## EPA Comments May 22, 2015

This is written regarding the EPA August 6, 2014 proposed rulemaking, “Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program” , which would restrict many commonly used hydrofluorocarbons (HFCs). In particular these
comments below regard polyurethane spray foam insulation.

T hank you for the opportunity to present information to you that is vital to our industry. The issue is

more complex than at first glance and not just one insulatio n versus another or one blowing/expanding agent against another based on pure preference. It is about energy usage and efficiency and what is feasible with regards to the timetables to bring viable pro ducts to market in a manner that provides ample time for safe and proper development while protecting jobs and business growth

. It is really about risk and reward. Does speeding up the elimination of HFCs in spray foams by two years offer a huge impact. An d does that justify the risk of job loss, expense, potential for rushing and not doing the job right, and potential for economic impact such that home owners and building owners don’t insulate or insulate less efficiently so that energy usage is higher and thus carbon footprint is higher.

The main point is that p olyurethane spray foam insulation is the most efficient and energy saving insulation on the market. Studies are proven showing 40% savings in energy consumption versus other
conventional insulati ons. That means less carbon footprint which pleases the environmental ly
conscious . And it means energy savings, putting more money in consumer s pocket s to spend on other things which strengthens the economy. Doesn’t that lead one to think that it is import ant to get it right from a safety and performance standpoint to continue such gains. Allow us as an industry the reasonable timeframe to bring new products to market and do the job right.

Polyurethane foam insulation has been around since the 1970’s but i ts huge impact i s still in its infancy having been truly geared for residential and commercial buildings only over the last 10

- 12 years. It has had a great impact and has tremendous potential for reducing our energy consumption per capita. Don’t let it get derailed or embroiled in manufacturers’ maneuvering and manipulating the political and public emotional opinion.

Existing blowing agents are proven and have gone through the very onerous and complete testing process to insure proper performance and safety regarding exposure and fire. Next generation blowin g agents are on the horizon and will come in time. It is the timing that is of question. The existing timetable to eliminate HFC’s provides adequate time for research, development, testing, field trials, a nd full implementation. But rather than rush and push arbitrary deadlines, we implore you to act such that proper testing is done to insure that the right and best alternatives are allowed to come to market.

Currently, the next generation of blowing agen ts are in testing and each of us as manufacturers of spray foam systems are at different stages of development. Typical catalysts and surfactants do not work well with these next generation materials and shelf life is not adequate, less than half the neede d time for
the manufacture to end

- use cycle. There are currently two molecules by three different manufacturersin progress. One is currently available in small quantities with true viability a year away. It appears at

this time to be the least compatible with other components in the blended system. The other molecule thus far appears to be more compatible and offers better performance and its full production is 18

- 24 months away and even then supply may be limited by plant size.

At this point in time there just is not enough data by the formulators like us (who actually put the raw materials together in viable commercial products)to chart an absolute best path. Insulation saves energy big time and that means it is very important to get it right. Allow us th at time please.

There are numerous polyurethane foam manufacturing companies and many
, many more dist r ibutors and contractors employed in this industry. Most are small to medium sized companies. They are hard

working, tax

- paying people who contribute to t he economy as so many people do. But our industry has a unique position at this time in that it can greatly impact energy red uction and environmental impact especially if we are allowed to develop systems in a methodical, scientific method with a reasonable timetable allowing us to do it right. Because doing it right means decades of insulation and energy saving performance i n homes and commercial buildings, including schools and hospitals, which is indeed a big environmental impact.

Thank you for your consideration of our input regarding this important topic.

Sincerely,



## Mac Hess

President & C.E.O.
P remium Spray Products, Inc. Marietta, GA
770

- 528

- 9556

1255 Kennestone Circle Marietta, GA 30066 Phone: 770

- 528

- 9556 www.premiumspray.com