1



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## ENVIRONMENTAL PROTECTION AGENCY 1

2

3

4



## Public meeting on 5



## Proposed Rule “Protection of Stratospheric 6



## Ozone: Change of Listing Status for Certain 7



## Substitutes under the Significant New 8



## Alternatives Policy Program” 9

10

11

12

13



## 9:14 a.m. to 12:11 p.m. 14



## Wednesday, August 27, 2014 15

16



## William Jefferson Clinton East Building 17



## Room 1153 18



## 1201 Constitution Avenue Northwest 19



## Washington, D.C. 20004 20

21

222



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## EPA STAFF: 1



## Cindy Newberg 2



## Gerald Wozniak 3



## Margaret Sheppard 4



## Chenise Farquharson 5



## Drusilla Hufford 6



## Luke Hall-Jordan 7



## Paul Horwitz 8



## David Donaldson 9



## David Godwin 10



## Jan Tierney 11



## Rob Landolfi 12



## SPEAKERS: PAGE 13



## Kevin Fay - Alliance for Responsible 14



## Atmospheric Policy 9 15



## Christopher Nitz - Danfoss 15 16



## Allan Thornton - Environmental Investigation 17



## Agency 18 18



## Douglas Fratz - Consumer Specialty Products 19



## Association 23 20



## Julie Becker - Alliance of Automobile 21



## Manufacturers 27 223



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## SPEAKERS (Cont'd): PAGE 1



## Dave Stirpe - Honeywell 32 2



## Robert McArver - Association of Home 3



## Appliance Manufacturers 36 4



## Michael Parr - DuPont 42 5



## Emily Davis - Natural Resources Defense 6



## Council 46 7



## John Ferraro - Extruded Polystyrene Foam 8



## Association 52 9



## Ron Shebik - Hussmann Corporation 56 10



## Peter Williams - New Era Group 62 11



## Mac Hess - Premium Spray Products 68 12



## Brian Casserilla - Kairak 72 13



## Mike Krupa - BASF 75 14



## Mary Dane - Traulsen 79 15



## Keilly Witman - Shecco America 83 16



## John Cabaniss - Assoc. of Global Automakers 88 17



## Stephen Schaefer - Hoshizaki America 92 18



## Michael Coyle - Bally Refrigerated Boxes 97 19



## Jason Paquette - Structural Concepts 101 20



## Terry Brooks - CrownTonka, ThermalRite 107 21



## Scott Lewit - Structural Composites 108 224



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## SPEAKERS (Cont'd): PAGE 1



## Paul Ramsbottom - American Panel 113 2



## Lee Thames - Thermo-Kool 117 3



## Charlie Souhrada - North American Assoc. of 4



## Food Equipment Manufacturers 122 5



## Karim Amrane - Air Conditioning, Heating, & 6



## Refrigeration Institute 127 7



## Kenny Owen - Master-Bilt Products 132 8



## Edward Bates - Pactiv Building Products 137 9



## Jose Avendano - Grindmaster-Cecilware Corp. 140 10



## Nathan Mouw - Whirlpool Corporation 144 11



## Karl Hielscher - Metl-Span 149 12



## Doug Raymond - National Aerosol Association 151 13



## Rick Heffernan - System Development 14



## Integration 153 15



## Richard Willey - Grindmaster-Cecilware Corp. 162 16

17

18

19

20

21

225



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## P R O C E E D I N G S 1



## 9:14 a.m. 2



## MS. NEWBERG: Okay. So welcome to EPA. 3



## This is a public hearing. So, I'm Cindy Newberg. 4



## I'm the Branch Chief for the Alternatives and 5



## Emissions Reductions Branch, which houses the 6



## SNAP Program. 7



## So welcome, and thanks for coming. We 8



## have quite a large turnout. Just to let you 9



## know, folks who are in the room from EPA, at the 10



## table, Gerald Wozniak, who will be giving 11



## speakers a one minute warning, and we'll get 12



## through that in a moment, Margaret Sheppard who 13



## is our SNAP Team Leader and Chenise Farquharson, 14



## who has organized this hearing for us today. 15



## Also in the room is Drusilla Hufford, who 16



## is the Division Director for the Stratospheric 17



## Protection Program, Luke Hall-Jordan, who is our 18



## refrigerants team lead, Paul Horwitz, who is the 19



## Deputy Division Director, David Donaldson who is 20



## the Branch Chief for the Stratospheric Protection 21



## Implementation Branch, and Dave Godwin will be in 226



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## the room in a moment, who is our refrigerants 1



## expert, and Jan Tierney, who is with our Office 2



## of General Counsel. 3



## I may have missed someone. I don't think 4



## so. Oh, and Rob Landolfi, who is a member of our 5



## SNAP Team and supporting this room. 6



## So this is a public hearing. The purpose 7



## of the hearing is to provide verbal comment on 8



## the proposed rule titled, “Protection of 9



## Stratospheric Ozone: Change of Listing Status for 10



## Certain Substances Under the Significant New 11



## Alternatives Policy Program.” 12



## The rule was published on the Federal 13



## Register on August 6th. Written comment is due 14



## by October 6th. The docket for the rule -- and 15



## there was information out front for folks who 16



## need additional information on how to provide 17



## comment to the docket -- is EPA-HQ-OAR-2014-0198. 18



## Providing verbal comment this morning 19



## does not preclude anyone from providing 20



## additional written comment. Verbal comment is 21



## being transcribed by a court reporter, who is 227



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## sitting behind me, Buck Johnson. If you have 1



## prepared versions of your oral comment and you're 2



## willing to provide it to Mr. Johnson, we would 3



## appreciate that. It will make sure that it's 4



## more accurately reflected in -- obvious it will 5



## all be accurately reflected, but to make sure we 6



## have everything quite as we want it to be. 7



## And just to be clear for folks, I think 8



## there were some people who had some questions and 9



## haven't participated in public hearings before. 10



## This is not an opportunity to ask the Agency 11



## questions. We're not positioned to answer any 12



## questions today. This is an opportunity to 13



## provide oral comment to the docket only. 14



## If you'd like to speak to EPA and have 15



## additional discussions, we're perfectly willing 16



## to set that up but it would be a separate 17



## meeting. It will not be happening today. 18



## A copy of the transcript from today's 19



## hearing will be made public. It will be part of 20



## our docket. And just to provide just some brief 21



## instructions to the speakers, which we'll start 228



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## with the speaking as soon as I finish this, 1



## please provide, when you start -- you've been 2



## provided with a number. That number, if you have 3



## preregistered to speak or if you registered on 4



## the spot, you were given a number. We'll be 5



## calling you in that order. 6



## When you start your testimony we would 7



## appreciate if you would state and spell your 8



## name, so we can make sure that it's correct in 9



## the docket. Also, state your affiliation. 10



## And to ensure all interested parties have 11



## an adequate opportunity to speak, we are sticking 12



## very strictly to a five minute time slot. If 13



## folks feel they didn't have sufficient time in 14



## that five minutes and they want to provide 15



## additional oral comment, and again you can 16



## provide written, at the end of the hearing we can 17



## come back and allow people who wanted additional 18



## time an additional five minutes. But we will be 19



## very clear about that. 20



## And Gerald is timing folks, and he has a 21



## one minute remaining sign that he will let you 229



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## know. 1



## UNIDENTIFIED SPEAKER: 2



## (Inaudible.)**11:37 3



## MS. NEWBERG: Yes. Short names need less 4



## time, right? 5



## With that, I'm going to hand it off to 6



## Chenise, who is going to go ahead and she will be 7



## calling each of the speakers up. 8



## MS. FARQUHARSON: Thanks, Cindy. Good 9



## morning everyone and thank you for being here. 10



## The first speaker is number one, Kevin Fay, the 11



## Alliance for Responsible Atmospheric Policy. 12



## MR. FAY: Good morning. Thank you. 13



## Kevin Fay, F-A-Y, the Alliance for Responsible 14



## Atmospheric Policy, and we appreciate the 15



## opportunity to speak here this morning. 16



## The Alliance is an industry coalition 17



## organized in 1980 to address the issue of 18



## stratospheric ozone depletion and the use of 19



## fluorocarbon compounds. Today the Alliance 20



## coordinates industry participation in the 21



## development of reasonable international and 2210



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## government policies at the nexus of ozone 1



## protection and climate change, and we're proud to 2



## continue its long history of working in a 3



## positive manner with EPA on the protection of 4



## stratospheric ozone and the mitigation of climate 5



## change. 6



## Our annual goods and services has been 7



## recently projected at $158 billion in the United 8



## States. 9



## We appreciate this opportunity to comment 10



## on the proposed change of listing status for 11



## certain compounds under the Significant New 12



## Alternatives Policy Program. While Alliance 13



## member companies will comment individually on the 14



## specific changes in listing status proposed in 15



## the rule, there are a number of broader concerns 16



## which are shared across the fluorocarbon 17



## producing and using sectors that we will touch 18



## upon. 19



## First, EPA has publicly stated its 20



## position as part of the North American Amendment 21



## proposals for the Montreal Protocol that it seeks 2211



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## to achieve a gradual phase down of HFC production 1



## and consumption on a GWP-weighted basis. EPA has 2



## supported the gradual phase down approach in 3



## order to allow for effective technology 4



## development and introduction to allow for the 5



## building codes and safety standards process to 6



## catch up with the newly available low-GWP 7



## compounds and technologies and to ensure 8



## continued improvement of energy efficiency 9



## performance where relevant. 10



## The Alliance supports these goals. As 11



## announced earlier this year, the Alliance also 12



## supports the negotiation of such an amendment to 13



## the Montreal Protocol as the best means of 14



## achieving ozone and climate environmental 15



## objectives while considering performance, safety, 16



## energy efficiency and technology availability. 17



## The Alliance is concerned that in many 18



## cases the transition dates in the proposed rule, 19



## however, are inconsistent with EPA's stated 20



## notion that there should be a gradual phase down 21



## of HFCs. With the proposed rule not likely to be 2212



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## finalized before the first or second quarter of 1



## 2015, the proposed transition deadlines in 2016 2



## and 2017 are not feasible, in many cases 3



## impossible, for companies and inconsistent with 4



## this notion of a gradual phase down as stated by 5



## the Agency. 6



## Second, the Alliance believes that the 7



## SNAP rulemaking schedule should be better 8



## coordinated with the ongoing DOE energy 9



## efficiency rulemaking schedules. The proposed 10



## modifications have significant energy efficiency 11



## implications, whether for foam insulation or air 12



## conditioning and refrigeration equipment. Any 13



## proposed changes to SNAP listing status should 14



## ensure that the alternatives whose use is being 15



## encouraged by the changes meet the requirements 16



## of stringent new DOE efficiency standards that 17



## are to be promulgated over the next several 18



## years. 19



## Given the important energy efficiency 20



## consequences of this proposed rule, it is unclear 21



## how this action will meet the statutory standard 2213



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## of no greater risk to human health and the 1



## environment. By forcing previously acceptable 2



## substitutes off the market, these proposals could 3



## in fact result in less efficiency, not more, in 4



## the near term. Change of status determinations, 5



## in most cases, should not be made based on one 6



## attribute alone such as GWP. 7



## Third, the SNAP change of listing status 8



## process should be used sparingly as the economic 9



## implications should require a higher standard of 10



## care in considering transition dates and market 11



## assumptions than is needed for the SNAP listing 12



## approval process. Whereas SNAP listing does not 13



## place a burden on companies to change their 14



## operations, a change of listing status requires 15



## adjustments to business models or practices that 16



## might not otherwise occur, potentially to a 17



## company's economic detriment. This does not mean 18



## that some relatively rapid transitions are not 19



## achievable, nor does it mean that transitions are 20



## not already taking place. However, final 21



## transition deadlines should take into account 2214



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## reasonable time frames from an economic 1



## standpoint and other competing regulatory 2



## initiatives such as energy efficiency standards, 3



## building codes, and safety standards and other 4



## issues. 5



## Lastly, it must be recognized that EPA 6



## has so far failed to respond to the petition 7



## filed by the Alliance earlier this year to extent 8



## Section 608 rules to HFCs. The immediate 9



## environmental benefit of preventing service 10



## emissions and leaks from existing equipment is 11



## likely far greater than any marginal benefit in 12



## the immediate implementation of the delisting 13



## proposal. 14



## In the recently sponsored Montreal 15



## Protocol workshop on HFC management, Alliance 16



## speakers and others documented the significant 17



## progress in the last few years on the 18



## development, availability, and implementation of 19



## low-GWP alternatives. The involved industries 20



## have already accepted the challenge of minimizing 21



## the climate change impacts of ODS substitutes and 2215



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## have made rapid progress. SNAP change of status 1



## activities should be limited and take into 2



## account the important considerations we have 3



## cited above. We should all work together to 4



## achieve an effective global regime to phase down 5



## HFCs that follows the Protocol’s historical 6



## pattern of ensuring measures that are both 7



## environmentally and economically acceptable. 8



## Thank you and we look forward to working 9



## with you on the completing of this rule. 10



## MS. FARQUHARSON: Thanks, Kevin. Speaker 11



## number two is Christopher Nitz from Danfoss. 12



## MR. NITZ: Hi. Good morning. I'm 13



## Christopher Nitz. It's N-I-T-Z, N like in Nancy. 14



## My role is Segment Manager for Commercial 15



## Refrigeration with Danfoss. 16



## Danfoss is a leading international 17



## manufacturer of high efficiency controls, 18



## compressors, and variable frequency drives for 19



## the heating, ventilation, and air conditioning 20



## and refrigeration industry. We appreciate the 21



## opportunity to provide comments today on the 2216



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## EPA's proposed rule. 1



## Danfoss supports the planned orderly 2



## approach to the phase down of high GWP chemicals 3



## on a CO 2 

## equivalent weighted basis. The phase 4



## down process is important to Danfoss, its 5



## customers and the industry as a whole. 6



## The EPA SNAP program, overall, has been 7



## successful in its quest to identify alternative 8



## refrigerants to CFCs and HCFCs in advance of the 9



## phase-out of those chemicals and the industry has 10



## responded. 11



## Danfoss supports the SNAP program; 12



## however, we do have four concerns. And they are, 13



## number one, while the SNAP process has been 14



## effective in listing refrigerant alternatives, 15



## the process to de-list is unproven. This causes 16



## concern simply due to the uncertainty as to the 17



## order in which specific refrigerants may actually 18



## be de-listed. 19



## Number two, in order to meet the proposed 20



## delisting date of January 1, 2016, it would 21



## require the industry to do a complete product 2217



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## line redesign in about one year, which is 1



## unrealistic. We recommend further engagement 2



## with equipment manufacturers to develop a 3



## realistic time line. 4



## Number three, even if it were possible to 5



## complete the redesign, significant progress needs 6



## to be made in both developing and implementing 7



## local codes and standards. This is a challenging 8



## hurdle to overcome. It's a complex issue and the 9



## January 1, 2016, time frame is also unrealistic. 10



## Finally, number four, Danfoss is aware of 11



## the Department of Energy’s concurrent rulemaking 12



## process regarding refrigeration equipment energy 13



## efficiency. Therefore, we urge EPA to work 14



## closely with the Department of Energy in 15



## synchronizing rulemaking timing in order to 16



## provide manufacturers with adequate notice and 17



## simultaneously comply with the refrigerant and 18



## the energy efficiency requirements. 19



## Lastly, we appreciate the opportunity to 20



## provide these comments, and we commend the EPA 21



## for taking the collaborative approach with 2218



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## stakeholders. Thank you. 1



## MS. FARQUHARSON: Thank you, Christopher. 2



## Speaker number three is Allan Thornton from the 3



## Environmental Investigation Agency. 4



## MR. THORNTON: Good morning. I am the 5



## President of the Environmental Investigation 6



## Agency. We're a nonprofit, independent 7



## environmental campaigning organization, and we 8



## work around the world to protect the global 9



## climate. We work across the European Union 10



## countries, in the U.S., and elsewhere to support 11



## the transition to HFC-free alternatives. 12



## We're pleased to have this opportunity to 13



## provide our comments regarding EPA's proposed 14



## rule on the change of listing status for certain 15



## substances under the Significant New Alternatives 16



## Policy Program. We would also like to 17



## congratulate the EPA on proposing a practical 18



## rule that addresses the steps laid out in 19



## President Obama's Climate Action Plan. EIA 20



## strongly supports this proposed rule and 21



## encourages the EPA to continue to remove high GWP 2219



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## HFCs as acceptable substitutes. 1



## In the U.S., HFC emissions are growing at 2



## a faster rate than all other greenhouse gases and 3



## they are projected to double by 2020 and triple 4



## by 2030. This rule, which is only addressing 5



## some high GWP HFCs and some end uses, is alone 6



## estimated that it will prevent emissions of up to 7



## 42 metric tons -- 42 million metric tons of CO2 8



## equivalent by the year 2020. 9



## In the refrigeration sector, the EPA is 10



## proposing to de-list certain high GWP HFCs, 11



## including 404A for new retail food refrigeration 12



## equipment. As this sector accounts for 13



## approximately 32 percent of global HFC 14



## consumption, it's important that lower GPW 15



## alternatives are used and phased in as they 16



## become available. 17



## There are already numerous other approved 18



## alternatives, including HFC-407A, CO 2 

## , ammonia and 19



## propane. By using lower GWP alternatives and new 20



## store builds, a supermarket can reduce its carbon 21



## footprint 25 percent or more. 2220



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## In addition, these new systems are more 1



## energy efficient. For instance, the 2



## transcritical CO 2 

## system has been shown in the 3



## field to be up to 30 percent more efficient than 4



## a system running on fluorinated gas refrigerants. 5



## Because of these climate savings and 6



## energy-efficient savings, many food retailers are 7



## already moving away from the use of HFC-404A. 8



## The consumer goods forum, which is a global 9



## network of retailers and food manufacturers, have 10



## pledged to begin phasing out HFC refrigeration 11



## equipment where commercially feasible as of 2015. 12



## And in the U.S., many supermarket chains are 13



## starting to install CO 2 

## transcritical or cascade 14



## systems that do not use HFC-404A. 15



## On the manufacturing side, large 16



## manufacturers have already begun making these new 17



## systems in the U.S. Three companies alone will 18



## produce over 200 CO 2 

## transcritical systems this 19



## year, mitigating the equivalent emissions of over 20



## 60,000 passenger cars just from leakage. 21



## These options show how quickly the market 2221



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## is changing in the U.S. and highlight the 1



## opportunity for U.S. businesses to continue to be 2



## leaders by moving away from older, high GWP 3



## options. 4



## While we laud the EPA for proposing this 5



## rule, EIA urges EPA to go further in light of the 6



## many available alternatives and the dire needs of 7



## the climate. First, we believe the rule does not 8



## adequately address all the sectors covered by the 9



## SNAP Program, for which there are many climate10



## friendly alternatives. 11



## One specific example of this is the EPA's 12



## failure to list HFC-23 as unacceptable for use in 13



## fire suppression and very low-temperature 14



## refrigeration system sectors, despite the fact 15



## that HFC-23 is 14,800 times more damaging to the 16



## climate than carbon dioxide and multiple other 17



## alternatives are already available. 18



## Second, EIA believes that the delisting 19



## dates for many sectors are too lenient, 20



## particularly for sectors where both chlorinated 21



## and nonchlorinated substitutes exist. For 2222



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## example, in the foam sector methyl formate, 1



## water, CO 2 

## hydrocarbons and HFO-1234 are all 2



## approved substitutes that are used not only in 3



## the U.S. but also around the world. 4



## In Europe, hydrocarbons have been used as 5



## blowing agents since 1992, and internationally 6



## the Montreal Protocol Multilateral Fund did not 7



## approve the use of HFCs by developing countries 8



## for any type of foam blowing agent. Therefore, 9



## EIA strongly urges EPA to bring forward the 2017 10



## delisting date by a year for foam blowing 11



## applications. 12



## All deadlines beyond 2016 in all of the 13



## sectors should be reviewed as there are numerous 14



## alternatives available for all the sectors being 15



## discussed in this rule. If too long a delay is 16



## allowed to transition from HFCs, not only will 17



## U.S. industry fall even further behind companies 18



## in the European Union, Japan, and even China -- 19



## MS. FARQUHARSON: Allan, sorry. Do you 20



## mind finishing up soon, please? Thank you. 21



## MR. THORNTON: Is that it? 2223



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MS. FARQUHARSON: Sorry. 1



## MR. THORNTON: Okay. Thank you very 2



## much. I'll just leave it there. 3



## MS. FARQUHARSON: Speaker number four is 4



## Douglas Fratz from the Consumer Specialty 5



## Products Association. 6



## MR. FRATZ: Good morning. I am D. 7



## Douglas Fratz, F-R-A-T-Z, and I am a staff 8



## executive for the aerosol products division of 9



## the Consumer Specialty Products Association. 10



## I'm also representing today, the 11



## Automotive Specialty Products Alliance, which is 12



## an alliance of CSPA for the Auto Care Association 13



## and the Motor Equipment Manufacturer's 14



## Association. 15



## CSPA's aerosol products division 16



## represents more than 150 companies that 17



## manufacture or market aerosol products or supply 18



## related products and services. This year is 19



## CSPA's 100th anniversary, and we have represented 20



## the aerosol industry since 1950 -- although I 21



## will say I wasn't there in 1950, although I look 2224



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## like I was. 1



## CSPA has been supportive of the goals of 2



## the EPA SNAP Program for stratospheric ozone 3



## protection and also for climate change 4



## mitigation. EPA's newest proposal primarily 5



## impacts CSPA members who have remaining uses of 6



## HFC-134a. The use of HFCs -152a and 134a as 7



## aerosol propellants began largely in the 1990s to 8



## meet VOC standards being set by EPA, California, 9



## and other states. These were to assist on 10



## tropospheric ozone attainment, and since 134A is 11



## nonflammable it was used where there were safety 12



## concerns. 13



## In 2002, CSPA and its members signed on 14



## as founding members of EPA's Responsible Use 15



## Principles for HFCs. For the past dozen years, 16



## CSPA members have sought to use 134a only where 17



## nonflammability is needed for product safety. 18



## After enactment of the global -- or of the 19



## California Global Warming Solutions Act of 2006, 20



## CSPA helped that state's Air Resources Board 21



## develop a series of regulations that restricted 2225



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## the remaining 134a uses in 17 different product 1



## categories. Our members' remaining uses are very 2



## small. We estimate that HFC-134a use in 3



## nonmedical aerosols represents less than one 4



## percent of HFC usage today in the United States. 5



## Nevertheless, we remain dedicated to do 6



## all that we can to improve our products. Another 7



## significant factor is the CSPA product care 8



## program. This program is a product stewardship 9



## program that establishes principles for all CSPA 10



## members to follow and minimizing the impacts and 11



## ensuring product safety. 12



## Reformulating product can be expensive 13



## and time consuming. We appreciate that EPA has 14



## recognized that some 134a uses need to continue 15



## in this proposed rule. But each manufacturer and 16



## each product is unique in its formulation and its 17



## uses, and careful evaluations are needed to 18



## assure that each and every one is stable in 19



## storage and safe for all intended uses. 20



## A new alternative, HFC-1234ze is now 21



## available, and CSPA members have been evaluating 2226



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## its use. Several members have ze-based products 1



## in the market now. CSPA members are dedicated to 2



## improving their products, and more are in the 3



## process of evaluating ze products. But they must 4



## assure that they are safe and effective for all 5



## intended uses. 6



## EPA hopes to issue its final rule in 7



## April of next year, but that is only months 8



## before the proposed January 2016 deadline. More 9



## time may be needed for some products. Product 10



## reformulations often require one or more years. 11



## For workplace products, worker education may be 12



## needed to assure safe use. For retail products, 13



## time is needed to adjust contracts with 14



## retailers, but we may need time and EPA 15



## assistance to work with retailers to assure that 16



## CSPA member complying products are not displaced 17



## by noncomplying products from offshore. This has 18



## been a significant problem in the past. 19



## CSPA will file comprehensive comments by 20



## the October 6th deadline to outline and support 21



## any minor adjustments that are needed to assure 2227



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## that our members can comply with the final rule, 1



## and continue to provide safe and effective 2



## products with minimal environmental impacts. 3



## CSPA looks forward to continuing work with the 4



## EPA on this common goal. Thank you. 5



## MS. FARQUHARSON: Thank you, Douglas. 6



## The next speaker is Julie Becker from the 7



## Alliance of Automobile Manufacturers. 8



## MS. BECKER: Good morning. My name is 9



## Julie Becker, J-U-L-I-E, B-E-C-K-E-R. I'm Vice 10



## President for Environmental Affairs of the 11



## Alliance of Automobile Manufacturers. We're a 12



## trade association of 12 light-duty vehicle 13



## manufacturers who account for about 75 percent of 14



## the new vehicles sold in the U.S. each year. I'm 15



## happy to be here today and even happier that I 16



## brought my own personal HFC-free air conditioner. 17



## Automakers supported the development of 18



## the groundbreaking Single National Program 19



## governing light-duty vehicle greenhouse gas 20



## emission and fuel economy. Our industry was the 21



## first to commit to greenhouse gas emission 2228



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## reductions on a broad scale. We've invested 1



## billions in this effort. 2



## One of the things I wanted to start with 3



## today is to tell you that automakers support 4



## transitioning as quickly as possible to 5



## refrigerants with a lower GWP, and to do this 6



## current models will need to be redesigned and a 7



## reliable supply of new refrigerants established. 8



## In addition to investing heavily in 9



## research of alternative refrigerants, automakers 10



## have worked to improve the efficiency of their 11



## refrigeration systems to prevent leakage. By 12



## reducing leakage, we reduce emissions of today's 13



## refrigerants and save consumers the cost of 14



## expensive refills. 15



## Going forward, as EPA notes in the NPRM, 16



## these improvements will reduce the motivation for 17



## do-it-yourselfers to use more cheaper HFC-134a in 18



## AC systems designed for HFO-1234yf. 19



## So the key question today is not whether 20



## to transition to low-GWP refrigerants, it's when 21



## the SNAP rule should take effect and how it 2229



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## should be structured. 1



## So let's start with when. We would 2



## propose that the rule take effect at the end of 3



## 2025. Simply put, doing so would preserve the 4



## integrity of the Single National Program for 5



## greenhouse gas emissions and fuel economy without 6



## threatening the program's greenhouse gas 7



## reductions at all. An integral part of that 8



## program is the earning of credits for 9



## transitioning to the new refrigerants, and we 10



## appreciate that EPA is not proposing to touch 11



## those credits. 12



## However, the second element of the Single 13



## National Program is that each manufacturer is 14



## given an opportunity model by model to determine 15



## when they should make the transition to low-GWP 16



## refrigerants since there is no drop-in solution 17



## here and the transition needs to occur as models 18



## undergo major redesign and new models are 19



## introduced. This is why when it set the GHG 20



## standards EPA predicted that manufacturers would 21



## transition, for the most part, to low-GWP 2230



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## refrigerants by 2021, but allowed any 1



## manufacturer that fails to do so to make up the 2



## difference by finding other ways to achieve equal 3



## greenhouse gas reductions. 4



## EPA now proposes to take away that 5



## valuable flexibility. Given that there is no 6



## measurable environment impact at stake, we think 7



## the best way to preserve the integrity of the 8



## Single National Program is to allow HFC-134a 9



## until the end of 2025. 10



## A second major concern is how, 11



## specifically how exports are addressed. Auto 12



## manufacturing is a cornerstone of the U.S. 13



## economy, representing 8 million jobs. A quarter 14



## of that, 2 million jobs, is due to automotive 15



## exports from the United States. U.S. assembly 16



## plants export to over 130 countries around the 17



## world, including many that have not begun 18



## creating the infrastructure for service and 19



## refilling local air conditioning systems with the 20



## new refrigerant. By my count, that's about 100 21



## countries that haven't done so, let alone 2231



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## updating their regulations governing 1



## transportation and handling of those new 2



## refrigerants. In the U.S., if the U.S. is any 3



## example, this process could take up to a decade. 4



## Now, we understand that EPA is reluctant 5



## to make an export exception, but this is an 6



## exceptional situation for appliances like 7



## refrigerators, manufacturers could unilaterally 8



## produce and export products that met all the use 9



## conditions for safe operation and they don't have 10



## to go through the significant changes to the 11



## regulations overseas, creating the infrastructure 12



## and the servicing that has to happen for vehicles 13



## because a vehicle at least once in its lifetime 14



## typically needs a new refrigerant. 15



## Well, absent changes in the SNAP rule, 16



## both the lack of infrastructure and the fact that 17



## alternative refrigerants may not be approved for 18



## use in some nations would effectively prevent 19



## manufacturers in the U.S. from exporting vehicles 20



## to some markets. We recommend, therefore, that 21



## EPA adopt provisions consistent with what the 2232



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## European Union has done and limit the SNAP rule 1



## to vehicles intended for the U.S. Market. 2



## Thank you for this opportunity to 3



## testify. Of course, we also plan to present in4



## depth written comments on a variety of issues 5



## that are raised in the NPRM. 6



## MS. FARQUHARSON: Thank you, Julie. 7



## Speaker number six is Dave Stirpe from Honeywell. 8



## MR. STIRPE: Good morning. My name is 9



## Dave Stirpe, S-T-I-R-P-E, and I'm Manager of 10



## Regulatory Affairs at Honeywell. 11



## Honeywell supports changes in the listing 12



## status of certain high-GWP substances and 13



## applications where alternatives are technically 14



## and economically feasible and commercially 15



## available. Honeywell has developed such 16



## alternatives that produce overall environmental 17



## benefits in all of the sectors addressed by the 18



## rule and in areas the rule has not addressed such 19



## as commercial chillers and spray foam. 20



## The SNAP proposal addressed by President 21



## Obama in his June 13 -- his June 2013 Climate 2233



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Action Plan can succeed due to the availability 1



## of these alternatives, and we are ready to work 2



## with the EPA and manufacturers on the 3



## implementation of the President's goals. 4



## We support EPA's use of the SNAP Program 5



## to transition the industry to low-GWP 6



## alternatives and have been working diligently to 7



## develop technologies to further these goals. 8



## Honeywell has invested significantly in a new 9



## platform of low- and lower-GWP compounds for use 10



## by equipment and product manufacturers worldwide. 11



## We are working with manufacturers today to 12



## evaluate and implement these new compounds and 13



## new products and equipment. Regulatory 14



## incentives and drivers, such as this SNAP 15



## statute’s change rule will lead companies to 16



## commercial adoption of new compounds that reduce 17



## the risk to human health and the environment. 18



## Last December, Honeywell and its 19



## suppliers announced plans to invest $300 million 20



## in building a new facility in Geismar, Louisiana, 21



## to produce HFO-1234yf for motor vehicle air 2234



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## conditioning. This refrigerant has a GWP of less 1



## than one, lower than carbon dioxide. The plan is 2



## expected to be operational by the end of 2016. 3



## Nearly 2 million cars in the world will use 4



## 1234yf by the end of this year, including many in 5



## the United States. 6 

## While the CAFÉ Credit program that EPA 7



## has offered U.S. automobile manufacturers to meet 8



## the tailpipe emission standards has helped to 9



## drive adoption of lower-GWP refrigerants, there 10



## is still a large percentage of the U.S. 11



## automobile fleet that does not need the CAFÉ 12



## credits gained from adopting low-GWP 13



## refrigerants. The proposed change of listing 14



## status would help accelerate that refrigerant 15



## conversion for the remaining U.S. automobile 16



## fleet. 17



## In January of this year, Whirlpool 18



## Corporation announced that it has implemented the 19



## use of Honeywell Solstice LBA, Liquid Blowing 20



## Agent, into its foam insulation used in U.S. made 21



## household refrigerators and freezers. This 2235



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## compound has a GWP approximately 1,000 times 1



## lower than the most common foam blowing agents in 2



## use today. It is also nonflammable and VOC 3



## exempt by EPA. That conversion is expected to be 4



## complete by the end of 2014, resulting in global 5



## warming impact equivalent to removing more than 6



## 400,000 cars annually from the road. 7



## Solstice LBA has also been commercial in 8



## the U.S. for more than a year in spray foam. 9



## Commercialization of Solstice LBA has also 10



## occurred in Japan, the E.U., and even in China 11



## for a variety of foam applications, including 12



## appliance, panel and spray foam. A commercial13



## scale plant for this compound has already begun 14



## operations in Baton Rouge. 15



## Honeywell has completed construction of 16



## yet another commercial-scale plant, also in Baton 17



## Rouge, to produce HFO-1234ze, a low-GWP compound 18



## for use as a refrigerant extruded by styrene foam 19



## blowing agent, as an aerosol propellant. It is 20



## nonflammable, VOC exempt by EPA and California, 21



## and has a GWP of one. 2236



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We are working with companies to replace 1



## HFC-134a in extruded polystyrene foam, consumer 2



## and technical aerosols, and chillers. In fact, 3



## 1234ze has been sold commercially since 2009 in a 4



## variety of consumer and technical aerosol 5



## applications in Europe, Asia, and the U.S., as 6



## well as for one-component foams and extruded 7



## polystyrene foam applications in Europe. 8



## These are just some of the examples where 9



## alternatives can be implemented in sectors using 10



## HFCs. Thank you for the consideration of these 11



## comments. 12



## MS. FARQUHARSON: Thank you, Dave. 13



## Speaker number seven is Robert McArver from the 14



## Association of Home Appliance Manufacturers. 15



## MR. MCARVER: Good morning. I'm Rob 16



## McArver. That's M-C-A-R-V-E-R. I'm the Vice 17



## President of Policy and Government Relations with 18



## the Association of Home Appliance Manufacturers, 19



## or AHAM. I appreciate the opportunity to explain 20



## why AHAM is opposed to the proposed delisting 21



## rule as it applies to refrigerator foam. 2237



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## This proposed action is well beyond the 1



## authority delegated to EPA under the Clean Air 2



## Act. It is unnecessary to protect the 3



## environment, exposes a lack of regulatory 4



## coordination among federal agencies, and creates 5



## significant burdens to U.S. businesses. 6



## The U.S. appliance manufacturing industry 7



## has been at the forefront of providing consumers 8



## increasingly sustainable and environmentally 9



## preferable products. Over time, we've 10



## transitioned our products to highly efficient 11



## non-ozone depleting substances, which has cost 12



## manufacturers hundreds of millions of dollars. 13



## All of these transitions from CFCs to HCFCs to 14



## HFCs have been encouraged, actually urged and 15



## applauded by EPA, including the extremely 16



## beneficial move to HFCs. 17



## With these new generations of products, 18



## we have eliminated almost all use of ozone19



## depleting substances. We recognize that HFCs are 20



## ultimately transitional chemicals, although it is 21



## not sufficiently reflected in EPA's analysis. In 2238



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## fact, a significant portion of products sold in 1



## the U.S. market no longer use HFCs as foam 2



## blowing agents, opting instead for hydrocarbons 3



## or HFO. Despite this, the EPA proposal goes well 4



## beyond the actions that were suggested in 5



## preproposal workshops, indeed going so far as to 6



## propose unnecessarily accelerating delisting of 7



## widely used chemicals that still have significant 8



## beneficial uses in the U.S. 9



## This action only serves to insert the 10



## federal government into the marketplace by 11



## forcing investments that are economically 12



## unsound. These actions exceed EPA's legal 13



## authority and are unnecessary, and thus we oppose 14



## them. 15



## What EPA has proposed is not authorized 16



## under Section 612 of the Clean Air Act. The 17



## statute requires the replacing of ozone-depleting 18



## substances with substitutes as a trigger for 19



## regulatory action. But nowhere in the U.S. are 20



## ODSs being substituted for non-ODS materials in 21



## refrigerator foam blowing agents. At present, we 2239



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## are on second, third, or fourth generations of 1



## refrigerator products since ODSs were used in 2



## U.S. production. There simply is no ODS 3



## substitution taking place, and thus EPA does not 4



## have authority to regulate further in this area. 5



## AHAM is working on a current valid 6



## estimate of the reduced level of HFC usage and 7



## refrigerator foam and what is forecasted for 8



## future demand, and we will provide that data in 9



## our written comments. Initial analysis 10



## indicates, however, that by 2015 many 11



## refrigerators sold in the U.S. will not use high12



## GWP foam blowing agents and the trend of dramatic 13



## reductions in the use of high-GWP HFCs by this 14



## responsible industry will accelerate in the 15



## future. 16



## Regardless of these trends, manufacturers 17



## of all sizes will be impacted by this rule. For 18



## those that have not fully transitioned from HFC 19



## foam blowing agents and do not have the time or 20



## the capital to invest in 100 percent transition 21



## by an arbitrary January 1, 2017, date, the impact 2240



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## of these proposals could be devastating. 1



## These same firms have invested millions 2



## of dollars in new DOE efficiency requirements 3



## that become effective in less than a month. The 4



## DOE requirements were based on assumptions about 5



## the availability of HFCs and have diverted the 6



## scarce capital that is available for regulation7



## driven investment. 8



## To make matters worse, the major new 9



## burdens EPA proposes are unnecessary because the 10



## use and potential emission of high-GWP HFCs for 11



## refrigerators sold in the U.S. market are far 12



## less than were estimated. This is a classic 13



## example of the cumulative regulatory burden that 14



## falls on manufacturers when EPA and DOE fail to 15



## coordinate their rulemaking activity. 16



## EPA also significantly underestimates the 17



## cost of this proposal. One particularly 18



## disappointing example is the suggestion that 19



## refrigerator manufacturers seek to replace HFCs 20



## and foam-blowing agents have drop-in substitutes. 21



## In fact, there are no available drop-ins. That 2241



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## false but convenient misnomer overlooks the years 1



## and millions of dollars of work necessary to 2



## ensure continued manufacturing efficiency, 3



## product quality performance and longevity, and 4



## evaluation of potential impacts on energy 5



## efficiency and the compatibility of plastics 6



## used. On top of that, it is well known that the 7



## use of hydrocarbon foam in U.S. factories 8



## requires an investment in bomb proofing such 9



## production to protect employees and new VOC 10



## controls, and in reformulation analysis to ensure 11



## continued energy efficiency. 12



## These steps are neither cheap nor easy, 13



## and the significant burdens they impose were 14



## inadequately addressed in the proposal. By 15



## forcing 100 percent across the board transitions 16



## in such a short period of time, this proposal 17



## would put companies and their products at risk, 18



## given the limited alternatives that are currently 19



## available. 20



## AHAM urges EPA to drop this ill21



## considered effort after more carefully and 2242



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## accurately taking into account the realities of 1



## the marketplace and the true costs and benefits 2



## of this effort. The appliance industry's 3



## transition away from HFCs is well under way. 4



## EPA's proposal should reflect and support this 5



## rather than impede it. 6



## Thank you for considering our comments. 7



## MS. FARQUHARSON: Thank you, Robert. The 8



## next speaker is number eight, Michael Parr from 9



## DuPont Chemicals and Flouroproducts. 10



## MR. PARR: Good morning. Thank you for 11



## the opportunity to join you all. My name is 12



## Michael Parr, P-A-R-R, with DuPont. DuPont 13



## appreciates the opportunity to participate in 14



## this hearing and briefly present our views on the 15



## proposed Change of Status Rule under EPA's 16



## Significant Alternatives Program. 17



## We would also like to recognize the 18



## significant stakeholder outreach that EPA has 19



## performed in preparing this proposal and the 20



## Agency's ongoing openness to the views of all 21



## stakeholders in the process. 2243



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We applaud the White House and the Agency 1



## also for the timely action in developing this 2



## proposal in response to the President's Climate 3



## Action Plan. I believe you all have set a record 4



## for OMB review, and I congratulate you for that. 5



## As we stated at the beginning of the 6



## stakeholder outreach process, DuPont recognizes 7



## the need for concerted global action to avoid 8



## significant future growth in greenhouse gas 9



## emissions associated with the use of HFCs in the 10



## various applications. That is why we are 11



## bringing low global warming potential, energy 12



## efficient products to market across a variety of 13



## HFC end uses. 14



## We also believe that in avoiding these 15



## future emissions, it is critical that we do so in 16



## a manner that ensures that we remain able to 17



## deliver the critical societal services that HFCs 18



## provide today. This includes safe and energy 19



## efficient refrigeration, air conditioning, foam 20



## insulation, fire suppression, repellants, and 21



## waste heat recovery. It is also important that 2244



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## we avoid these emissions in a manner that does 1



## not impede the global trade in these important 2



## products that is central to achieving these 3



## reductions in cost effective manner. 4



## The nature of the regulatory approach 5



## taken to avoid these future emissions will have a 6



## lot to do with how successfully we achieve these 7



## goals. That is why we have strongly supported 8



## the Administration's efforts to amend the 9



## Montreal Protocol to employ the well understood 10



## and very effective tools of that protocol to 11



## achieve these necessary transitions. We believe 12



## the mechanics of the protocol would provide both 13



## a globally consistent framework for the 14



## transitions and the ability to make cost 15



## effective transitions while ensuring we can 16



## continue to serve our markets properly. A 17



## patchwork of uncoordinated national and regional 18



## command and control regimes would be a much less 19



## effective regulatory model for these changes. 20



## We do believe the EPA's SNAP authority 21



## can provide a reasonable down payment on the 2245



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Montreal Protocol process by focusing on areas 1



## where technology transitions are already underway 2



## in the marketplace, alternatives are already 3



## available, or will soon be, and action under SNAP 4



## can accelerate those transitions. We think the 5



## Montreal Protocol is the better tool for driving 6



## new transitions and long-term reductions. 7



## As for the specifics of the proposed 8



## rule, we're still evaluating it and talking with 9



## our customers and other value chain participants 10



## and stakeholders, and we will be submitting 11



## detailed comments. Based on our review to date, 12



## we generally think the scope of the proposal is 13



## appropriate and reflects transitions already 14



## underway in the market. 15



## There are some areas, such as motor 16



## vehicle air conditioning, where we think the 17



## proposed timing is actually lagging the business 18



## as usual market transition that is underway, and 19



## there are others, such as in several of the foam 20



## segments, where we feel the proposed timing is 21



## faster than the market can reasonably manage. 2246



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We look forward to providing more detail 1



## in our written comments. In closing, we 2



## appreciate the opportunity to share our views and 3



## believe that the proposed SNAP rule, with some 4



## adjustments, can be a helpful down payment on the 5



## broad market transitions to be achieved under an 6



## amended Montreal Protocol. 7



## We look forward to working with EPA, 8



## important customers in the auto, foam, appliance, 9



## and propellant segments and other stakeholders in 10



## finalizing this regulation. Thank you very much. 11



## MS. FARQUHARSON: Thank you, Michael. 12



## The next speaker is number nine, Emily Davis from 13



## the Natural Resources Defense Council. 14



## MS. DAVIS: Thank you for the opportunity 15



## to be here today. My name is Emily Davis, 16



## D-A-V-I-S, and I'm here on behalf of the Natural 17



## Resources Defense Council and the Institute for 18



## governance and sustainable development. 19



## I'd like to thank EPA for the opportunity 20



## to comment on its proposal to change the listing 21



## status of certain substitutes under the 2247



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Significant New Alternatives Policy and 1



## congratulate them on their proposal. 2



## EPA's SNAP program has a proud history of 3



## collaboration among stakeholders, and NRDC and 4



## IGSD are proud of the relationship we've built in 5



## the process of implementing past transitions. 6



## We're eager to work with industry and other 7



## stakeholders as these SNAP rules are finalized 8



## and implemented. 9



## HFCs, the chemicals at issue in today's 10



## SNAP proposal, were added to the SNAP list 11



## because they were an improvement on the chemicals 12



## they replaced. But they are, themselves, 13



## extremely potent chemicals with a very high 14



## global warming potential thousands of times 15



## greater than carbon dioxide. This means that 16



## every ton of HFCs has an impact on the climate 17



## many times worse than a ton of carbon dioxide. 18



## We also know that HFC emissions are forecasted to 19



## almost triple by 2030 if we don't act to reduce 20



## their use. 21



## The good news is that safer chemicals 2248



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## exist and 25 years of experience with the 1



## Montreal Protocol and the Clean Air Act has shown 2



## us that transitioning to safer chemicals works 3



## smoothly. In fact, we know more now about safer 4



## alternative chemicals to HFCs than we knew at a 5



## comparable moment for alternatives to CFCs. 6



## When EPA proposed phasing down CFCs and 7



## other ozone-depleting substances, there were dire 8



## warnings that the industry could not survive 9



## without these chemicals; but in fact, the phase10



## out of CFCs was successful and the warnings did 11



## not come true. Similar warnings may be repeated 12



## now, but the history of success and the evidence 13



## in support of safer alternatives shows that we 14



## will be able to succeed in moving away from HFCs 15



## as proposed. 16



## EPA's proposed rule is important for 17



## several reasons. First and foremost, it is 18



## critical because of the reductions in HFCs that 19



## will be achieved in the sectors at issue, 31 to 20



## 42 million metric tons of carbon dioxide 21



## equivalent in 2020 by EPA's estimates. 2249



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Second, the rule is important because it 1



## provides a needed signal to industry that as 2



## safer alternatives are brought to market, 3



## dangerous substitutes with high global warming 4



## potentials will be removed from the SNAP list. 5



## Third, the rule is important because it 6



## puts U.S. industry in the leadership position as 7



## the global market moves away from high-GWP 8



## substances. 9



## From an environmental standpoint, if EPA 10



## were only taking into account the risks of human 11



## health and the environment the Agency would act 12



## to ban HFCs immediately. We know that these 13



## chemicals are extremely potent agents of climate 14



## change, and we know that continuing to use them 15



## only exacerbates the climate problem. So in that 16



## sense, the very idea of the SNAP program takes 17



## into account the technological feasibility and 18



## business concerns of the regulated community in 19



## the very structure of the program itself by 20



## removing harmful chemicals only as safer 21



## alternatives come to market. 2250



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## However, NRDC and IGSD believe that for 1



## some sectors transition dates can and should be 2



## accelerated from the dates in the proposed rule. 3



## For example, we believe that the motor vehicle 4



## air conditioning sector can transition by 2017. 5



## In this sector, the industry already has many 6



## vehicle models that use low-GWP alternatives to 7



## HFCs, and manufacturers that have signaled that 8



## they will develop additional models in the next 9



## few years. 10



## Adopting a 2017 date also makes sense 11



## because it aligns the U.S. time line with the 12



## European auto market, which is required to 13



## transition away from HFCs completely by 2017, 14



## five years earlier than the date EPA has proposed 15



## here. 16



## We believe the deadlines should be based 17



## on the leaders in the industry rather than 18



## laggers and setting these accelerated time lines 19



## in certain sectors would do just that. But we 20



## believe the automakers should be able to meet an 21



## earlier transition date. NDRC and IGSD are 2251



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## interested in hearing the concerns of automakers 1



## and other parties who do not believe they can 2



## meet a 2017 deadline, and we would be glad to 3



## work with such parties to discuss how such 4



## concerns can be addressed. 5



## Securing HFC reductions as quickly as 6



## possible is critical to achieving the goals of 7



## the President's Climate Action Plan. In addition 8



## to accelerating the dates in the proposed rule, 9



## we urge EPA to quickly start work on the next 10



## SNAP rule. Further progress to replace higher 11



## GWP substances can be made in these and other 12



## sectors based on the alternatives currently on 13



## the market and those that are being developed. 14



## Further, such action is critical as a 15



## means of reducing domestic emissions of 16



## greenhouse gasses, making the U.S. an industry 17



## leader in safer chemicals and paving the way for 18



## international action through the Montreal 19



## Protocol. Thank you. 20



## MS. FARQUHARSON: Thank you, Emily. 21



## Speaker number 10 is John Ferraro from the 2252



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Extruded Polystyrene Foam Association. 1



## MR. FERRARO: Good morning. My name is 2



## John Ferraro, spelled F-E-R-R-A-R-0, and I'm the 3



## Executive Director of the Extruded Polystyrene 4



## Foam Associations. 5



## XPSA is the trade association 6



## representing manufacturers of extruded 7



## polystyrene foam insulation products and the 8



## industry's raw material suppliers. XPSA is 9



## regular members of Dow, Owens Corning, Pactiv 10



## Building Products collectively manufacture more 11



## than 95 percent of all XPS destined for use in 12



## the North American Market. 13



## XPS insulation applications include 14



## external walls, foundations and basements, 15



## commercial roots, plus other uses. XPS is an 16



## excellent thermal insulation product due to its 17



## high R-value to thickness ratio and plays a 18



## critical role improving the energy efficiency of 19



## buildings by lowering heating and cooling costs 20



## for building owners and occupants. 21



## XPS insulation maintains thermal and 2253



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## structural integrity during the building service 1



## life. With the trend to longer building 2



## lifetimes, the use of thermal insulation only 3



## increases the net savings in energy and 4



## greenhouse gas emissions. The use of thermal 5



## insulation for increased energy efficiency is 6



## important to reduce global warming and plays an 7



## important role in meeting EPA's challenge to 8



## reduce carbon emissions. 9



## First-year savings of XPS far exceed 10



## energy consumed in the manufacturing process. 11



## Emissions of blowing agents and foams such as 12



## HFC-134a are significantly offset by energy 13



## savings over the life of the building. As 14



## currently outlined, the removal of 134a from 15



## foam-blowing agents is scheduled for January 1st, 16



## 2017, which is unrealistic, unreasonable and 17



## inconsistent with the gradual phase down approach 18



## proposed by EPA within the Montreal Protocol. 19



## When EPA SNAP evaluated HCFCs, XPS 20



## manufacturers essentially had a 14-year window to 21



## move from CFCs to the current zero ozone 2254



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## depleting HFCs technologies. With each 1



## conversion, all of our manufacturers used 2



## approximately seven years to ensure the safety, 3



## mechanical performance, and integrity of our 4



## products, met the expectations of the industry 5



## and our customers. 6



## At the time, it was acknowledged by EPA 7



## that it would take manufacturers significant time 8



## to convert based on the aged thermal testing to 9



## be conducted, the need to obtain emission 10



## permits, make required modifications to existing 11



## plant designs, order and install equipment to 12



## optimize worker safety and efficiency, and 13



## finally the need to approve and certify these new 14



## formulations to comply with the required industry 15



## standards and state and local codes. 16



## If this proposed rule was not finalized 17



## until early 2015, manufacturers will have a less 18



## than a two-year period to perform the conversion. 19



## Additionally, because it takes several months for 20



## sufficient depletion of the supply channel, it is 21



## realistically an even shorter time frame. In 2255



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## addition to these timing considerations, there 1



## are also questions as to the volume of 2



## commercially-viable replacements to HFCs and 3



## their availability in the United States. 4



## Suppliers do not currently have an alternative 5



## that is both functional and cost equivalent. 6



## Several replacements being proposed for 7



## our industry are flammable, which could result in 8



## significant changes to the manufacturing and 9



## product performance. One of the newer 10



## technologies being offered is not currently 11



## available in the U.S. in commercially-certified 12



## quantities. In 2015, we only anticipate that one 13



## supplier from one location in the U.S. would be 14



## available to supply this technology to the XPS 15



## industry. 16



## An evaluation of XPSA members has 17



## suggested the cost of this product would 18



## significantly increase the cost of XPS products. 19



## A responsibility of the SNAP rule is to assess 20



## the cost effectiveness, and we do not believe 21



## this was adequately conducted for XPS insulation. 2256



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Therefore, this may actually lead to less 1



## greenhouse gas emission savings from in-use foam 2



## insulation contributions due to more expensive 3



## insulations we require to insulate buildings. 4



## This would result in less insulation being used 5



## overall. 6



## We urge you to reconsider the conversion 7



## time line for 134a foam insulation technologies 8



## or consider narrow use exemptions for high9



## performance insulation using 134a until the new 10



## technologies are understood and widely available 11



## within the industry. 12



## XPSA appreciates the opportunity to share 13



## its thoughts on the proposed rule and looks 14



## forward to working with EPA in a constructive 15



## manner. Thank you for your consideration of our 16



## comments. 17



## MS. FARQUHARSON: Thank you, John. 18



## Speaker 11 is Ron Shebik from Hussmann 19



## Corporation. 20



## MR. SHEBIK: Good morning, and thank you 21



## for giving me an opportunity this morning. 2257



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Again, my name is Ron Shebik. The name is 1



## S-H-E-B-I-K, and I'm the Regulatory Compliance 2



## Manager for Hussmann Corporation. 3



## Hussmann is a larger company. We have 4



## four locations, four manufacturing locations 5



## located in North America. We make a variety of 6



## products that fall under the commercial 7



## refrigeration equipment spectrum. We make 8



## supermarket cases, we do general merchandisers, 9



## we also build the refrigeration systems as well 10



## as condensing units, and we're also involved with 11



## walk-in cooler/freezer refrigeration. 12



## Okay. Hussmann, as well as our 13



## customers, we support energy efficiency and we 14



## are also in support of clean air policies. 15



## However, the concern we have are the time lines 16



## that are being provided, as well as the options 17



## that are being provided by the EPA. Again, 18



## Customer is a very focused -- we're very center19



## focused on our customers. We support our 20



## customer's needs and interests. Most of our 21



## customer's focus areas are reliability, energy 2258



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## efficiency, performance, food safety, product 1



## quality, as well as cost of ownership. And all 2



## of our retailers or end-users overall efficiency 3



## of the store is key to their business. And I 4



## believe those are areas that fall in line with 5



## both the EPA and the DOE. 6



## Excuse me. So, prior to the NOPR coming 7



## out, the Notice of Proposed Rulemaking, Hussmann 8



## has been very active working with the EPA. We 9



## attended public meetings that were available in 10



## 2013, as well as early 2014, and we also had 11



## meetings with the EPA, both I believe in April 12



## and June with NAFEM as well as HRI. And again, 13



## our concern there was to make sure that the EPA 14



## understands our concerns and what we feel is 15



## technologically feasible to move forward in these 16



## areas. 17



## First, I want to start talking about the 18



## impact on our customers. For self-contained 19



## merchandisers, our customers have very little 20



## options, either going with HC or transcritical -- 21



## HC refrigerants or transcritical CO 2 

## . These are 2259



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## now what's favorable for our customers, and they 1



## can definitely result in a cost increase. 2



## For our supermarket cases, we're going to 3



## be limited to 407 Series refrigerants. The 4



## impact on a customer who has recently installed a 5



## 404A system, which has a lifetime up to 25 years, 6



## is something that needs to be looked at and 7



## reviewed. What's it going to do to the lifetime 8



## of that system? 9



## Another concern we had with the use of 10



## alternative refrigerants, in particular 11



## hydrocarbons, is that the end-users can and will 12



## have problems getting building permits in their 13



## stores. I have dealt with this in several 14



## locations already. We acknowledge that UL on the 15



## listing end is up to speed, and they do have 16



## their safety guidelines in place for 17



## certification. However, the end-users affect the 18



## AHJs, the ones who have to approve the 19



## installation in the field that currently is not 20



## there. And in many locations, the AHJs are a 21



## little leery to move forward with the option of 2260



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## propane or other alternative hydrocarbons. 1



## Another concern we have with our -- our 2



## customers have is there is a reduction in new 3



## product development. OEMs are going to be 4



## dedicating all their resources towards testing 5



## and compliance, which means that new product 6



## innovation is going to be tossed out the window 7



## because we, as manufacturers, just need to be 8



## focused on compliance. 9



## As I said, there's an added complexity 10



## for the retailers as far as those who have 11



## systems that are currently compliant with the law 12



## using 404A in their supermarkets. How would 13



## these store owners, these retailers, handle a 14



## refurbishing of a store eight years from now with 15



## a 404A system that has a 25-year lifetime, yet 16



## they want to go to new, highly-efficient cases to 17



## test shift for a system. 18



## These are concerns that need to be 19



## addressed that aren't properly addressed in a 20



## NOPR. 21



## Hussmann has a few -- sorry, I'm running 2261



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## out of time here. We do have some additional 1



## concerns as well. In order to get a product to 2



## market, DOE uses a -- or, EPA, I'm sorry, uses 3



## the term "potentially available." The concern we 4



## have with potentially available? You're 5



## referring to a refrigerant. You're not looking 6



## at the refrigerant system. 7



## In order to get a case developed into 8



## market, we have to look at the condensing unit 9



## and the rest of the components that go into the 10



## system. We're looking at a year, if not longer, 11



## just to get a compressor or a condenser unit 12



## listed. Once it's listed, it goes to our 13



## manufacturer. We put it in our case, and we have 14



## to go through the same procedure with you to get 15



## it listed. Sixteen months is not enough time to 16



## get this work done. We're looking at years, 17



## especially if you have multiple product lines. 18



## So again, that's an area that EPA needs to look 19



## at and hopefully come up with a revised time 20



## line. 21



## I would request that hopefully EPA would 2262



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## allow us to reconsider and perhaps work with the 1



## manufacturers to possibly -- something like a 2



## written negotiated rulemaking where we can sit 3



## down and go over what we feel is technologically 4



## feasible, and we can all move forward in 5



## agreement with what is best for the future. We 6



## feel that 2020 is definitely a better time line 7



## that can be more realistically achieved and 8



## benefit both manufacturers as well as our 9



## customers. 10



## Thank you for your time. 11



## MS. FARQUHARSON: Thank you, Ron. Is 12



## Kate DeAngelis present, or another representative 13



## from Friends of the Earth? 14



## (No audible response.) 15



## MS. FARQUHARSON: Okay. We'll move on to 16



## speaker number 13, Peter Williams from New Era 17



## Group. 18



## MR. WILLIAMS: Good morning. My name is 19



## Peter Williams with the New Era Group, 20



## W-I-L-L-I-A-M-S. Our group is a nonprofit 21



## consulting group representing interests of 2263



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## refrigerant reclaimers, alternative refrigerant 1



## manufacturers and distributors throughout the 2



## United States. Our clients have invested 3



## significant resources in an effort to support the 4



## United States Clean Air Act. 5



## The very safety net that the nation needs 6



## to support a viable environmental policy, New Era 7



## Group agrees with the President's Climate Action 8



## Policy. The issues of climate change -- the 9



## issue of climate change is very relevant and 10



## significant in America. EPA's latest challenge 11



## is to establish regulatory policy which will 12



## achieve the goals set forth by the Administration 13



## in this matter. 14



## We're expressing concerns that EPA has 15



## not -- that EPA has lost their way with respect 16



## to ensuring the use of accurate data as it vets 17



## and presents these rules to the public for 18



## approval. There is a need to look at the history 19



## that EPA took to phase-out CFCs. In fact, the 20



## phase-out of CFCs was accomplished five years 21



## sooner than required. EPA was able to accomplish 2264



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## an accelerated phase-out and brought enforcement 1



## and venting as an important part of that 2



## rulemaking. 3



## EPA had, at that time, a very significant 4



## tool, the ODC tax, which prevented stockpiling. 5



## In 1993, the 1993 Rule referenced the need for 6



## data collection throughout the rule. The 7



## significance of that action was to understand the 8



## use and the demand for CFCs in order for there to 9



## form a better policy. 10



## The Agency stated policy in 1993 brought 11



## forth the worst first doctrine. It was that 12



## doctrine that led all of us to believe that there 13



## would be an aggressive ACFC phase-out. EPA is to 14



## be commended for the work done with respect to 15



## the Significant New Alternatives Program. 16



## Implementation of the clean air requirements must 17



## be considered as a great cornerstone to success 18



## of the 1995 consumption phase-out. 19



## In addition to this success, the nation 20



## saw recovery and reclamation grow. 21



## Unlike the prior phase-out periods, EPA, 2265



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## having vacated their prior process, did not seek 1



## any data from the industry on the needs or the 2



## inventories of HCFCs. The baseline was too high. 3



## The stockpile of products like R-22 went on for 4



## over 18 years before EPA attempted to identify 5



## the oversupply. 6



## The entrepreneurial spirit of the 7



## companies that develop alternative refrigerants 8



## further supported aggressive refrigerant 9



## management. These SNAP-approved products 10



## provided a hedge for the United States consumer 11



## against high prices. No one holding a patent had 12



## the illusion that these alternatives would last 13



## forever. 14



## Some of our concerns are the failure of 15



## the Rule to create a sustainable path for 16



## reclamation through the requirements of recovery 17



## of all refrigerants: 18



## For every molecule that is recovered and 19



## reclaimed, there is less demand and emphasis on a 20



## new molecule. 21



## No clear policy on what we're regulating, 2266



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## i.e. ozone depletion, global warming, greenhouse 1



## gasses, not to forget CO2e. 2



## HCFC issues are unsettled. This rule and 3



## other EPA actions were predicated on the HCFC 4



## phase-out. 5



## EPA has chosen to allow mobile 6



## applications until the year 2021 to adjust, and 7



## at the same time EPA is pulling the plug on SNAP 8



## products in 2016. 9



## Recordkeeping and reporting must be 10



## placed into the rule for proper understanding of 11



## the current and future inventory demands. 12



## Labeling of products on safety issues to 13



## include any side effects. 14



## This rule seeks to limit the HCFC 15



## production -- this rule seeks to limit the use of 16



## HCFC products, at the same time HCFC-22 and all 17



## of the direct and indirect effects go on being 18



## produced. HCFC-22 has a lower GWP than some of 19



## the SNAP alternatives. But unlike SNAP products, 20



## HCFC has an ozone-depleting factor that SNAP 21



## products don't. 2267



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We feel that EPA has to rethink the 1



## policy of recordkeeping and reporting. We have 2



## been constant in our request for EPA to require 3



## all holders, sellers and processors report these 4



## amounts, the amounts of these chemicals on an 5



## annual basis. EPA is instituting a national -- 6



## by instituting a national survey/data collection 7



## will allow the public to know what the 8



## inventories are. This action will allow the 9



## public to make comments based on facts, not 10



## assumptions. 11



## We suggest that EPA is not giving the 12



## American public all the benefit of research and 13



## development. The haste to write the rule to 14



## phase-out a class of products in favor of only a 15



## few HFO and flammable materials may result in 16



## some of the products being left on the sidelines 17



## and issues of new chemicals will not be fully 18



## captured. The jump to these new products does 19



## not ensure that all have made -- 20



## MS. FARQUHARSON: Pete, sorry to 21



## interrupt you, but we have to allow enough time 2268



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## for other folks, so thank you. 1



## MR. WILLIAMS: Oh, okay. Thank you. 2



## MS. FARQUHARSON: Thank you. Speaker 14 3



## will be George Parsons. He's from Ice-O-Matic. 4



## Is George in the room? 5



## (No audible response.) 6



## MS. FARQUHARSON: Okay. We will move on 7



## to speaker number 15, Mac Hess from Premium Spray 8



## Products. 9



## MR. HESS: You'll have to excuse me, this 10



## is the first time I've attended one of these 11



## things. I'm going to have to use my computer on 12



## this presentation. 13



## My name is Mac Hess, H-E-S-S. I'm 14



## President and Managing Partner of Premium Spray 15



## Products, a company out of Marietta, Georgia. 16



## First off, I'd like to thank you for the 17



## opportunity to present information to you today 18



## that is vital to our industry. The issue is more 19



## complex than at first glance and not just one 20



## insulation material as we have against another 21



## insulation material that does not use HFCs. And 2269



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## it's not based on who our competition is and what 1



## they're doing either. It's based on the overall 2



## effects that this has on a company like Premium 3



## Spray Products and small industry. 4



## It is about energy usage that our 5



## products provide efficiency for, and also in the 6



## process of doing that, have a positive overall 7



## effect on the environment. 8



## A little history -- and unlike the 9



## earlier speaker, I do go back to those days of 10



## the 1960s through today. When I was first in the 11



## industry, we were using the R11s, a very good 12



## product, very inexpensive, provided the highest 13



## quality insulation and fire retardant 14



## capabilities in our foams. We were phased out of 15



## the R11 in 1992 in my industry. 16



## In 1992 we went to HCFC, the 141b, which 17



## was not as good. It didn't have the fire 18



## retardancy and quality. The overall products 19



## were inferior to the R-11 products. We made good 20



## products, and we grew the industry in spite of 21



## that. 2270



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## In our industry, we phased out 141b to 1



## HFC to come into compliance with the Montreal 2



## Protocol and were using HFC-245fa, which I know 3



## you're familiar with. This product was a very 4



## very costly endeavor for us to develop, make 5



## replacements, get commercially quality products, 6



## and to meet all the test requirements that our 7



## industry required. And it also added about an 8



## additional 40 percent increase to the cost of our 9



## systems, which is -- I'm sorry. Yeah, it added 10



## about a 40 percent increase to the cost of our 11



## products. 12



## Premium Spray Products is a producer of 13



## polyurethane foam insulation, roofing, and 14



## similar products. Our major market, obviously, 15



## is the spray foam. We were involved in nonspray 16



## foam application where we also need blowing 17



## agents. And for our business, we are required to 18



## have long shelf lives, put it in drums, send it 19



## to job sites and have storage. So safety is an 20



## extremely important thing with us. 21



## The cost of replacing these products for 2271



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## our construction-only OEM customers is extremely 1



## high and forbidding for small companies like us 2



## in research time, testing, customer trials, 3



## approvals and certifications -- oh, sorry. 4



## Well, basically, in summary what I want 5



## to say is, let the market dictate which are the 6



## best products with the best ingredients. Do not 7



## overregulate or restrict quality, viable blowing 8



## agents in the U.S. We ask that additional 9



## monopolies not be created to restrain our 10



## industry and unnecessary cost. And we also would 11



## like to make sure that we are able to get sources 12



## of blowing agents from foreign sources. Existing 13



## blowing agents are proven and have gone through a 14



## very strenuous and complete testing process to 15



## ensure safety and fire -- human safety and fire 16



## regulations. 17



## Next generation blowing agents will and 18



## are coming. But rather than rush and push 19



## arbitrary deadlines, we implore you to act such 20



## that proper testing is done to ensure that the 21



## right and best alternatives are allowed to come 2272



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## to the market. And at this point in time, there 1



## just is not enough data by the formulators like 2



## us who are actually -- who actually put the raw 3



## materials together in viable commercial products 4



## to charge an absolute best path. Insulation 5



## saves energy, big time, and that means it's very 6



## important to get it right. Allow us that time, 7



## please. 8



## MS. FARQUHARSON: Okay. Thank you, Mac. 9



## The next speaker is Brian Casserilla from Kairak. 10



## MR. CASSERILLA: Good morning. My name 11



## is Brian Casserilla. That's C-A-S-S-E-R-I-L-L-A. 12



## I'm the Business Unit Manager for Kairak, a 13



## division of Illinois Tool Works. Thank you for 14



## your time. I truly appreciate the opportunity to 15



## share our thoughts regarding the proposed SNAP 16



## rule. 17



## As a quick background of Kairak, we are 18



## located in Fort Worth, Texas, and have been in 19



## operation for over 25 years. Our company 20



## manufactures self-contained commercial 21



## refrigeration fixtures and large remote systems 2273



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## for food service and food retail applications. 1



## Our products not only meet strict Health 2



## Department standards, but are also designed with 3



## our customer's operations in mind. 4



## Our team takes great pride in our 5



## system's ability to maintain safe food 6



## temperatures in the toughest kitchen 7



## environments. As we like to say in Fort Worth, 8



## Kairak is a refrigeration company of last resort. 9



## Please note, we have always taken an 10



## environmentally friendly proactive approach in 11



## our designs as demonstrated through the release 12



## of our BLU Product line. Kairak's BLU fixtures 13



## and remote systems utilize glycol as a secondary 14



## cooling agent, greatly reducing the amount of 15



## refrigerant needed in our equipment. As 16



## proposed, this SNAP rule making will 17



## fundamentally change the character of released 18



## product designs. The proposal eliminates our 19



## chosen refrigerants for both self-contained 20



## fixtures and remote systems. We also lose 134a 21



## as our preferred blowing agent for cabinet 2274



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## insulation. 1



## We ask that you consider the breadth and 2



## depth of work required to meet the current 3



## proposal deadlines for commercial refrigerant 4



## projects and blowing agents. Every one of our 5



## designs will change. Every one of our product 6



## families will need to be recertified through ETL 7



## or NSF. Every one of our building materials will 8



## need to be modified. Every piece of marketing 9



## and sales literature will need to be updated. 10



## Our entire manufacturing facility will need to be 11



## retooled to keep our employees safe from the 12



## introduction of flammable refrigerants. And at 13



## this time, not all of our suppliers have 14



## commercially available products for us to test 15



## and design into our systems. 16



## Kairak is asking for your help and 17



## partnership as we strive to continuously improve 18



## our products and designs. We request your 19



## consideration for the adjustment of the 20



## implementation time line for refrigerants and 21



## blowing agents to match the full time line given 2275



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## to the manufacturers of commercial refrigeration 1



## products based in Europe. 2



## We also ask for your consideration for 3



## the approval of additional nonflammable 4



## refrigerants for self-contained fixtures as it is 5



## our belief continued use of nonflammable 6



## refrigerants will provide an additional era of 7



## workplace safety for our employees as well as the 8



## people employed by our customers and field 9



## service agents. 10



## Thank you for your consideration. 11



## MS. FARQUHARSON: Thank you, Brian. 12



## Speaker 17 is Michael Krupa from BASF. 13



## MR. KRUPA: Thank you for the opportunity 14



## to speak at today's hearing. I am Mike Krupa, 15



## and that's K-R-U-P-A. I’m one of the Technical 16



## Managers at BASF Corporation. 17



## BASF supplies chemicals that are used to 18



## make polyurethane foams for insulation and other 19



## markets affected by the proposed HFC changes. 20



## HFCs are used as blowing agents and act 21



## as the main component to improve insulation 2276



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## properties of the foam. We have been involved in 1



## all of the previous blowing agent changes as 2



## directed by the Montreal Protocol. During all of 3



## the blowing agent changes, a great deal of 4



## formulation work is always necessary. In almost 5



## every case, a change of the blowing agent 6



## requires a major formulation change to provide a 7



## product that works for our customers. 8



## The previous changes from CFCs to HCFCs 9



## to HFCs were not easy and did not occur without a 10



## lot of challenges. There was a lot of cost 11



## incurred due to trials, production runs, and 12



## higher levels of scrap, until the formulations 13



## could be optimized for each of our customers. 14



## We're also concerned about the 15



## availability of new blowing agents. HFO products 16



## are available from Arkema and Honeywell with 17



## another product from DuPont pending TSCA 18



## approval. These manufacturers can comment on the 19



## commercial status and quantities of their 20



## available products. But the indications that we 21



## have been given are that the available supply as 2277



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## of the 1st of January, 2017, will be insufficient 1



## to meet the needs of the affected industries. 2



## The alternative low-GWP blowing agents that are 3



## readily available right now are either flammable 4



## or did not provide adequate insulation 5



## properties. 6



## There's a large capital investment and 7



## several years to implement flammable blowing 8



## agents for a customer that does not currently 9



## have that capability. Timing is our most 10



## important concern. 11



## The time required to effect the changes 12



## discussed here is significant. We estimate that 13



## simply introducing and qualifying new products at 14



## each of our affected customers will take a full 15



## five years to complete. Many of our customers 16



## require agency approvals and certifications to 17



## sell products requiring a flammability rating. 18



## These approvals are granted by Underwriter 19



## Laboratories and Factory Mutual Insurance 20



## Company. As the change in blowing agents is 21



## widespread, affecting multiple industries, UL and 2278



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## FMGlobal are likely to run into serious capacity 1



## constraints regarding their ability to provide 2



## individual product certifications per customer. 3



## As the process is often iterative, these delays 4



## will have a compounding effect on the industry's 5



## ability to change all product formulations in the 6



## required time frame. 7



## We've already implemented low-GWP blowing 8



## agent changes in some of our largest customers. 9



## These conversions took approximately five years 10



## to complete. Conversions at our small customers 11



## will likely be last. We simply do not have the 12



## time or resources to ensure a smooth transition 13



## to the new blowing agents in a two year time 14



## frame. Based on the information presented here 15



## and what we have learned from our industry 16



## partners, BASF would suggest that a delay in the 17



## implementation of the proposed rule is necessary. 18



## We would support a scheduled phase-out of HFC19



## 134a and HFC-245fa as blowing agents for nonspray 20



## polyurethane foams effective no earlier than 21



## January 1st, 2020. Thank you. 2279



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MS. FARQUHARSON: Thank you, Michael. 1



## Speaker 18 is Mary Dane from Traulsen. 2



## MS. DANE: Hi. My name is Mary Dane, 3



## that's D-A-N-E, and today I am speaking for 4



## Traulsen, which is an ITW Food Equipment Group 5



## company. We are located in Fort Worth, Texas. 6



## We have over 400 employees that manufacture 7



## various forms of commercial appliances that are 8



## used in many different industries, schools, 9



## hospitals, restaurants -- just a wide variety of 10



## applications. All of our products are used in 11



## freezing, quick chill, holding. They require a 12



## large amount of safety and performance in all 13



## different kinds of applications and heat 14



## requirements, you know, from hot kitchens to cool 15



## stores. 16



## Basically what our concern is today, 17



## besides the safety of the product and the needs 18



## of our customer, is -- is number one, our 19



## concern. And today we would like to discuss the 20



## time line proposal for the removal of a number of 21



## the refrigerants with high GWPs. We would be 2280



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## most affected by R-134a and R-404A. One is used 1



## mostly in refrigeration, the other in freezing, 2



## and of course, those that are used in the foam 3



## blowing agents which would be another whole plank 4



## to part of what we're working on. 5



## We've begun to apply these -- just a 6



## proposed scheduled to how we can come about this. 7



## I got my trusty little pencil out and we figured 8



## we have 512 base models of product, 9



## differentiations of product, and that was before 10



## I started in with hingings and doors and things 11



## like that. So if you extrapolate that out, I 12



## have more than two to 3,000 bills and material 13



## for each and every thing and that doesn't begin 14



## to go into our custom made products. Every 15



## single one of those bills and material will need 16



## to be changed in order to go from the 17



## refrigerants that we currently use to what is 18



## being proposed. 19



## We have no drop-in alternatives in the 20



## rules as stated, though they talk of proposed -- 21



## that there are potential releases. What we're 2281



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## unable to get when we speak to some of the 1



## chemical manufacturers is if there is any 2



## commitment from the EPA to even get a letter of 3



## completed file that says that they're far enough 4



## through their process that we would able to count 5



## on, or to even begin to plan on when we can go to 6



## our compressor manufacturers and ask is there 7



## even a compressor that will use the refrigerant 8



## that you're waiting for to be released. 9



## So that's kind of forced us into where we 10



## can only look at flammable refrigerants. And as 11



## you've heard from the 17 speakers before me in 12



## various forms, flammability refrigerants, while 13



## it's more of a natural and has low GWP, it has a 14



## lot of things that we are concerned about which 15



## requires us to go in and change our factories. 16



## Some of us have multiple facilities. Some of us 17



## have maybe one facility, but we're jam packed. 18



## You know, our facility is the size of seven 19



## football fields. But I'm telling you, trying to 20



## get through that thing is -- you know, is quite 21



## tight. And we have to keep current production 2282



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## going while we're switching over to something 1



## else. 2



## So frankly, we have no commercial drop3



## ins. And we've spoke to all the same people that 4



## are speaking today, and we don't see a promising 5



## supply of commercially available components and 6



## things that would be able to be available for us 7



## to even begin testing to be able to plan to meet 8



## a 2016 date. 9



## So, what little we're able to do with 10



## some of the -- from some little samples and the 11



## little quantities that we get of things to test 12



## by, we're finding that there's an energy 13



## efficiency sacrifice that puts us in risk of 14



## meeting DOE requirements that come out separately 15



## from EPA requirements. And sometimes they tend 16



## to fight against one another. So to go to meet 17



## lower GWP, we have to give up something else. 18



## So, basically one of the things we would 19



## ask today, besides a delay of the rule, is the 20



## comments are very important to us. We want to 21



## make sure that we give the EPA enough 2283



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## information, enough data. Also some of the stuff 1



## that's in the first rule that you have going on 2



## where you put the special use categories in, 3



## there's a lot of important topics we want to 4



## address to that. So we want to make sure that 5



## the rule that we're getting ready to comment on 6



## and that's due October 8th, we'd like to have a 7



## little extra time so we can take into 8



## consideration how servicing will effect some of 9



## the other things. 10



## So we would request the minimum of 2025 11



## date as far as being able to convert, especially 12



## if it requires something that's not a drop-in 13



## replacement, and a little extra time on the 14



## comments. 15



## But as always, we appreciate the EPA's 16



## openness to discussion, and we look forward to 17



## further discussion with you. Thank you very 18



## much. 19



## MS. FARQUHARSON: Thank you, Mary. 20



## Speaker 19 is Keilly Witman from Shecco America. 21



## MS. WITMAN: Hi. My name is Keilly 2284



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Witman. I'll spell the first name. It's a 1



## little more difficult than the last name. It's 2



## K-E-I-L-L-Y, W-I-T-M-A-N. And I'm here to 3



## represent a company called Shecco, which is a 4



## market development company for natural 5



## refrigerants. If there is time after everyone 6



## else has spoken, I would like to make comments on 7



## behalf of KW Refrigerant Management Strategy, 8



## where I will deal with input I've received from 9



## service techs, end-users, and equipment 10



## manufacturers on commercial systems. 11



## Right now what I'm going to focus on is 12



## self-contained units, stand-alone equipment. 13



## Some might say that delisting the HFC 14



## refrigerants with high GWPs of 134a and up as of 15



## 2016 is ambitious. But the writing has been on 16



## the wall for years. EPA has had petitions in 17



## front of it for years, and an awful lot of the 18



## industry should not be surprised that this is 19



## happening. 20



## The Atmosphere America conferences for 21



## the past three years have had limited -- we 2285



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## limited participation to 250 people. They've 1



## sold out every year. There have been 2



## presentations and business cases presented from 3



## 90-plus companies for natural refrigerants and 4



## the end-uses talked about; 60 presentations on 5



## trends in natural refrigerants, 22 of them on 6



## commercial refrigeration this past year alone; 7



## 20-plus technology case studies, all of which are 8



## available to the public. In addition to those 9



## conferences, FMI Energy features more and more 10



## presentations and commercial refrigeration and 11



## self-contained units related to natural 12



## refrigerants. 13



## The Purdue conference in July 2014 had 14



## 400-plus presentations and dozens of research 15



## papers focusing on low GWP, HFCs, HFOs, CO 2 

## , 16



## hydrocarbons, and ammonia. So, my only surprise 17



## is that others are surprised. 18



## The 2013 guide, North American Guide on 19



## natural refrigerants which surveyed 440 members 20



## of U.S. industry, resulted in a directory with 21



## over 165 HVAC and R system and component 2286



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## manufacturers and engineering firms that are 1



## already working with natural refrigerants. 2



## There were at least 4,000 light 3



## commercial refrigeration units in the U.S. using 4



## hydrocarbons or CO 2 

## by the end of 2012. UL has 5



## standards for hydrocarbons and CO 2 

## use in 6



## commercial refrigeration. ASHRAE issued a 7



## position document on natural refrigerants in 2009 8



## and reaffirmed it in 2011. AHRI released its 9



## report on low-GWP refrigerants also. 10



## A large number of U.S. manufacturers have 11



## relied on the EPA doing what it has stated it is 12



## going to do. They invested in technology that 13



## uses environmentally friendly refrigerants and 14



## provide energy efficiency gains. Industry needs 15



## certainty to invest. Pulling back on EPA's plans 16



## is a disincentive for those in industry who 17



## prepared for the future. Why would anyone invest 18



## in environmentally friendly technology ahead of 19



## time if EPA halts progress for those who did not 20



## see the writing on the wall or chose to ignore it 21



## to catch up? 2287



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## EPA should not allow itself to be misused 1



## as a protectionist organization for competitors 2



## who cannot compete. Shecco is in the process of 3



## completing its market research on the use of 4



## natural refrigerants for 2014. Data will be 5



## available towards the end of this year as well as 6



## a new directory of companies that are fully ready 7



## and eager to meet the demand that would be 8



## reflected if the SNAP rule went forward in 2016. 9



## Shecco will be providing further data to 10



## EPA in comments by the October deadline, and a 11



## position on EPA's questions about other options 12



## like splitting self-contained into large charge 13



## 134A units and small charge low-GWP units, which 14



## will only provide a perverse incentive to certain 15



## manufacturers to increase the amount of 16



## refrigerant used in these units. 17



## Thank you for the opportunity to speak on 18



## behalf of Shecco today, and thank you for holding 19



## this hearing. 20



## MS. FARQUHARSON: Thank you, Keilly. Is 21



## John Cabaniss present? 2288



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## (No audible response.) 1



## MS. FARQUHARSON: Great. So, John will 2



## be speaking on behalf of the Association of 3



## Global Automakers. 4



## MR. CABANISS: Good morning. My name is 5



## John Cabaniss. That's spelled C-A-B-A-N-I-S-S, 6



## Director of Environment and Energy at the 7



## Association of Global Automakers. We also 8



## represent 12 automakers that sell cars worldwide. 9



## If I could ask to have my statement that 10



## I gave you put in the record, and I'll just focus 11



## on a couple of things to expand on the remarks 12



## made by my colleague, Julie Becker earlier, from 13



## the Auto Alliance. There are really two things 14



## that, as she pointed out, are of major concerns 15



## to us. 16



## One is the delisting date for cars for 17



## model year '21. We also would like to see more 18



## flexibility. We want to see the flexibility 19



## preserved that's in the federal greenhouse gas 20



## program already for vehicles, and we agree with 21



## the recommendation that the alliance made of 2289



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## postponing the delisting until the end of model 1



## year '25. 2



## That said, we agree with the assessment 3



## that EPA has made in the rulemaking, proposed 4



## rulemaking, that the transition will occur 5



## earlier for most vehicles, and that most will be 6



## transitioned probably by the '21 model year. 7



## However, the flexibility, the compliance 8



## flexibilities that Ms. Becker mentioned are 9



## highly valued by the companies, and as she noted, 10



## the emphasis here is on changing vehicles during 11



## major redesigns. 12



## While the five-year cycle is an average 13



## that was mentioned in the proposal, some models 14



## have much longer redesign cycles, up to seven or 15



## eight years, and in the past some have even been 16



## longer. 17



## For vehicles that were redesigned already 18



## for the 2016 Model year, which begins in just six 19



## months, those that are already locked. And if 20



## they're working on a seven or eight model year 21



## cycle for those models, they wouldn't come up 2290



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## again until '23 or later. So, this is why this 1



## flexibility could be important for at least a 2



## small set of these vehicles through '25. 3



## The other big problem for us is the 4



## export rule, and the main point there of course 5



## is that right now about 2 million are exported 6



## from the U.S. annually, according to Department 7



## of Commerce data. They value those exports at 8



## $52 billion a year. About half of those exports 9



## go to Canada or Mexico. Another 10 percent go to 10



## Europe, so there's a sizable fraction of those 11



## exports that will be transitioning to low-GWP 12



## refrigerants because of either the existing 13



## requirements in Europe or what we'll find here in 14



## North America because of the Federal GHG program 15



## and under NAFTA. But that still leaves 40 16



## percent of vehicles that go to other 17



## destinations, which is a sizable number, has a 18



## significant value. 19



## There are three undesirable outcomes that 20



## could occur. One, by imposing the rule on those 21



## exports -- one is if you -- the risk is that the 2291



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## companies would move the production outside of 1



## the U.S. That would, of course, have job impacts 2



## and balance of payment impacts that would be 3



## significant -- potentially. 4



## Another outcome would be that the 5



## companies could build the vehicles -- continue to 6



## be able to build the vehicles in the U.S. and not 7



## charge the system until they get it outside of 8



## the U.S. That has the undesirable effects of 9



## poor quality control at the factory, and other 10



## potential environmental problems because of more 11



## leakage when you do charge it. 12



## So, the other complication with exports 13



## is that, as we found here in the U.S., when we 14



## did SNAP rules for some refrigerants that are 15



## slightly flammable, there are often fire and 16



## safety code requirements that have to be 17



## addressed along with other things in order to be 18



## able to put those refrigerants into commerce. 19



## Here in the U.S., it took us several years 20



## working with EPA to get state fire codes updated 21



## to allow some of those refrigerants to be sold 2292



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## here. We suspect that some of the same things 1



## will happen in other markets around the world, 2



## and so we again would caution you about applying 3



## the rule to exports going to markets that do not 4



## support these refrigerants. Thank you very much. 5



## MS. FARQUHARSON: Thank you, John. 6



## Speaker 21 is Stephen Schaefer from Hoshizaki 7



## America. 8



## MR. SCHAEFER: Good morning. I'm Stephen 9



## Schaefer, S-C-H-A-E-F-E-R. 10



## I work for Hoshizaki America and we thank 11



## the EPA for their important work and the 12



## opportunity for industry engagement in this 13



## process. 14



## Hoshizaki America is a small business 15



## from Georgia that specializes in food equipment, 16



## especially commercialized machines and commercial 17



## refrigerators and freezers. We pride ourselves 18



## on quality, reliability and being stewards to the 19



## environment. 20



## Hoshizaki America has been chosen as 21



## Energy Star partner of the year two years running 2293



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## due to the ingenuity involved in qualifying many 1



## Energy Star products. 2



## Hoshizaki America would like to join the 3



## EPA on a mission to achieve goals in the SNAP 4



## program without compromising occupational health, 5



## public safety or market competitiveness. The 6



## choices that the EPA is giving the commercial 7



## refrigeration industry to phase-out R-134a and 8



## R404-A present many challenges and complications 9



## on all the fronts that could cripple the industry 10



## if not given proper evaluation. 11



## One of the primary challenges in this 12



## proposal is limited substitutes. Carbon dioxide 13



## is in no way a viable replacement for R-134a or 14



## R-404A in stand-alone units. The pressures 15



## needed by the refrigeration system are five times 16



## that of the current refrigerants. To change the 17



## system to accept carbon dioxide would result in 18



## larger pipes and a high risk of death for 19



## undertrained service personnel and innocent 20



## bystanders when servicing. 21



## No suppliers, except one, have even 2294



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## attempted to offer carbon dioxide components for 1



## the industry. Carbon dioxide has been known for 2



## decades, but has never been considered viable due 3



## to the lack of support, components, and failures 4



## in the industry. 5



## Isobutane and propane are also suggested 6



## replacements due to low GWP. These choices have 7



## restrictions and risks due to high flammability 8



## that make the design cycle complicated and 9



## problematic for potential injuries to school 10



## children, hospital patients and prisoners to name 11



## a few. 12



## Risks, such as the potential for sparks, 13



## in the current system would need to be carefully 14



## reviewed in relation to flammable refrigerants. 15



## High flammability refrigerants pose risk of death 16



## when combined with service people who are thrust 17



## into working on the equipment without the proper 18



## amount of training time. 19



## Manufacturers' production lines would 20



## also need to be transformed to take into account 21



## flammable charge. On top of this, there are 2295



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## strong concerns that energy efficiency for the 1



## alternative refrigerants that could pose a great 2



## risk to the industry. The Department of Energy 3



## has imposed much tighter restrictions for energy 4



## use, and each model must be designed to meet 5



## these requirements in order to be sold. 6



## Refrigerant change is also to be handled 7



## concurrently with the mandate to change foam 8



## blowing agents by 2017. Added to the list of 9



## mandatory tasks, each unit must be evaluated for 10



## safety and sanitation which adds time to the 11



## design cycle. 12



## Hoshizaki America estimates that the 13



## minimum time for each model group is 30 weeks due 14



## to design, testing, and approval for overloaded 15



## third-party approval agencies. There is no way 16



## that we could do this in two years and component 17



## manufacturers, such as compressors, have 18



## specified they do not have products ready for 19



## each model that we have until two to three years 20



## from now. 21



## As demonstrated, the complexity of 2296



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## changing refrigerants while simultaneously 1



## designing to meet new mandatory energy efficiency 2



## requirements makes it impossible to deliver in 18 3



## months. This phase-out should be done 4



## methodically, with proper alternatives given not 5



## only to help the environment, but also properly 6



## prioritize the safety for manufacturers, service 7



## personnel and end-users alike. 8



## If the alternatives are not as efficient 9



## and end up requiring more energy, the net result 10



## would be an increasing carbon footprint and even 11



## more damage to the environment. 12



## Hoshizaki America implores the EPA to 13



## allow for a 10 year phase-out for commercial 14



## refrigeration to not only allow for refrigerant 15



## and component manufacturers to come up with 16



## viable nonflammable choices, but also for the 17



## manufacturers to save countless lives by not 18



## rushing to change over refrigerant without the 19



## time for each safety aspect to be considered. 20



## Unlike previous changeovers, the 21



## alternatives given now are not truly in the 2297



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## infant stage for entering the U.S. Market. 1



## Hoshizaki America agrees that we need to be good 2



## stewards for the environment, but as the original 3



## intent of SNAP, flammable refrigerants should not 4



## be the first choice and proper time should be 5



## given to safeguard, so to protect innocent lives 6



## from being lost. 7



## Thank you for your time in this process. 8



## MS. FARQUHARSON: Thank you, Stephen. 9



## The next speaker is Michael Coyle from Bally 10



## Refrigerated Boxes. 11



## MR. COYLE: Good morning and thank you 12



## for the opportunity to speak today. My name is 13



## Mike Coyle, that's C-O-Y-L-E. I'm the President 14



## of Bally Refrigerated Boxes. 15



## Bally is a leading U.S. manufacturer of 16



## commercial refrigeration equipment, and we 17



## produce a variety of insulated panels that are 18



## sold both domestically and internationally. The 19



## company's principle markets are institutional 20



## food service and refrigerated warehouses. 21



## Bally's customer base includes hundreds 2298



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## of food service equipment dealers and 1



## refrigeration wholesalers. Most of our customers 2



## lack formal engineering personnel and look to us 3



## for guidance and interpretation of new 4



## regulations as they relate to the products that 5



## we manufacture. 6



## Bally is very concerned with the proposed 7



## SNAP rule to phase out HFC-245fa by January 1st, 8



## 2017. Bally does support the gradual phase down 9



## of HFCs across many applications. However, a 10



## more responsible timetable must be considered for 11



## our sector of the market. The current timetable 12



## is virtually impossible to achieve, and I will 13



## attempt to put into context the issues that 14



## surround my concern. 15



## Bally manufactures structural insulated 16



## panels that range from 6 to 28 foot in length, 17



## any new urethane foam formulation needs to be 18



## thoroughly tested for structural integrity, 19



## insulating value, flame spread, smoke generation, 20



## adhesion properties and proper flow through our 21



## existing foam processing equipment to adequately 2299



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## fill these panels. 1



## And I need to comment -- the raw testing 2



## costs and the resource divergent cost to Bally 3



## and the individual companies in our industry will 4



## be enormous. Also we don't know how the limited 5



## number of testing labs will be able to 6



## accommodate the large burden of testing for all 7



## of the companies that will need to go through the 8



## process. These tests are Underwriters Lab, 9



## Factory Mutual, Miami Dade Structural Testing, 10



## DOE K Value and R Value Testing that's now 11



## promulgated, IBC and all local building codes as 12



## they relate to our foam insulated structures. 13



## Bally is not aware of any existing HFO-based 14



## Class One system that is available for the 15



## industry right now to test in a production 16



## environment. To my knowledge, only laboratory 17



## lot sizes of pre-blended systems have been made 18



## available to our industry. 19



## Our industry generally procures and 20



## stores raw materials in large 40,000 pound 21



## shipments, therefore shelf life and solubility of 22100



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## any new HFO on the polysystem requires it to be 1



## thoroughly tested and eliminated as having any 2



## potential issues. We are not certain of the 3



## chemical companies’ production capacity to cover 4



## the millions of pounds required for our segment 5



## of the industry. 6



## We believe that foreign manufacturers of 7



## insulated panels will begin to import finished 8



## panels that have either HFC-141b or 245fa in 9



## their finished composite panel, and that will be 10



## cost disadvantageous to Bally and our other 11



## competitors domestically. We have seen this 12



## example in the past. 13



## We have no data currently about the 14



## toxicity of the system, but we do plan to test 15



## that thoroughly. We asked EPA to do the 16



## following: please delay the implementation and 17



## phase-out of 245fa until at least 2020, 18



## preferably longer. Based on my personal 19



## experience during the change to 245fa, it will 20



## take at least this long to perfect the 21



## commercialization of the foam system. Thank you 22101



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## very much. 1



## MS. FARQUHARSON: Thank you, Michael. 2



## The next speaker is number 23, Jason Paquette 3



## from Structural Concepts. 4



## MR. PAQUETTE: Good morning. My name is 5



## Jason Paquette. It's P-A-Q-U-E-T-T-E. 6



## Structural Concepts would like to thank the EPA 7



## for the opportunity to appear before you today. 8



## We are a privately held company with 480 9



## employees located in Mesquite in Michigan. We 10



## are a producer of remote and stand-alone 11



## commercial refrigerated units for the retail and 12



## food service industry. Eighty percent of our 13



## equipment is stand-alone with the vast majority 14



## of our cases falling in the three-quarter to 15



## three horsepower range. 16



## We have over 600 active models and -- 17



## MS. FARQUHARSON: Jason, I'm sorry. Do 18



## you mind speaking in the mic, please? 19



## MR. PAQUETTE: We have over 600 active 20



## models in our product offering. SCC supports the 21



## efforts to reduce the overall energy usage and 22102



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## carbon footprint our product has on the 1



## environment. With each phased down of 2



## refrigerant gases in the past, there has been a 3



## readily available alternative refrigerant that 4



## required no more than a compressor and valve 5



## change. Today, we are left with only flammable 6



## refrigerants or a high-pressure refrigerant with 7



## no component availability and reduced efficiency 8



## rates at elevated temperatures. 9



## With the current charge limits on 10



## flammable A3 refrigerants, only approximately 15 11



## percent of our product line could be converted to 12



## a hydrocarbon refrigerant with a single 13



## condensing unit. The rest of the product 14



## offering would need to go to multiple condensing 15



## units which would in turn increase energy 16



## consumption. 17



## In addition to compressors and valves, 18



## heat exchanges and electrical safety components 19



## need to be designed into the product to conform 20



## to current UL, NSF, and DOE regulations. These 21



## units would need a complete redesign of the 22103



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## refrigeration system and have to be retested and 1



## recertified. 2



## To keep the charge limit down, hot gas 3



## condensate heaters would need to be replaced with 4



## electric heaters, again increasing overall energy 5



## consumption that could potentially put the unit 6



## over the allowable DOE energy levels. For a 10- 7



## year life expectancy, this would result in 8



## increased energy and an increased overall carbon 9



## footprint between 10 and 40 percent over our 10



## 404A. 11



## Many customers have concerns about 12



## flammable products placed into their store 13



## environments. Service companies would need to be 14



## trained to handle these refrigerants. Just 15



## implementing the charging and handling of the 16



## flammable refrigerant in a manufacturing 17



## environment would take several years. 18



## The only other refrigerant in 19



## consideration for stand-alone refrigerated units 20



## is R-744. Currently, there are only a few 21



## compressor manufacturers that produce CO 2 22104



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## compressors, and these are primarily for small 1



## vending machines and large refrigerated rack 2



## manufacturers with barely any offerings in 3



## between. The major compressor manufacturers of 4



## fractional and small horsepower compressors have 5



## abandoned the possibility of producing a CO 2 6



## compressors as it is not economically feasible 7



## for them with the increased material thicknesses 8



## due to the high pressures and the inherent 9



## inefficiency of CO 2 

## when ran transcritical. 10



## With compressors that are double the weight of 11



## their HFC counterparts, the increased material 12



## and increased shipping weight, again, adds to the 13



## overall carbon footprint. 14



## When ran above the critical point (which 15



## many stores are going to be up to 80 degrees) so 16



## it would be common, the systems consume much more 17



## energy than conventional systems today. Using 18



## data from one CO 2 

## compressor manufacturer with a 19



## 95 degree gas cooler temperature, the overall 20



## energy increases by 45 percent from the current 21



## R-404A compressor. This inefficiency would push 22105



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## the case over the allowable energy levels as 1



## dictated by the DOE and exceed the R-404A carbon 2



## footprint by approximately 30 percent. 3



## Both of these alternative refrigerant 4



## choices would leave our customers with costly, 5



## less efficient product. The current proposal 6



## would force a large percentage of our product out 7



## of the market due to the charge limits, component 8



## availability, regulatory limitations and time 9



## lines. It will take tens of thousand of hours to 10



## redesign and test new systems and making a 11



## January 2016 date unfeasible. 12



## The EPA cannot just focus on the GWP 13



## number for a given refrigerant without taking 14



## into consideration the overall energy usage and 15



## the overall carbon footprint of the equipment 16



## itself. If the industry is forced to go to only 17



## these refrigerants, we find ourselves in a 18



## situation where we no longer meet the energy 19



## requirements set forth by the Department of 20



## Energy. 21



## This brings us to the need for additional 22106



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## low-GWP refrigerants. Currently, SNAP has 30 1



## refrigerants submitted to them for approval. 2



## We've tested some of these refrigerants with very 3



## good results. HFO blends such as R-448A and 4



## R-449A have one-third the GWP of R-404A and 5



## provide up to a 10 percent energy reduction while 6



## still remaining an A1 nonflammable, low pressure 7



## refrigerant. We, as well as other CRE 8



## manufacturers, have evaluated this refrigerant in 9



## our labs and have validated these findings. 10



## In lieu of this, the supermarket systems 11



## and condensing units are allowed refrigerants 12



## that standalone retail systems are not. 13



## Standalone refrigeration units should be allowed 14



## to use refrigerants such as R-407A and R-407C, 15



## just like the supermarket systems. While still 16



## not being able to meet the January 2016 date, 17



## these alternatives could be implemented 18



## dramatically faster than the proposed 19



## alternatives. 20



## With the cost, safety, and regulatory 21



## component availability concerns with the current 22107



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## proposed alternatives for standalone 1



## refrigeration units and the sheer amount of time 2



## it would take to redesign over 600 models, we 3



## would need up to 10 years to implement across all 4



## of our models. If the supermarket refrigerant 5



## alternatives that are still on the acceptable 6



## list for the supermarkets, or ideally the HFO 7



## blends could be added to the allowable 8



## refrigerant usage list, implementation could be 9



## done in a much faster time frame. Thank you. 10



## MS. FARQUHARSON: Thank you, Jason. 11



## Speaker 24 is next, Terry Brooks from CrownTonka, 12



## ThermalRite. 13



## MR. BROOKS: Thank you for the 14



## opportunity. My name is Terry Brooks. I'm with 15



## CrownTonka, Thermalrite International Cold 16



## Storage. That's B-R-O-O-K-S. We're 17



## manufacturers of walk-in coolers and freezers 18



## located in Plymouth, Minnesota with six 19



## manufacturing locations. 20



## The proposed ruling would be extremely 21



## damaging to small family-owned businesses such as 22108



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## ours. At this time, there is no economical 1



## replacement for blowing agents currently in use. 2



## The switch to alternatives would not only raise 3



## the cost of our products, but also saddle the 4



## walk-in cooler freezer companies, many of which 5



## are small privately-held businesses such as ours, 6



## with huge investments and testing and equipment, 7



## which would put many of us out of business. 8



## Further, the cost of our products would 9



## rise significantly, hurting our customers, many 10



## of whom are independent restaurants and grocery 11



## stores. 12



## This ruling should be postponed or 13



## delayed until a viable alternative blowing agent 14



## is commercially available. We propose at least 15



## 2020. The proposed rulemaking also would impact 16



## our industry's ability to comply with the DOE 17



## regulations that have currently been enacted. 18



## Thank you very much for the opportunity. 19



## MS. FARQUHARSON: Thank you, Terry. 20



## We're going to skip ahead to number 26, Scott 21



## Lewit from the Structural Composites and Compsys. 22109



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MR. LEWIT: Good morning, and thank you 1



## for allowing me to speak. I am Scott Lewit, 2



## L-E-W-I-T, President of Structural Composites and 3



## Compsys Inc., a small businesses located in 4



## Melbourne, Florida. We formed in 1987, and we 5



## currently employ 40 people from Ph.D. to high 6



## school graduates. We supply the composites 7



## industry with cutting-edge technology and 8



## products that affordably improve efficiency. Our 9



## PRISMA Preform Technology is a game-changing 10



## technology broadly employed in the recreational 11



## marine industry, and in the process of 12



## transitioning into the broader transportation, 13



## infrastructure and building construction markets. 14



## The technology allows for high rate 15



## production of lightweight, load-bearing 16



## composites. We can support the loads of a 17



## highway bridge deck, or we can provide superior 18



## insulation and structures to trailers, buses, 19



## railcars, recreational vehicles and intermodal 20



## containers, just to name a few. 21



## Our technology has recently received 22110



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## national recognition. We won the 2014 National 1



## Innovation Award. We won the 2014 Tibbett's 2



## Award. We won three congressional medals of 3



## merit for our technology, all derived from small 4



## business innovative research work for the Navy. 5



## We are survivors of the great economic 6



## downturn. We are more recently survivors of 7



## sequestering and government shutdowns. We have 8



## been busy providing leadership and technology to 9



## help the nation. And in doing so, we are 10



## creating the groundwork for a great resurgence in 11



## U.S. manufacturing using advanced composites. 12



## In the DOD, we have proven the benefits, 13



## lowered manufacturing costs, decreased weight. 14



## This gives us increased efficiency, performance, 15



## and payload ability. 16



## We recently teamed and are a key partner 17



## in the Composites NOW! Team. Here, we are 18



## competing for $170 million Department of Energy 19



## and industry-funded effort to bring composites 20



## into the transportation, wind energy, and 21



## compressed gas storage markets. Our small 22111



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## business, Structural Composites, was able to 1



## commit over $30 million of cost share to the 2



## team. While we have not heard if we have won or 3



## not, the effort has already caused a critical 4



## mass accelerating our technology into the 5



## transportation segment. 6



## The core of our innovation is the PRISMA 7



## Preform technology. Here, we take fiber 8



## reinforcements and we cast them into shape using 9



## expanding 134A based polyurethane foam produced 10



## by BSF. A key aspect of our technology is the 11



## foam expanding into the fabric, but not going 12



## through it, allowing the outer fiber layers to be 13



## ready for accepting resin. 14



## Several years ago, we had the daunting 15



## task of switching from R-22 to 134a. At that 16



## time, we had the 134a material available and had 17



## run trials to determine that it could be adapted. 18



## The EPA granted us an extension to allow this 19



## transition. We made it, but it was costly for 20



## this small business and it sucked resources from 21



## our core mission. 22112



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Ladies and gentlemen, the proposed change 1



## to ban 134a is widely unknown to the impacted 2



## industry, small businesses like us. 3



## The same 134a that we use in our 4



## performing process is key to several industries, 5



## some of which we supply such as U.S. Coast Guard 6



## approved foam, which is widely used in the 7



## recreational marine industry. Here the foam 8



## provides both structure and floatation, thus the 9



## change in blowing agent involves much work and 10



## buy-in from our boat building customers to the 11



## regulatory agencies such as the U.S. Coast Guard, 12



## American Bureau of Shipping, American Boat and 13



## Yacht Council, and the DOD depending on 14



## application. 15



## We ask for balance. Our PRISMA 16



## technology is proven to provide significant 17



## weight, performance, and cost advantages. The 18



## efficiency is dramatic, from DOD craft that are 19



## 40 percent more payload fuel efficient to 20



## refrigerated trailers that are over 25 percent 21



## more thermally efficient and 15 percent lighter 22113



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## and will have far longer extended service 1



## performance. Clearly, the efficiency and reduced 2



## manufacturing impact of our technology offsets 3



## the very small amount of nonrecurring 134A foam 4



## used. 5



## Based on our experience with R22 to the 6



## 134a transition, it is not by any means a snap. 7



## Once a proven alternative is available, we will 8



## need four to six years for transition. This 9



## would give us time for plant evaluations, 10



## customer acceptance trials, agency certification 11



## and plant conversion. As we have no alternative 12



## at this time, we ask that the composites industry 13



## be exempt from the rule change and remain exempt 14



## until a viable alternative is available. 15



## Thank you for your consideration of small 16



## business and U.S. manufacturing as you consider 17



## this decision. We will be sending written 18



## comments. Thank you. 19



## MS. FARQUHARSON: Thank you, Scott. 20



## Speaker 27 is Paul Ramsbottom from American Panel 21



## Corporation. 22114



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MR. RAMSBOTTOM: Good morning. Paul 1



## Ramsbottom, R-A-M-S-B-O-T-T-O-M, American Panel. 2



## I'm here today representing American 3



## Panel, a family-owned small business company 4



## manufacturing walk-ins for the commercial food 5



## industry in Central Florida. 6



## As a small company we are especially 7



## sensitive to this. In our opinion, it's an 8



## accelerated phase-out of HFC refrigerant. 9



## Accelerated phase-outs require extra expense, man 10



## hour to condense the time line, and make fully 11



## operational using the new foam insulation. 12



## This dedication of our time and resources 13



## pushes aside our other, what I call other new 14



## product commitments. Basically, it's a big 15



## problem for us. 16



## We have, as a company, gone through the 17



## CFC phase-out from that foam insulation to the 18



## HCFC-141b foam phase-out, and then into HFC19



## 245fa. Each of those changes was never clear cut 20



## for us. The time from being advised by our foam 21



## insulation supplier that they had an acceptable 22115



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## formulation until production startup of this new 1



## foam was never less than one year and was 2



## actually closer to two years. There was always 3



## issues, and the foam insulation -- our present 4



## foam insulation supplier is still six to eight 5



## months away from having field trial samples of 6



## the HFC-free foam. 7



## We've heard earlier that there are some 8



## natural refrigerants. There clearly is not a 9



## natural refrigerant available in foam insulation 10



## that we would use in the panels in panel 11



## manufacturing. And then also, we do not care to 12



## use pentanes because DOE has recently imposed the 13



## requirements for -- new requirements for our 14



## walk-in panel manufacturers, and those 15



## requirements do not permit us to use pentanes 16



## because they would make us increase the panel 17



## thickness size, which again puts a burden on us 18



## economically because we have to change our 19



## fixtures. 20



## Although there's been some announcements 21



## and publications about a major appliance 22116



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## manufacturer using HFC -- sorry, HFO foam 1



## insulation, this formulation is not a Class One 2



## foam. For those that do not know, Class One is a 3



## requirement for our industry to certify us for UL 4



## and Factory Mutual. It allows us to manufacture 5



## a large rated -- fire rated structures such as 6



## refrigerator warehouses. 7



## We do not have a Class One foam precedent 8



## right now, so even if this could happen within 9



## the next year, this provides us little time to 10



## certify the foam with UL and in our case with 11



## Factory Mutual. And you've heard from another 12



## manufacturer, Miami Dade, all these panel 13



## manufacturers represented here today, they would 14



## fall in line -- they would have to fall in line 15



## and wait their turn for the panel certification. 16



## Factory Mutual, for instance, quotes just 17



## on normal panel certification process of six 18



## months. So given that there is eight to 10 major 19



## panel manufacturers here, this doesn't make 20



## logical sense to us. 21



## Lastly, we're just asking for the delay 22117



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## in implementation of the HFC phase-out until 1



## 2020. This allows time to choose an appropriate 2



## manufacturer, work with them through field tests 3



## of this new formulation and use up existing HFC4



## 245fa foam stock and deplete our stock panels 5



## while implementing the new foam into our plasto 6



## sink tanks and dispensing equipment. Thank you 7



## for your time and consideration. 8



## MS. FARQUHARSON: Thank you, Paul. Is 9



## Lee Thames present, Thermo-Kool? 10



## MR. THAMES: I am Lee Thames, 11



## T-H-A-M-E-S, Vice President and Operations 12



## Manager of Thermo-Kool. We're a small business, 13



## walk-in cooler manufacturer located in Laurel, 14



## Mississippi. 15



## We currently use an HFC blowing agent to 16



## expand the urethane foam of our walk-in panels. 17



## That is on the unacceptable list by EPA. Since 18



## 1992, due to the Montreal Protocol we have gone 19



## through two blowing agent changes, from a CFC to 20



## an HCFC, and now to an HFC. Each time this has 21



## occurred, processability becomes more and more 22118



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## difficult -- it's more and more difficult, as 1



## well as extreme cost, time, and labor due to the 2



## equipment changes and numerous other parameters 3



## that come with each change that highly affect our 4



## business. 5



## Due to the proposed SNAP rule by EPA to 6



## phase-out the current HFC blowing agents, we are 7



## extremely concerned about a number of issues 8



## which are the time span, the cost and efficiency. 9



## We believe the change to the alternative blowing 10



## agents is inevitable. However, the proposed date 11



## of January 1st, 2017, especially the idea to 12



## accelerate the now announced unacceptable blowing 13



## agents to 2016 is totally unreasonable. We 14



## propose a date of at least no sooner than 2020. 15



## There are three refrigerant companies 16



## that have developed HFOs and only one has a 17



## plant, to my knowledge, that is manufacturing 18



## product. However, there is no way that the 19



## current capacity of this plant can handle the 20



## number of walk-in cooler companies and other 21



## panel manufacturers that use blowing agents by 22119



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## 2017. In discussion with one of the plant 1



## account managers with one of these refrigerants 2



## plants, it was stated that after engineering 3



## drawings for the plan are completed, it would 4



## take approximately 18 to 24 months to erect a new 5



## manufacturing plant that could be built either in 6



## the states or possibly even in Asia. 7



## The concern is that there is not enough 8



## supply of the refrigerants used as blowing agents 9



## to supply the entire walk-in manufacturing 10



## industry. The foam system houses, BASF, Dow, and 11



## Carpenter to name a few, do not have systems 12



## utilizing HFOs as blowing agents readily 13



## available. Based on past development schedules, 14



## it takes a minimum of at least two years for the 15



## flammability, toxicity, and field testing before 16



## they feel confident to actually sell a new system 17



## to their customers. 18



## As a panel manufacturer, the last thing 19



## we need is failure or a safety-related issue to 20



## occur with our end-users that consists of 21



## schools, restaurants, hospitals, hotels, prisons, 22120



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## et cetera. It took a major appliance 1



## manufacturer five years to do developmental 2



## testing to qualify and get an HFO commercially 3



## available as a blowing agent. 4



## Shelf life is also a major concern as 5



## mentioned earlier, that the solubility does not 6



## allow the product to stay within the system long 7



## enough to actually produce. 8



## There are a lot of uncertainties 9



## regarding equipment modifications that would most 10



## likely be required to adjust to the new molecules 11



## and the HFOs. And if hydrocarbons are used as an 12



## alternative, explosion proof motors and equipment 13



## would be required. Lead times of the equipment 14



## would be significantly increased since this would 15



## affect all of the manufacturers. 16



## There would also be a significant cost 17



## burden. Equipment modifications due to changing 18



## to an HFO or a hydrocarbon blown system would be 19



## in the neighborhood of anywhere from $100,000 to 20



## $500,000. Third-party testing, such as UL and 21



## FM, are a major cost burden that is required, not 22121



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## only for fire safety but for numerous other 1



## municipalities requiring seismic, wind, and other 2



## load bearing tests. Every time there is a foam 3



## formulation change, new testing is required such 4



## as mentioned earlier, Miami Dade County, Florida 5



## Building Code, Houston approval, those types of 6



## places that could cost it in excess of $150,000 7



## for the various tests. Certifying labs would not 8



## be able to manage the amount of testing in the 9



## time frame proposed since this change would 10



## affect every walk-in manufacturer in the 11



## industry. 12



## We are just now also recovering from the 13



## lost margins due to the recession that we have 14



## encountered over the recent years, especially 15



## small businesses are struggling to get back to a 16



## financially stable condition and just need more 17



## time before we have to go through the next 18



## generation of blowing agent changes. 19



## It has been -- 20



## MS. FARQUHARSON: Thank you, Lee. Sorry. 21



## We have to allow enough time for other speakers. 22122



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MR. THAMES: Okay. Thank you very much. 1



## MS. FARQUHARSON: Thank you. The next 2



## speaker is Charlie Souhrada from North American 3



## Association and Food Equipment Manufacturing. 4



## MR. SOUHRADA: Good morning. My name is 5



## Charlie Souhrada. I'm Director of Members 6



## Services for the North American Association of 7



## Food Equipment Manufacturers. My last name is 8



## spelled S-O-U-H-R-A-D-A. 9



## NAFEM appreciates the opportunity for 10



## industry engagement and discussion regarding the 11



## delisting process outlined in SNAP. NAFEM 12



## represents more than 500 member companies, many 13



## of which you've heard from this morning and many 14



## which you'll hear more from later. 15



## These companies manufacture commercial 16



## food service equipment and supplies for the food 17



## away from home market. These member companies 18



## make the tools used to prepare, cook, serve, and 19



## store food safely, including a variety of 20



## refrigeration products ranging from blast 21



## chillers, coolers, freezers, and even ice cream 22123



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## and soft serve machines. 1



## NAFEM has a long history of supporting 2



## the prevention of climate change and the 3



## reduction of energy consumption. More than 10 4



## years ago, NAFEM members actively worked with the 5



## EPA to help start the Energy Star program for 6



## commercial food service equipment. That active 7



## support continues today and includes other 8



## environmentally focused activities such as the 9



## development of life cycle and carbon footprint 10



## calculators in helping our members understand 11



## global environmental standards such as WEEE RoHS. 12



## We do these things because our customers demand 13



## them. They're good for business, good for the 14



## environment, and they're the right thing to do. 15



## NAFEM is gravely concerned that EPA's 16



## proposed SNAP rulemaking will impose unintended 17



## negative consequences, including possibly 18



## compromising the occupational health of employees 19



## through the commercial refrigeration 20



## manufacturing, distribution, service, and end-use 21



## markets. These dangers also could extend to the 22124



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## public at large as flammable refrigerants are 1



## forced into certain market applications. In all 2



## applications, EPA's proposal does not provide 3



## adequate time to research, design, test, train, 4



## and certify these products. 5



## In addition, our industry has been 6



## inundated by various DOE energy standards and 7



## EPA's July 9th proposal to add refrigerants under 8



## SNAP. Because of the timing and cumulative 9



## impacts of these government actions, we 10



## respectfully request a 60 day comment period 11



## extension to this proposal. 12



## If finalized, this proposal will have 13



## dire consequences on our industry. The proposal 14



## will raise the cost of finished goods while 15



## reducing the number and diversity of products 16



## consumers need in the market place. U.S. 17



## manufacturers also will be significant 18



## disadvantaged in the domestic and global markets 19



## because European manufacturers have a significant 20



## head start with these deadlines and are more 21



## likely to meet the strict requirements than 22125



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## domestic manufacturers. 1



## These impacts, paired with the high 2



## levels of capital required to develop, 3



## manufacture, and test products with new 4



## refrigerants by the short compliance window of 5



## 2016, will cause refrigeration manufacturers to 6



## cut jobs and move out of the refrigeration 7



## industry, or close their doors entirely. For 8



## these reasons, we propose an alternate time frame 9



## based on industry deliverables, experiential 10



## knowledge, and to assure the success of all 11



## businesses in the safe transition to low-GWP 12



## refrigerants. 13



## NAFEM members are greatly concerned that 14



## the proposal, as written, limits our industry to 15



## four refrigerant options: ammonia, CO 2 

## , isobutane, 16



## and propane. Considering current mandates 17



## originating out of the DOE regarding energy 18



## efficiency combined with the toxicity, 19



## flammability, and costs of these alternatives, 20



## the industry is facing lengthy research and 21



## engineering challenges. 22126



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Based on the experience by European 1



## manufacturers and prior changes within the 2



## domestic industry, we believe that EPA should 3



## provide at least a 10-year time frame for its 4



## proposed conversion. While we appreciate EPA's 5



## willingness to meet with NAFEM and other affected 6



## stakeholders, NAFEM believes that EPA's docket 7



## lacks inappropriately robust industry analysis of 8



## the food refrigeration equipment manufacturing 9



## industry, potential impacts on small 10



## manufacturers, as well as their business 11



## customers, many which are small, and any 12



## reasonable support for EPA's regulatory 13



## flexibility act conclusions. 14



## The Reg Flex Act as amended by SBREFA 15



## requires federal agencies to prepare an initial 16



## and final regulatory flexibility analysis that 17



## describes the impact of the proposed rule on 18



## small entities. 19



## Here, EPA certified that the proposed 20



## rule will not have a significant impact on a 21



## substantial number of small entities. NAFEM 22127



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## recommends that EPA initiate a SBREFA small 1



## entity representative review panel immediately to 2



## help inform any final rulemaking. 3



## And finally NAFEM, of course, is 4



## available to meet with EPA to discuss all of its 5



## concern with the proposed rule and possible 6



## solutions that will both achieve the Agency's 7



## regulatory obligations, while not unduly 8



## impacting our industry and our customers. We 9



## will be submitting detailed comments before the 10



## close of the comment period, and we thank you 11



## very much for this opportunity. 12



## MS. FARQUHARSON: Thank you, Charlie. 13



## Speaker 30 is Karim Amrane from Air Conditioning, 14



## Heating, and Refrigeration Institute. 15



## MR. AMRANE: Good morning. My name is 16



## Karim Amrane, spelled A-M-R-A-N-E, and I'm with 17



## the Air Conditioning and Heating and 18



## Refrigeration Institute, AHRI. We appreciate the 19



## opportunity to appear before you this morning and 20



## provide input into the proposed rulemaking. 21



## AHRI is a trade association representing 22128



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## manufacturers of heating, cooling, water heating, 1



## and commercial refrigeration equipment. We have 2



## a long history in support of environmental 3



## issues. We have worked very closely with the EPA 4



## on issues related to climate change, refrigerant 5



## purity, recovery and recycle equipment, 6



## technician certification, and AHRI has been an 7



## industry leader in researching alternative 8



## refrigerants. 9



## In the 1990s, our alternative refrigerant 10



## evolution program successfully led to the 11



## identification of substitute refrigerants to 12



## ozone depleting substances. Three years ago, we 13



## started a similar program to identify low-GWP 14



## alternatives. The program has evaluated, so far, 15



## 38 alternatives in various air conditioning and 16



## refrigeration applications. Results for the 17



## first phase of the programs are available on the 18



## AHRI website. 19



## The second phase was initiated this year 20



## to evaluate additional low-GWP alternatives. 21



## AHRI supports an amendment to the Montreal 22129



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Protocol that would achieve a gradual phase down 1



## of HFCs to allow for the development of low 2



## global warming potential alternative 3



## technologies. EPA supported the North American 4



## Amendment proposal to the Montreal Protocol which 5



## calls for a similar gradual phase down of HFCs. 6



## However, provisions of the proposed rule that are 7



## modifying the listing of certain HFC refrigerants 8



## and foam blowing agents by January 1st, 2016 or 9



## 2017 are inconsistent with the EPA stated 10



## position at the Montreal Protocol. 11



## AHRI is very concerned with the proposed 12



## ruling’s potential negative impact on commercial 13



## refrigeration equipment manufacturers. We 14



## believe that the proposed change of status of R15



## 404A, 507A, 134a, and other HFC blends in 16



## standalone commercial refrigeration equipment is 17



## premature and will leave manufacturers with no 18



## viable alternatives. 19



## Most of the SNAP listed low-GWP 20



## refrigerants for this application will result in 21



## less efficient products. It will increase 22130



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## overall greenhouse gas emissions, which is 1



## contrary to the stated objective of the rule. It 2



## should be noted that direct refrigerant emissions 3



## represent on average less than 10 percent of the 4



## overall life cycle climate performance of 5



## standalone commercial refrigeration systems. 6



## Taking this fact into account, EPA should accept 7



## additional alternatives for this end use, 8



## including R-407A and R-407F. However, for all 9



## commercial refrigeration end uses, the proposed 10



## transition effective date of January 1, 2016, is 11



## unrealistic, unfeasible, and inconsistent with a 12



## gradual phase down of HFCs that EPA is advocating 13



## internationally. Similarly the January 1, 2017, 14



## transition date for foam blowing agent is 15



## impractical. Manufacturers will need a 16



## significant amount of time to test new 17



## alternatives and get the necessary safety 18



## listings from agencies such as UL and ETL. 19



## There is currently not enough laboratory 20



## testing facilities in the U.S. to accommodate all 21



## the testing that would be required in the amount 22131



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## of time that EPA is contemplating. Furthermore, 1



## the use of most of the alternatives that EPA 2



## believes could be implemented in a short period 3



## of time is severely restricted by all major 4



## mechanical, fire and building codes in the U.S. 5



## Although work has already started to 6



## amend these codes to accommodate alternative 7



## refrigerants, the process will take several years 8



## to complete. Complicating further the matter are 9



## new federal minimum energy conservation standard 10



## for commercial refrigeration equipment and walk11



## ins that are expected to take effect in 2017. 12



## The Department of Energy has adopted very 13



## aggressive standards that may not be achievable 14



## with the current alternatives, potentially 15



## forcing manufacturers not to comply with the law. 16



## Taking all these issues into account, we believe 17



## that the more realistic implementation date would 18



## be around 2020 at a minimum. 19



## Finally, we would like to express our 20



## concern with the lack of coordination between EPA 21



## and DOE on rulemaking activities impacting the 22132



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## same industry. As previously mentioned, DOE has 1



## set very aggressive new federal minimum energy 2



## conservation standards for commercial 3



## refrigeration equipment and walk-in coolers and 4



## freezers and has based its entire analysis on 5



## refrigerants and foam blowing agents that EPA is 6



## now proposing to list as unacceptable. The 7



## proposed SNAP rulemaking has significant energy 8



## efficiency implication and EPA has an obligation 9



## to ensure that the alternative it proposes 10



## results in products with equal or less energy 11



## consumption that are affordable to consumers. 12



## Thank you very much for the opportunity 13



## to present our views. 14



## MS. FARQUHARSON: Thank you, Karim. 15



## Speaker 31 is Kenny Owen from Master-Bilt 16



## Products. 17



## MR. OWEN: Good morning. And thank you 18



## for the opportunity to be here today. My name is 19



## Kenny Owen, that's O-W-E-N. I am Vice President 20



## of Engineering for Master-Bilt Products. 21



## Master-Bilt is a small manufacturer of 22133



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## commercial refrigeration equipment with 1



## manufacturing located in New Albany, Mississippi. 2



## Master-Bilt employs approximately 400 people. 3



## Master-Bilt manufactures over 215 models 4



## of self-contained and remote refrigerators and 5



## freezers. It also imports 50 models of 6



## commercial refrigerators and freezers. Master7



## Bilt also manufactures walk-in coolers and 8



## freezers and the associated refrigeration units 9



## that go with these walk-ins. We manufacture over 10



## 700 condensing unit models, 400 evaporator 11



## models, and we also build custom design multi12



## circuit racks, parallel racks, and secondary loop 13



## parallel racks. 14



## Every single product that we manufacture 15



## uses an HFC that EPA plans to ban. Every single 16



## one. Our refrigeration units use either 134 or 17



## R-404A, and all our foam blowing is done with R18



## 245fa. 19



## My company is not opposed to converting 20



## to more environmentally friendly refrigerants and 21



## blowing agents, but EPA must be more realistic in 22134



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## the time frame that's currently proposed. 1



## When we converted from CFC refrigerants 2



## to HFC refrigerants in the mid-1990s, drop-in 3



## replacements were readily available. So were the 4



## components for using these new refrigerants, such 5



## as someone has mentioned, compressors and 6



## expansion valves, which was all you had to change 7



## to make that conversion. 8



## At this time, no commercially available 9



## drop-in replacement for 134a, 404A, or 245fa 10



## exists. This makes the transition for Master11



## Bilt infinitely more difficult than the previous 12



## transition from HFCs -- or from CFCs. 13



## Since the non drop-in alternatives 14



## available and proposed by EPA have many bad 15



## characteristics such as flammability, toxicity, 16



## poor energy efficiency, much more testing is 17



## going to be required than what was required with 18



## the switch from CFCs to HFCs. Also, many 19



## proposed alternatives have restrictions on use 20



## which may prohibit their use in larger capacity 21



## equipment such as the charged limitation on the 22135



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## flammables. 1



## Every one of our 1300-plus models will 2



## have to be redesigned. Every one of our 1300 3



## plus models will have to be tested, relisted for 4



## UL safety, CSA safety, NSF sanitation, DOE 5



## energy, and when applicable, EPA Energy Star. 6



## This testing can take as long as 18 weeks per 7



## model. Even if performed concurrently by our 8



## small engineering staff, we estimate it will take 9



## us working non-stop over three years, and this is 10



## at the expense of new product development. 11



## We can't begin this conversion until the 12



## components are available from our suppliers, and 13



## we talked about that already. You've already 14



## heard that from people. 15



## Before we can sell these new products, a 16



## lot of things have to change; a lot of things 17



## have to happen. Among them, our factory will 18



## have to be upgraded with many new pieces of 19



## equipment since current equipment is not 20



## compatible with the proposed alternative 21



## refrigerants. This will be a very large expense 22136



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## to my company and many other small businesses. 1



## Our service technicians have to be trained to 2



## work on flammable, toxic, extremely high pressure 3



## systems. Our customers have to be convinced that 4



## it's okay to have flammable refrigerants inside 5



## their stores and around their customers and their 6



## employees, and around their food products. 7



## Our agency testing companies like UL, 8



## CSA, Intertek, will have to add a lot of new test 9



## facilities, as we've heard already, they're going 10



## to be jammed packed with all these changes 11



## because it's not just us, it's everybody. 12



## Building codes have to be updated, and 13



## there are a lot of other things that you heard 14



## today. We won't go through all of that. 15



## Regarding blowing agents for polyurethane 16



## foam, replacements are available to replace 17



## 245fa. We know that. These blowing agents are 18



## not drop-in replacements for our current foam 19



## system. All are either unable to pass Class One 20



## burn tests, which are required by building codes, 21



## or they're less -- excuse me, less energy 22137



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## efficient. Less efficient foam will cause a 1



## standard walk-in panel to go from four inches to 2



## five inches. This means our manufacturing costs 3



## go up and our customers will have to pay more. 4



## Given the facts of the situation Master5



## Bilt does not see any way we can comply with 6



## 2016/17 deadline proposed. We feel better 7



## alternatives must be available. We would like 8



## for you to have 2025 for these rules to take 9



## affect. And I hope this brief overview will help 10



## you understand the urgency of our situation. 11



## We will be submitting detailed comments 12



## before the deadline, which we request that you 13



## extend at least 60 days. And thank you for the 14



## opportunity to be here. 15



## MS. FARQUHARSON: Thank you, Kenny. 16



## Speaker 32 is Edward Bates from Pactiv Building 17



## Products. 18



## MR. BATES: Good morning. Edward Bates, 19



## B-A-T-E-S. I work with Pactiv Building Products. 20



## We're a manufacturer of extruded polystyrene foam 21



## insulation. We're also a member of the Extruded 22138



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Polystyrene Association that you heard Mr. 1



## Ferraro talk this morning about our products and 2



## the energy efficiency and global warming 3



## reduction benefits of our products. 4



## Pactiv building products just recently, 5



## in 2010, invested millions of dollars for the 6



## conversion from the HCFC to the HFC, and with 7



## that we had over seven years advance notice to 8



## plan and execute. We are now facing another 9



## multi-million dollar investment in operating 10



## costs to phase-out the HFC-134a with effectively 11



## less than two years to plan and execute. 12



## Extruded polystyrene insulation produced 13



## with the HFC-134a is part of the global warming 14



## reduction solution and is not part of the 15



## problem. The high retention rates of the gas in 16



## our product combined with the long life of our 17



## product, basically the life of the structure, in 18



## high thermal insulation performance from the 19



## extruded polystyrene produced with the HFC-134a 20



## is a net global warming reducer. 21



## The 2017, January 2017, HFC-134a phase- 22139



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## out for XPS insulation is not consistent with the 1



## phase down approach that was discussed during our 2



## May 2014 meeting. In addition, the January 2017 3



## phase-out is not feasible given the lack of 4



## commercially available replacements, the 5



## significant amount of development work required, 6



## the extensive product testing, third-party 7



## compliance approvals, as well as potentially 8



## lengthy air permitting requirements. 9



## Pactiv Building Products believes that a 10



## commercially available alternative to the HFC11



## 134a for XPS insulation that will provide 12



## equivalent properties and performance does not 13



## currently exist. 14



## We also request that XPS insulation be 15



## excluded from the HFC-134a phase-out due to its 16



## contributions to the global warming problem. And 17



## if this exclusion cannot be granted we request 18



## the HFC-134a phase-out for XPS insulation be 19



## extended to January 2022. Thank you. 20



## MS. FARQUHARSON: Thank you, Edward. 21



## Speaker 33 is Jose Avendano from Grindmaster- 22140



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Cecilware Corporation. 1



## MR. AVENDANO: Yes, good morning. My 2



## name is Jose Avendano, A-V-E-N, D as in David, 3



## A-N-O. I'm with Grindmaster-Cecilware. We are a 4



## manufacturer of food service equipment. We 5



## manufacture noncarbonated cold beverage 6



## equipment, frozen drink equipment, cold and hot 7



## liquid coffee equipment and you can keep going. 8



## I mean, we have probably over 60,000 items on our 9



## builds and materials. 10



## I had originally planned to pretty much 11



## give a presentation similar to what everybody had 12



## done, but as I sat over there I started thinking 13



## about ways to illustrating this better. And I 14



## thought, wait a minute, I worked 20 years in the 15



## appliance industry, and I've worked 10 years in 16



## the food service industry. Maybe I should use 17



## that to illustrate the point. 18



## I remember in my days when I was in the 19



## appliance industry, if you wanted a compressor 20



## and that compressor was not available, you picked 21



## up the phone and you either called Compressor A 22141



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## supplier or Compressor B supplier. Before you 1



## knew it, three people are walking through the 2



## door from that supplier and they were working 3



## with you trying to figure out how to develop that 4



## compressor for you. 5



## Now that I'm in the food service 6



## industry, when I call Compressor A or Compressor 7



## B, they say, I'm sorry, I don't have that 8



## compressor for you. And maybe I don't even get 9



## an answer right away. Maybe I have to wait about 10



## a week to get an answer. So it is really 11



## challenging to find parts that are suitable for 12



## the equipment that we make. Okay? 13



## And it's all about profit and revenue, so 14



## what happens is the people that have more sales 15



## and more money, in this case let's talk -- and 16



## I'm not attacking the appliance industry because 17



## it's in my heart. They get preference over 18



## somebody who is making over a company that is 19



## $100 million or $50 million company. That is the 20



## way the economy is. Okay? 21



## In addition to that, I also remember that 22142



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## we had a calorimeter at the appliance company 1



## that I worked for. We had probably about 12 or 2



## 14 environmental test chambers to run tests. We 3



## had a foam group for our insulation that was 4



## probably five people. We had a refrigeration 5



## group that had about seven or eight engineers. 6



## And I can go on. 7



## Now, I go to the food service industry. 8



## I have a staff of 12 people. I don't have any 9



## foam experts. I hardly have one refrigeration 10



## engineer, and we have a lot of work going on. 11



## Okay? 12



## So, I think one of the things that I see 13



## that really puzzled me when I saw the proposal 14



## was the fact that all these different industries, 15



## large, small, mass production versus custom made, 16



## everybody was kind of like put in the same 17



## bucket. Okay? And I got to tell you that -- and 18



## I've heard some people say here that Agency 19



## approvals is going to be a challenge. Make no 20



## mistake. Agency approvals are going to be a 21



## challenge. 22143



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## In my opinion, the way that this should 1



## be approached is you should use a divide and 2



## conquer approach. In other words, this should be 3



## split up and consider the proposal by -- first of 4



## all, break it up into -- I think you had aerosol, 5



## you had foam blowing agents, you had automobile 6



## air-conditioners and commercial refrigeration. 7



## As I stand here, I'm not even sure that 8



## we fall under commercial refrigeration because I 9



## was never able to get an answer on that. So I'm 10



## not even sure that our equipment is affected, but 11



## I would tend to think that it would be. So that 12



## would be the first thing that I would do. 13



## Now, the other thing that I want 14



## everybody to think about is, there are 16 months 15



## between now and January 1st, 2016. I can tell 16



## you this, three months at least will be field 17



## tests, and three months at least are going to be 18



## reliability testing and all the testing that we 19



## have to do, plus agency approvals. That's six 20



## months. We have 10 months to do this change. 21



## Think about that. Thank you. 22144



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MS. FARQUHARSON: Thank you, Jose. 1



## Speaker 34 is Nathan Mouw from Whirlpool 2



## Corporation. 3



## MR. MOUW: Good morning. My name is 4



## Nathan Mouw. That's spelled M-O-U-W. I'm the 5



## Director of Regulatory Affairs for Whirlpool 6



## Corporation. I certainly appreciate this 7



## opportunity to share Whirlpool's view of this 8



## rule. 9



## Whirlpool is a leading manufacturer and 10



## marketer of major and portable home appliances. 11



## We employ more than 23,000 people here in the 12



## United States, and manufacture right here in the 13



## United States over 82 percent of our products 14



## that we sell here. 15



## We've been a longstanding partner with 16



## DOE and EPA to continually and dramatically 17



## improve the efficiency of our products and 18



## protect the environment while delivering on the 19



## utility and performance that our end consumers 20



## demand. 21



## Whirlpool participated in several public 22145



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## SNAP workshops and meetings over the past 12 1



## months. We very much appreciate the Agency's 2



## outreach to stakeholders. However, we were quite 3



## surprised by this proposal since it differed 4



## significantly from the clearly-signaled intent of 5



## the Agency. We participated honestly and openly 6



## during the SNAP meetings, and again we're 7



## disappointed in this decision to expand the 8



## proposed coverage of foam blowing agents that are 9



## proposed to be classified as unacceptable actions 10



## like this go against what should be shared goals 11



## of transparency and predictability. 12



## Next, like so many others I'd like to 13



## offer a few comments on the proposed time line. 14



## EPA has proposed the transition time line of 15



## January 1st, 2017, for refrigerator foam blowing 16



## agents. Assuming a final rule is released in the 17



## first or second quarter of 2015, this allows only 18



## 18 to 21 months to transition. This proposed 19



## transition time line is simply not feasible for 20



## multiple reasons, many of which have already been 21



## mentioned today. 22146



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## First, EPA has failed to take into 1



## account associated time lines for DOE amended 2



## energy conservation standards. Refrigerator 3



## manufacturers are just now finishing our 4



## execution of an energy standards transition; a 5



## transition that results in products that are 6



## significantly more efficient. A great win, but a 7



## transition that has required a complete refocus 8



## of our engineering staff, required capital 9



## investments of tens of millions of dollars, and 10



## has required significant transition expense for 11



## advertising, marketing, consumer outreach costs, 12



## all a direct result of this required transition. 13



## The current proposal would require 14



## another transition of similar scope and magnitude 15



## at a time when manufacturers were hoping to 16



## refocus on our consumer renovation, driving 17



## additional energy efficiency, improved 18



## performance, and lower costs. 19



## Second, EPA has failed to acknowledge a 20



## significant technical complexity of transitioning 21



## a foam blowing agent in a refrigerator. There is 22147



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## no, quote, drop-in alternative for foam blowing 1



## agents and refrigerators as commonly advertised. 2



## Transitioning from one blowing agent to another 3



## is a major engineering challenge to execute. 4



## This transition requires significant engineering 5



## design, testing, approvals to ensure all product 6



## requirements are met, but also to ensure that the 7



## process, the manufacturing process, is delivering 8



## the product with the quality levels that you all, 9



## as end consumers, demand. 10



## Design and process considerations must be 11



## made at the individual model level due to 12



## differences in the product design and assembly. 13



## Manufacturers that have numerous models, multiple 14



## product platforms, and multiple factories to 15



## transition cannot execute a transition in the 16



## time period that EPA has proposed. 17



## Lastly this affectivity date may have 18



## unintended consequences in the market, which are 19



## very important. Whirlpool believes that the 20



## short transition timing that EPA is proposing for 21



## refrigerator freezer foam blowing agents will at 22148



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## best limit the options that manufacturers have 1



## for selection of alternative technologies and for 2



## supplier partnerships and at worst disrupt our 3



## business operations because we're unable to 4



## transition in this time frame to any alternative. 5



## The outcome may be a narrow choice or 6



## singular choice of suppliers for the 7



## alternatives, and could very possibly result in 8



## inadequate supply and disruption of our business 9



## operations. Manufacturers need absolute 10



## certainty in supply to continue to meet market 11



## demand for our products. 12



## EPA should instead adopt an affectivity 13



## date that allows natural market forces to direct 14



## manufacturer's decisions on alternatives to 15



## pursue, allow adequate time to pursue those 16



## alternatives and allow time for the supply base 17



## to actually develop to meet those supply needs. 18



## Whirlpool advises EPA to reconsider this 19



## proposed rule as it relates to refrigerator foam 20



## blowing agents. This proposed rule will, at 21



## best, result in marginal benefits above what is 22149



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## already happening in our industry. 1



## Because of the apparent disregard for 2



## regulatory cooperation with other agencies, this 3



## rule will impose significant, unnecessary and 4



## redundant burdens on manufacturers. Because of 5



## the proposed time line of the rule, it will cause 6



## hurried selection of alternatives and suppliers 7



## and likely result in suboptimum outcomes. 8



## Rather, EPA should consider a time line that is 9



## aligned with DOE amended energy conservation 10



## standards and take into account the true 11



## challenges and realities of a transition of this 12



## magnitude. 13



## Again, thanks for holding this meeting 14



## today. Thanks for considering our comments, and 15



## we look forward to further constructive and open 16



## dialog on this rulemaking. 17



## MS. FARQUHARSON: Thank you, Nathan. 18



## Speaker 35 is Karl Hielscher from Metl-Span. 19



## MR. HIELSCHER: I'm Karl Hielscher, H-I20



## E-L-S-C-H-E-R, president of Metl-Span, 21



## Lewisville, Texas. 22150



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We have six manufacturing facilities in 1



## six states -- I'm sorry, seven in six states -- 2



## and are a leading manufacturer of rigid insulated 3



## metal panels that serve a variety of 4



## nonresidential construction projects and demands. 5



## The primary issue for me to speak, along 6



## with everyone else who has spoken here today, is 7



## the need to have a more coordinated cohesion of 8



## the approach to make these transitions that we've 9



## all participated in since the Montreal Protocol 10



## began. And the primary problem that we have as a 11



## company is the fact that we have six plants and 12



## we have to meet the countless federal, state, and 13



## local and building code requirements for not just 14



## the product we make, but also the ability to 15



## produce that product. And so the three- to five16



## year periods that people have spoken about today 17



## is really a minimum time frame for all of us. 18



## Thank you. 19



## MS. FARQUHARSON: Thank you, Karl. 20



## Speaker 36 is Doug Raymond from the National 21



## Aerosol Association. 22151



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MR. RAYMOND: Good morning -- and it is 1



## still morning. My name is Doug Raymond. Last 2



## name is R-A-Y-M-O-N-D, here on behalf of the 3



## National Aerosol Association. 4



## We're here today to work with the EPA in 5



## an attempt to develop the best possible 6



## amendments to the SNAP rule. NAA appreciates the 7



## time the EPA has provided to the aerosol industry 8



## on this issue, and we look forward to working 9



## with you over the next 60 days. 10



## The aerosol industry has been removing or 11



## reducing the use of GWP compounds, high-GWP 12



## compounds for years. Our work with the 13



## California Resources Board has resulted in 14



## numerous product categories from containing high15



## GWP compounds. The most widely used GWP compound 16



## used in aerosols is HFC-134a. It's used 17



## primarily because the compound is nonflammable. 18



## However, other characteristics make the compound 19



## preferable. Generally, use of the HFC-134a has 20



## been restricted to products in which 21



## nonflammability has been required. The SNAP 22152



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## amendments will further this process, so the 1



## removal of the HFC out of the aerosols industry 2



## has only a few options to the HFC. Carbon 3



## dioxide is one of the candidates; however, if 4



## carbon dioxide was an alternative for use in the 5



## reformulation it would have been done. The 6



## difference in the cost is great and everybody 7



## would have switched out of 134a. 8



## The next candidate is alternative 9



## products as stated by EPA which means 10



## nonaerosols. Being the NAA, we don't really 11



## consider that an alternative; but again, if that 12



## was an alternative it would have happened. 13



## People would have looked to that already. 14



## The last one is -- the next candidate is 15



## the HFO-1234, which is a low-GWP, no ODP, and is 16



## nonflammable. But ASTM E681 and ISO 10156 for 17



## most applications, the HFO-1234 will be a 18



## replacement. 19



## The vapor pressure, however, is different 20



## than HFC-134a, and under narrow conditions the 21



## 1234ze exhibits flame limits. However, there 22153



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## have been numerous products that have been 1



## developed and a large number of nonflammable 2



## aerosols that will be using the HFO. 3



## Aerosols are convenient and easy to use 4



## due to their portability and are a necessary tool 5



## for some users. One main reason for the industry 6



## that it's not the appropriate time limit that 7



## we're looking at -- it's 1/1/2016 -- is industry 8



## has had numerous other issues to deal with. 9



## We've had to deal with VOC regs, the GHS, which 10



## is going to be kicking in next year, and other 11



## limits. Thus, the 1/1/2016 date is probably not 12



## going to be feasible for some products. By the 13



## time this regulation is done, it will give us 14



## less than a year to comply. 15



## In closing, we would ask the EPA to 16



## consider all of these issues when preparing the 17



## final document. The 1/1/2016 date will be less 18



## than one year away. Thank you very much. 19



## MS. FARQUHARSON: Thank you, Doug. The 20



## last registered speaker I have this morning is 21



## Rick. Is Rick Heffernan in the room? 22154



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## MR. HEFFERNAN: Yes. 1



## MS. FARQUHARSON: Great. Rick will be 2



## speaking on behalf of System Development 3



## Integration, SDI. 4



## MR. HEFFERNAN: SDI. Good morning. I 5



## can still say that it's morning, Doug, because I 6



## have two minutes left, and I'll try to keep it to 7



## that. 8



## My name is Rick Heffernan, spelled 9



## H-E-F-F-E-R-N-A-N. I'm one of the owners of SDI 10



## located in Neptune, New Jersey, together with our 11



## partners, No Climb Products. We represent two 12



## small family-owned businesses that develop, 13



## manufacture and distribute specialized fire alarm 14



## system test equipment to the life safety industry 15



## in both the commercial and industrial markets. 16



## I am a principle member of Chapter 14, 17



## testing and maintenance of fire alarm and 18



## signaling systems, as well as Chapter 29, single 19



## and multiple station alarms and household fire 20



## alarm systems of NFPA 72, the National Fire Alarm 21



## and Signaling Code which specifies the 22155



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## requirements for a fire alarm systems and 1



## associated components that protect the general 2



## public. 3



## Most federal, state, and local 4



## municipalities have adopted NFPA 72 for the 5



## enforcement of fire and life safety codes and 6



## associated regulations. I'm also a principle 7



## member of NFPA 720, the standard for the 8



## installation of carbon monoxide detection, and I 9



## currently sit on the National Board of Directors 10



## for the Automatic Fire Alarm Association, or 11



## AFAA. 12



## The products I'm here to talk about very 13



## briefly are two types of smoke detector testers 14



## that utilize HFC-134a. The first is used for the 15



## functional testing of smoke detectors where 16



## confined spaces and potential ignition sources 17



## can be present. Thus, there is a need for a 18



## nonflammable product. Currently, we are working 19



## on an HFO-based replacement. However, due to the 20



## need for a UL listing -- and that's no easy task 21



## -- in the past, it's taken up to four months for 22156



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## a simple label change with no testing involved, 1



## and other necessary and vital certifications and 2



## endorsements, this product cannot be commercially 3



## available by 1/1/16. We essentially have to go 4



## around all of the detector manufacturers, the 5



## smoke alarm manufacturers after we have the UL 6



## listing, and say, Please test this with your 7



## product. Does it work? Just in most cases of 8



## covering yourself, obviously. 9



## These types of products represent an 10



## extremely small amount of the entire fire 11



## detecting testing market. It would be great if 12



## there was a drop-in replacement for our niche and 13



## vital product sector, but unfortunately there 14



## isn't. 15



## The second product that I'm going to 16



## refer to as far as a smoke detector and alarm 17



## tester is used in testing the sensitivity of fire 18



## detectors and alarms, which is required by NFPA 19



## 72, the National Fire Alarm Signaling Code, 20



## Sections 14.4.4.3.4. In it's most current 21



## edition, the 2013 edition. 22157



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## We're asking for the EPA to provide an 1



## acceptable use status for HFC-134a due to the 2



## fact that our tests with the HFO haven't been 3



## successful. Quite simply, it doesn't work. The 4



## HFO does not have the vapor pressure needed to 5



## perform the function of the current product. In 6



## addition, at elevated temperatures and the 7



## confined spaces in the presence of an ignition 8



## source, the HFO can exhibit flammability. 9



## This sensitivity product is used with 10



## expensive equipment. The prohibition of HFC-134a 11



## in this small use will cost companies 12



## significantly due to the loss of the use of this 13



## equipment. As a result, it will expose the 14



## public to an unacceptable risk due to the fact of 15



## noncompliance with requirements set forth in the 16



## previously mentioned NFPA 72, the Fire Alarm 17



## Safety Signaling Code. 18



## When SDI was founded, it was done with a 19



## vision to provide quality products to improve the 20



## protection of life and property, and we stand by 21



## that belief today. As a follow-up we're 22158



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## preparing a document sent through your proper 1



## channels that will back up all of my comments and 2



## explain them in greater detail. 3



## Thank you for your time and consideration 4



## and I'm -- is it about noon? Maybe a little 5



## after? Okay. Thank you. 6



## MS. FARQUHARSON: Thank you, Rick. 7



## Before we move on to the folks who signed up to 8



## speak this morning and the folks who want to 9



## provide additional comments, I want to make sure 10



## I capture all the registered speakers. 11



## So once again, is Kate DeAngelis present 12



## from Friends of the Earth? 13



## (No audible response.) 14



## MS. FARQUHARSON: Okay. George Parsons 15



## from Ice-O-Matic. Is George present? 16



## (No audible response.) 17



## MS. FARQUHARSON: All right. So did you 18



## have a question? Okay. 19



## Did anyone sign up this morning to speak? 20



## (No audible response.) 21



## MS. FARQUHARSON: Okay. All right. So, 22159



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Keilly, do you want to -- you'll go after Keilly. 1



## Is that okay? 2



## (No audible response.) 3



## MS. WITMAN: (Now speaking on behalf of 4



## KW Refrigerant Strategy) Wow, it's enviable to 5



## have to come up here a couple of minutes when 6



## everyone is dying to go to lunch, but most of the 7



## comments so far have focused on what people think 8



## will not work and the timing being too soon, and 9



## all of that other stuff. What I wanted to go on 10



## record about is commercial refrigeration systems, 11



## the delisting of 404A and 507A, and the 12



## alternatives available and the timing. 13



## I conducted a series of meetings with 14



## equipment manufacturers of systems, service 15



## contracting organizations, and supermarket end 16



## users, and have also conducted some webinars, 17



## mainly to deal with the problem of 18



## misunderstanding that happened as a result of the 19



## way that the rule was worded. 20



## I think the problem is, is that when the 21



## rule refers to commercial refrigeration end uses, 22160



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## self-contained and standalone equipment is very, 1



## very different than refrigeration systems, and 2



## when supermarkets and other industry stakeholders 3



## read that in certain commercial refrigeration end 4



## uses 404, 507, 134a, would be delisted, they did 5



## not realize that 134a was just for self-contained 6



## units, and they became very panic stricken, I 7



## would say. When the rule came out, my phone rang 8



## off the hook. 9



## So, it would be helpful just in terms of 10



## explaining this rule to make that very clear 11



## separation. It would certainly eliminate a lot 12



## of anxiety. 13



## The second thing is that I have yet to 14



## hear of anyone when I ask the question of, you 15



## know, is it a problem to use the 407 series 16



## refrigerants instead of 404 or 507 in supermarket 17



## refrigeration systems. Not a single person said, 18



## yes, it would be a problem. In fact, the 19



## majority of people I talked to said EPA could 20



## make this change tomorrow and it would not affect 21



## us. I think the supermarkets that are involved 22161



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## in the Green Chill Partnership were ready for 1



## this years ago. They led the charge to the 407 2



## series of refrigerants in terms of getting the 3



## compressor manufacturers to approve of its use. 4



## So, I think that the 407F alternative both for 5



## new systems and for retrofits is fairly 6



## unproblematic. 7



## When I ask service technicians, you know, 8



## are there problems with 407 series refrigerants 9



## retrofits versus 404 and 507, every service tech 10



## organization I spoke with said it's a non-issue. 11



## I can't remember the last time I did a 404 or 507 12



## retrofit out of R-22. We already are doing 407. 13



## That's what is happening out there. 14



## In addition to that, 407 brings certain 15



## advantages in R-22 retrofits. The feeling is 16



## that it's an overall easier retrofit. That 17



## doesn't mean that it's a no-brainer. There are 18



## some things you have to watch out for, but the 19



## feedback I get from supermarket end users is that 20



## the retrofit process is faster and easier, which 21



## allows more time to check leak tightness during 22162



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## the retrofit process, which of course had the 1



## obvious environmental benefits associated with 2



## that. 3



## So I just wanted to give comments related 4



## to something that is perhaps not as problematic 5



## as some of the other areas. When you start 6



## talking about self-contained units with 7



## manufacturers and supermarkets, it's a different 8



## story, which I've already discussed in my 9



## previous comments. Thank you. 10



## MS. FARQUHARSON: Thank you, Keilly. 11



## Richard Willey will be next. Richard will be 12



## speaking on behalf of Grindmaster-Cecilware 13



## Corporation. 14



## MR. WILEY: Thank you. My name is 15



## Richard Willey. I'm a Components Engineer for 16



## Grindmaster Corporation in Louisville, Kentucky. 17



## Today, we listened and we heard everyone 18



## that was in agreement with moving to HC. The 19



## issue that we're facing is its timing. I'm going 20



## to be like Paul Harvey, and I want to explain the 21



## rest of the story from a compliance perspective. 22163



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## Before we can do anything on the 1



## mechanical side of the implementation of 2



## components and finished products using HC, we 3



## have to understand fully what are the 4



## requirements from all the jurisdictions having 5



## authority, UL, CSA, NSF. No one has mentioned 6



## sanitation impact. I'm sure there will be an 7



## impact for sanitation approvals also. 8



## These agencies, while they speak to 9



## having coverage and their current standards, most 10



## of that coverage is for information only, or is 11



## vague and ambiguous when it comes to the very 12



## specifics of what we're talking about. When 13



## we're talking about going to new components for a 14



## different refrigerant, all of these components 15



## are pressure vessels. They're subject to 16



## mechanical properties. One of those properties 17



## is burst strength. 18



## In order to have the proper burst 19



## strength, you have to have a mechanical design, 20



## it has to be tooled, and then we go through our 21



## burst test and our endurance testing. We cannot 22164



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## meet that requirement in 14 months, for several 1



## reasons that safety agencies do not have the 2



## tools in place. The specific tools I'm speaking 3



## of are test procedures, test equipment, 4



## interpretation of the results of the test 5



## procedure. Most of the time, you will have a 6



## test that simulates real world conditions, and 7



## then there has to be an interpretive period of 8



## how the test results apply to real world 9



## situations. 10



## Specifically, I'm speaking to leakage. 11



## How much is going to be an allowable leakage? 12



## Well, our proposal here and many other documents 13



## speak that it can't reach the lower explosive 14



## limit. But then it doesn't define the room size. 15



## It doesn't define a lot of the parameters that we 16



## need to understand. 17



## Now, how this will happen is we will go 18



## back to the agencies and we'll be working with 19



## these folks. Well, the Agency standards change 20



## on a consensus basis. That means that many 21



## people will be reading and reviewing these, and I 22165



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## would venture to say that we are not going to 1



## have a consensus standard back from UL or from 2



## CSA in that 14 months that would provide adequate 3



## coverage for testing and interpretation. 4



## I propose that we delay this until 2020 5



## or until such time as we can make a determination 6



## based on facts, delivered to us by our safety 7



## authorities and our other authorities having 8



## jurisdiction. We are going to be receiving 9



## input, I'm sure, from NFPA. We're going to have 10



## to manage how OSHA responds to the training 11



## program for hazardous materials. We're going to 12



## have to look at how the Department of 13



## Transportation is going to consider the 14



## hydrocarbons as a hazardous material and 15



## different category. There's a lot of 16



## interaction. 17



## There are at least 14 different standards 18



## that I listed back here this morning that I will 19



## have to read and understand before I can offer to 20



## the mechanical designers a game plan that says 21



## this is how that we're going to be able to 22166



### OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376 

## achieve full compliance and to deliver what we 1



## need to meet our obligation, our civic 2



## obligation, our obligation to our customers, and 3



## our obligations to our shareholders. 4



## So I humbly propose that we delay this 5



## process. Thank you. 6



## MS. NEWBERG: Is there anyone else who 7



## wanted to take the floor? 8



## (No response.) 9



## If not, then this concludes the hearing 10



## today on this rule, which is the Stratospheric 11



## Protection Rule, Change of Status Listing for 12



## Certain Substances under the Significant New 13



## Alternatives Policy Program. 14



## Thanks very much for coming. 15



## (Proceedings concluded at 12:11 a.m.) 16