HFC

- 134a. Propellant pressure is a key property that must be taken into account when developing an aerosol product. Honeywell notes, however, that th e lower vapor pressure of HFO

- 1234ze(E) has not prevented the development of a wide variety of HFO

- 1234ze(E) aerosol products such as dusters, freeze sprays, and horns

– in which the propellant is the only ingredient

– as well as formulated aerosols such as defluxers, tire inflators, novelties, smoke detector testers, and others. In an article published in Aerosol Europe , Ms. Virginie Fourneau of Inventec Performance Chemicals suggests that the vapor press ure of HFO

- 1234ze(E) is actually better than that of HFC

- 134a for aerosol formulation. 26
4. Conversion Requirements While it is not possible to address potential conversion requirements under all possible circumstances, Honeywell is not aware of any special or costly modifications undertaken at any of the locations at which HFO

- 1234ze(E) aerosols are currently being filled. This was confirmed in a recent conversation with a U.S. filler of technical aerosols who has been using HFO

1234ze(E) for several years. Conversion costs were described as being “minimal.”

x One

- Time Costs : Based on customer conversions that have occurred to date, and discussions on pending conversions, it is not anticipated that there will be any capital costs required to convert an aeroso l filling line from HFC

- 134a to HFO

- 1234ze(E) . In some instances, a nominal expense might be required to replace gaskets and seals, but even this is uncertain because HFO

- 1234ze(E) is generally compatible with the same materials as HFC

- 134a.

x Aerosol Pack age Costs : In general, no changes in aerosol package components (i.e., cans, valves, actuators, dip tubes, etc.) are required when converting from HFC

- 134a to HFO

- 1234ze(E) . However, in at least one product category, it will be possible to use a less exp ensive package with HFO

- 1234ze(E) . Aerosols like dusters and freeze sprays, which contain only HFC

- 134a, exceed the allowable pressure for Department of Transportation (DOT)

- specified aerosol cans. Those products are packaged in specially permitted cans, which cost approximately twice as much as a standard DOT 2Q can. A DOT 2Q can costs approximately $0.30 per unit, versus approximately $0.60 per unit for the more robust container. Dusters and freeze sprays containing HFO

- 1234ze(E) will not require the more expensive packaging because HFO

1234ze(E) has lower vapor pressure than HFC

- 134a.

25 http://www.honeywell

- s olstice

- propellants.com/ResourceCenter/Pages/Details.aspx?ItemID=2 26 Vol. 18, No. 11

– 201027 x Aerosol Product Costs : Historically, HFC

- 134a prices have been very volatile because of supply/demand imbalances, and have ranged from $2.00 per pound to nearly $6.00 per pound. Based on current HFC

- 134a pricing, the price of HFO

- 1234ze(E) at full commercialization is expect ed to be approximately 1.5

- 2 times the price of HFC

- 134a. The incremental cost to use HFO

- 1234ze(E) in an aerosol will depend upon the propellant concentration, which will typically range from 100% (as in a duster or freeze spray) to as low as 20

- 25% in a formulated aerosol product like a cleaner or mold release.
5. Availability of Products N ot Containing HFC

- 134a Honeywell agrees that many of the aerosol product classes in which the use of HFC

- 134a will continue to be acceptable under the current proposal are both necessary and useful. However, in some categories, such as cleaning products for electronics, sprays for aircraft maintenance, and dusters, there are either commercially available products or shelf

- ready products that have not yet been commercia lized that do not contain HFC

- 134a or any other high

GWP propellant. Many of these products do contain HFO

- 1234ze(E) , but several contain other propellants. 27 We believe that the continued availability of products containing HFC

- 134a in these categories w ill serve as a disincentive for companies to develop and market lower

- GWP versions of those products. This was demonstrated at the August 1, 2014 Small Business Administration Roundtable by a commenter noting that they had not started reformulating their product simply because there was no regulation making it necessary to do so.
6. Open

- Ended Sell

- Through Period EPA has proposed a sell

- through period to prevent “stranded inventory .” The sell

- through period would allow inventory produced prior to January 1, 2016 to be sold, imported and exported after that date, even if the product is classified as an unacceptable use of HFC

- 134a. Honeywell does not object to a sell

- through period to prevent stranded inventory, but allowing continued sale of unacceptable product without an end

- date wo uld delay the transition to low

GWP substitutes, and disadvantage small businesses that are unable to carry large inventories. Honeywell thus proposes th at EPA prohibit the sale, import and export of aerosol products manufactured with unacceptable substitutes by no later than January 1, 2017 , thereby allowing manufacturers a year to transition their inventory. Honeywell also proposes that the sell

- through period should apply only to products that were manufactured prior to January 1, 2016 and that have entered the distribution channel. Honeywell believes that extending the sell

through period to manufacturers, especially with an open

- ended sell

- through peri od, serves as a disincentive f or the timely conversion to low

- GWP substitutes.
7. Additional Product Bans Honeywell does not believe there is sufficient justification to allow continued use of HFC

- 134a in duster sprays for photographic negatives, semicon ductor chips, and specimens under electron microscopes. Honeywell believes that eliminating these uses of HFC

- 134a is practical because of the commercial availability of dusters containing alternate prop ellants such

27 See the table “Summary of Honeywell Position

— Aerosols” at page 5

- 7, above.28 as HFC

- 152a and HFO

- 1234ze(E). Further more, since dusters are often distributed through channels over which the marketer has no control, this special exemption creates a loophole whereby a duster labeled for an exempt use could be purchased and used for other applications. As a practical examp le, California regulations allow HFC

- 134a dusters to be used only on energized electrical equipment, and cans are so labeled. However, it is possible to purchase an HFC

- 134a duster from an online catalog for delivery to an address in California without an y restrictions or questions about the intended end

- use. Honeywell believes that the special exemption for duster sprays for photographic negatives, semiconductor chips, and specimens under electron microscopes creates a loophole without any demonstrated o ffsetting benefit. Honeywell also proposes that EPA list HFC

- 134a as unacceptable for use in cleaning products for removal of flux and other soils from electrical equipment and electronics. There are numerous examples of available defluxers containing alt ernative propellants, including non

flammable propellants such as HFO

- 1234ze(E)

. 28

*** As shown in the table below, aerosol customers are already transitioning to low

- GWP substances

. Table 8 . Announcements from Customers Adopting Low

- GWP Alternatives in Aerosol Applications **Company Application**  **Date Headline**  Mission Pharmacal Personal Care Sept. 17, 2014 Dr. Smith’s® Goes to Washington to Participate in White House HFC Industry Leadership Roundtable Home Safeguard Industries (HSI) Smoke Alarm Tester Dec. 2013 Home Safeguard Industries Chooses Solstice® Propellant for Fire Safety Testing

Microcare Dusters May 28, 2009 Honeywell's New Propellant Reduces Global Warming Impact of Aerosol Cleaners in Europe by 99 Percent Falcon Safety Dusters Feb. 28, 2011 Dust

- Off® Non

- Flammable ECO Duster Set for U.S. Launch
Solchim S.p.A. Novelty Aerosols 2009 Solchim S.p.A., Specialty Aerosols Company, Replaces R

- 134a with Solstice® Propellant

HK Wentworth Group Dusters / Freezer Sprays Jan. 2012 HK Wentworth Group, an industrial products company selling to markets around the world, leverages the low carbon benefits of Solstice® Propellant in it s air

- dusters and freezer sprays Produits Sanitaires Aeronefs (PSA) Airplane On

Board Insecticide May 2012 Solstice® Takes Flight

28 See Appendix III.29 MTi Group Mining Products August 2013 MTi Group Chooses Honeywell Solstice® Propellant for Inflatable Mining Products

Electrolube Duster Spray for Electrical and Electronic Equipment July 21, 2011 Electrolube Exhibits “Green Products” at AATE

**III. CONCLUSION**  Thank you for this opportunity to share our commen ts on the proposed r ule. Honeywell is stron gly supportive of EPA’s proposal , and believes that the time to act is now so that the U.S. can lead the rest of the world in transition ing away from high

- GWP compounds

. If you have any further questions, please do not h esitate to contact: Ken Gayer at kenneth.gayer@h oneywell .com, Amy Chiang at amy.chiang@h oney well.com, or Dave Stirpe at d avid .stirpe@h oneywell.com

.30 

## APPENDIX **I Alternative**  **Products for Refrigerant A pplications** 

**A. Mobile Air**  **Conditioning (MAC)**

– **Solstice® MAC (HFO**
**- 1234yf)** 

x In use in nearly two million cars globally

x 99 .9 % reduction in GWP compared to HFC

- 134a

x More efficient than CO 2

x 28 different automobile brands are selling approximately 60 different models in the world designed to use HFO

- 1234yf. U.S.

- based companies, including Ford, GM, Chrysler, and Tesla are manufacturing more than a dozen models using HFO

1234yf. 29

29 This data is from a list compiled by the Institute for Governanc e and Sustainable Development (IGSD) (Oct. 12, 2014) (Sources include Deutsche Umwelthilfe, Mobile Air Conditioning Society (9/19/2014), EU Stakeholder Meeting (11/2013) and IGSD communication with MVAC experts. **Company ,**  **Product Name Product Photo** 
General Motors

Cadillac XTS, others

www.gm.com Chrysler Corporation

Jeep Cherokee, others www.chrysler.com31 

### B. **Vending Machines**
**- HFO** 
**- 1234yf** 

x In use by two manufacturers in Japan

x 99% reduction in GWP compared to HFC

- 134a

x More efficient than CO 2 , safer than hydrocarbons

**Company Product Photo**  Kubota Corporation

www. **kubota**

global.net/ **vending** /english/

Fuji Electric

www.fujielectric.com32 

### C. **Chillers**

– **Solstice® zd and Solstice ®**  **ze (**  **HFO**
**- 1233zd(E)**  **and HFO** 
**- 1234ze(E)**  **)**

x Appro ximately 99% reduction in GWP compared to HFC

- 134a or HCFC

- 123

x Chillers are 10% more efficient than best chillers today.

**Company, Product Name**  **Product Photo**

Trane

– HFO

1233zd (E) Centrifugal Chiller http://www.trane.com/ commercial/north

america/us/en.html
Climaveneta

- HFO

1234ze (E) Chiller http://www.climavenet a.com/

Airedale

- HFO

1234ze (E) Chillers

www. **airedale** .com

Geoclima

– HFO

1234ze (E) Chiller www.geoclima.com

Star Refrigeration

– HFO

- 1234ze (E) Chiller http://www.star

ref.co.uk33 

### D. **Commercial Refrigeration**
**- Solstice® N** 
**- 40** 

x GWP of N

- 40 is 67% l ower than R

- 404a while delivering higher efficiency

x Oak Ridge National Labs testing show s 11.6% increase i n the coefficient of performance compared to R

- 404A

x Copeland testing shows 3

- 8% higher efficiency than R

- 404A

**Company, Product Name Logo or Product Photo**  Oak Ridge National Labs

http://www.ornl.gov

Copeland

– Emerson Climate Technologies http://www.emersonclimate .com/en

us/brands/pages/copeland.as px34 

## APPENDIX II **Alternative P**  **roducts for HFC**
**- 134a, HFC** 
**- 245fa and HFC** 
**- 365mfc**  **Foam A pplications** 

**A. One Component F**  **oam**

x HFO

- 1234ze(E) in one

- component foam, replacing HFC

- 134a

x Commercial in EU since 2008

**Company, Product Name Logo or Product Photo** 

Product Name:35 

## B. **Extruded Polystyrene (XPS)** 

x HFO

- 1234ze(E) in extruded polystyrene foam, replacing HFC

- 134a and HFC

- 152a

x Commercial in EU since 2010 and Australia, Japan since 2014

**Company, Product Name**  **Logo or Product Photo**

Product Name:36 

## C. **Continuous Panels**

x HFO

- 1234ze(E) and HFO

- 1233zd(E) replacing HFC

- 134a, HFC

- 245fa, HFC

- 365mfc, and hydrocarbons

x Commercial in EU since early 2014, commercialization imminent in US

**Company, Product Name**  **Logo or Product Photo** Kingspan (EU)

x phenolic boards for residential insulation

All Weather Insulated Panels (US)

x Insulated metal panels for industrial construction and cold storage.37 

## D. **Domestic Appliances**

x HFO

- 1234ze(E) and HFO

- 1233zd(E) replacing HFC

- 134a, HFC

- 245fa and HFC

365mfc/227ea

x Commercial in US, Mexico, China; imminent in EU

**Company, Product Name**  **Logo or Product Photo Adoption complete /**  **underway:** Whirlpool (US / Mex), Midea (China), Festivo (Finland), Haier (China)38 

## E. **Commercial Appliances**

x HFO

- 1234ze(E) and HFO

- 1233zd(E) replacing HFC

- 134a, HFC

- 245fa and HFC

365mfc/227ea

x Commercial in EU, Japan; imminent in US, Mexico

**Company, Product Name**  **Logo or Product Photo Adoption complete**  **/ underway:** Porka (Finland), Okamura (Japan)

**Trials Nearing Completion:**  (company names confidential) US / Mex, US, Japan39 

## F. **Spray Foam**

x HFO

- 1234ze(E) and HFO

- 1233zd(E) replacing HFC

- 134a, HFC

- 245fa and HFC

365mfc/227ea

x Commercial in US, Japan; imminent in EU

**Company, Product Name**  **Logo or Product Photo** Lapolla (US), West Development Group (US), Soflanwiz (Japan), Nihon Puftem (Japan), BIP (Japan) Cleveland Airport (Company: West Development Group)

Purdue house (Company: Lapolla industries)

Philadelphia Water Treatment Facility (Company: West Development Group)

Nihon Puftem Announcement Toyo Tire (Soflanwiz) Announcement40 

## APPE **NDIX III Alternative**  **Aerosol Products For HFC**
**- 134a Applications** 

**A. Tire Inflators** 

x HFO

- 1234ze(E) based tire inflator

x At least 90% of the ma nufacturers are cur rently evaluating or have shelf

- ready product s

**Company, Product Name**  **Logo or Product Photo**
Technical Chemical Corporation, Tire Inflator41 

## B. **Dusters**

x All non

- flammable and recommended for use on electronics

x At least 90% of the manufacturers in the market have a commercialized product **Company, Product Name Logo or Product Photo**  Miller Stephenson, Aero Duster, http://www.miller

stephenson.com/low

- global

warming

- products/ Falcon, Dust

- Off ECO, http://www.amazon.com/indus trial

scientific/dp/B009L9A2X6

MicroCare, Big Blast EU, https://www.microcare.com/pr oduct

detail.html?xRefId=1&xRefIte mId=46&product_id=18

ITW Chemtronics , Typhoon Blast, Typhoon Blast All the Way, Typhoon Duster and Typhoon Surge, http://www.chemtronics.com/p roducts/product.asp?id=598
Techspray, ECO

- Duster, http://www.newark.com/techsp ray/1580

- 10s/eco

- duster

- spray bottle

- 253ml/dp/88T495042 

## C. **Safety Horns**

x HFO

- 1234ze(E) based non

- flammable safety and marine horns

x At least 90% of the manufacturers in the market have a commercialized product

**Company, Product Name Logo or Product Photo**  ECO Sonic Safety: For Marine as well, https://www.falconsignal.com/ shop/category/eco

- sonic

safety

- horn

ECO Sound Signal Horn: For Marine as well, https://www.falconsignal.com/ shop/eco

- sonic

- horn43 

## D. **Party Streamers**

x Non

- flammable option propelled by HFO

- 1234ze(E) , available in Europe

**Company, Product Name Logo or Product Photo**  Solchim, Party String

Xiomara, Party String, Snow Spray44 

## E. **Smoke Alarm Testers**

x Non

- flammable option propelled by HFO

- 1234ze(E)

x Major manufacturers are either currently evaluating or have commercialized product

**Company, Product Name**  **Logo or Product Photo** HomeSafe Guard, PurCheck , http://www.homesaf eguard.com/pur_che ck.html45 

## F. **Freeze Sprays for Tissue**

x Non

- flammable option propelled by HFO

- 1234ze(E)

x Many manufacturers have shelf

- ready product s or commercialized product s

**Company, Product Name Logo or Product Photo**  Miller Stephenson, Quick Freeze, http://www.miller

stephenson.com/low

- global

warming

- products/46 

## G. **Freeze Sprays for Electronics**

x Non

- flammable with HFO

- 1234ze(E)

x At least 90% of the manufacturers have a commercialized product **Company, Product Name, Link**  **Logo or Product Photo** Miller Stephenson, Quick Freeze, http://www.miller

stephenson.com/low

- global

warming

- products/ MicroCare, Circuit Chiller, https://www.microcare.com/pr oduct

detail.html?xRefId=1&xRefIte
m Id=49&product_id=58

Techspray, Freeze Spray, https://www.techspray.com/p

158

- eco - freezer.aspx

ITW Chemtronics, Freeze Spray, http://www.mcmelectronics.co m/product/CHEMTRONICS

ES1054

- /20

- 513047 

## H. **Additional: Industrial Cleaners and Rust Inhibitors**

**Company, Product Name, Link**  **Logo or Product Phot o** 

Miller Stephenson, Dry Lubricant, Precision Cleaning, Heavy Duty Solvent, Rust Inhibitor, http://www.miller

stephenson.com/low

- global

warming

- products/

Microcare, Flux R emover, https://www.microcare.com/pro duct

detail.html?xRefId=1&xRefIte mId=47&product_id=4448 

## I. **Additional: Other Products**

**Company, Product Name Logo**  **or Product Photo** Mission Pharmacal, Diaper Rash line of products, http://www.adultbarrierspray.com

Dental Ceramic Spray

Radio Systems Corp: Pet Training/Bark Control Product (Australia), http://intl.petsafe.net/intl/ch/products /bark

- control/spray MTi Mining Safety: Blast Bag (Australia), http://www.zero.mtigroup.com.au/
Fumakilla: Bug Control Product (Japan), http://www.fumakilla.co.jp49 

## APPENDIX I **V Case Studies of HFO** 
**- 1233zd(E) in Spray Foam and Appliance**  **Foam Applications**

x Solstice TM Liquid Blowing Agent “Takes Off” at Cleveland Hopkins International Airport

x Solstice TM Liquid Blowing Agent Receives Positive Review for Theater Roof Repairs

x Honeywell Solstice ® Liquid Blowing Agent: An Insulation Retrofit From the Outside

- In

x Solstice ® Liquid Blowing Agent Helps Philadelphia’s Quest to be “America’s Greenest City”

x Whirlpool Corporation, Case Study (April 2012)

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