DuPont appreciates the opportunityto participate in this hearing and to briefly present our initial views on the proposed change of status rule underthe Significant NewAlternatives Program. We would also like to recognize the significant stakeholder outreach that EPA engaged in duringthe development of this proposal, and the Agency's openness to the views ofall stakeholders
. We also applaud the White House and the Agency forthe timely action in developing this proposal in response to the President's Climate Action Plan
. As we stated at the beginning ofthe stakeholder outreach process, DuPont recognizes the need for concerted global action to avoid significant future growth in the greenhouse gas emissions associated w ith the use of HFCs in their various applications. That is why we are bringing low global warming potential, energy efficient products to market across various end uses. We also believe it is critical that in avoidingthose emissions we do so in a mannerthat ensures that we are still able to deliverthe critical societal services that HFCs provide today. Those include safe and energy efficient refrigeration, air conditioning, foam i nsulation, fire suppression, propellants and waste heat recovery. It is also importantthat we avoid those emissions in a mannerthat does not impede the global trade in these important products that is central to achieving our goals in a cost effective manner. The nature ofthe regulatory approach taken to avoid these future emissions will have a lotto do with how successfully we ach ieve our goals
. This is why we have strongly supported the Administration's efforts to amend the Montreal Protocol to employ the well understood and very effective tools ofthat Protocol to achieve the necessary transitions. We believe that the mechanics oftheProtocol would provide both a globally consistent framework for the transitions and the abilityto make cost-effective transitions while ensuring we can serve our markets properly. A patchwork of uncoordinated national and regional command and control regimes would be a much less effective model. Al 11c 

### liaoE obseu •ell IIFE-rienlll¥> we believe that EPA's SNAP authority can provide a reasonable down payment on the Montreal Protocol process by focusing on areas where technologytransitions are already underway and alternatives are already available orwill soon be, and action under SNAP can accelerate those transitions. As a 

### ge11ea al matte ...we thinkthe Montreal Protocol is a better tool for driving new transitions and long term reductions. As for the specifics ofthe proposed rule, we are still evaluating it and talking with our customers and other value chain participants and stakeholders, and will be submitting detailed comments. Based on our reviewto date, we generallythink the scope ofthe proposal is appropriate and reflects transitions underway in the market. There are some areas 

### 1such as motorvehicle air conditioning, where we thinkthe proposed timing actually lags the business as 

# ...

**~~\** usual market transition already underway, and others, such as in &eMe foam insulation segments, where we feel the proposed timing is faster than the market can reasonably manage. We lookforward to providing AW&h more detail in our written comments. In closing, we appreciate the opportunityto share our views, and believe that the proposed SNAP rule, with some adjustments, can be a helpful down payment on the broad market transitions to be achieved under an amended • Montreal protocol.



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