DuPont appreciates the opportunity to participate in this hearing and to briefly 

present our initial views on the proposed change of status rule under the 

Significant New Alternatives Program. We would also like to recognize the 

significant stakeholder outreach that EPA engaged in during the development of 

this proposal, and the Agency's openness to the views of all stakeholders. We 

also applaud the White House and the Agency for the timely action in 

developing this proposal in response to the President's Climate Action Plan. 

As we stated at the beginning of the stakeholder outreach process, DuPont 

recognizes the need for concerted global action to avoid significant future 

growth in the greenhouse gas emissions associated with 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 avoiding those emissions we do so in a manner that ensures 

that we are still able to deliver the critical societal services that HFCs provide 

today. Those include safe and energy efficient refrigeration, air conditioning, 

foam insulation, fire suppression, propellants and waste heat recovery. It is also 

important that we avoid those emissions in a manner that does not impede the 

global trade in these important products that is central to achieving our goals in 

a cost effective manner. 

The nature of the regulatory approach taken to avoid these future emissions 

will have a lot to do with how successfully we achieve 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 of that Protocol 

to achieve the necessary transitions. We believe that the mechanics of the 
Protocol would provide both a globally consistent framework for the transitions 

and the ability to 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 technology transitions are already underway and 

alternatives are already available or will soon be, and action under SNAP can 

accelerate those transitions. As a ge11ea al matte ... we think the Montreal 

Protocol is a better tool for driving new transitions and long term reductions. 

As for the specifics of the 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 review to date, we 

generally think the scope of the proposal is appropriate and reflects transitions 

underway in the market. There are some areas1

such as motor vehicle air 

conditioning, where we think the 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 look forward to providing AW&h more 

detail in our written comments. 

In closing, we appreciate the opportunity to 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 

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