BMW Group • Chrysler Group LLC • Ford Motor Company • General Motors • Jaguar Land Rover • Mazda

Mercedes‐Benz USA • Mitsubishi Motors • Porsche • Toyota • Volkswagen

1401 Eye Street, N.W, Suite 900, Washington, DC 20005‐6562 • Phone 202.326.5500 • Fax 202.326.5567  

www.autoalliance.org

  

May 3, 2010 

Environmental Protection Agency 

EPA Docket Center (EPA/DC) 

Air and Radiation Docket 

Mail Code 2822T 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

RE: Docket ID No. EPA–HQ–OPPT-2008–0918; Proposed Significant New Use Rule for 

1-Propene, 2,3,3,3-tetrafluoro- (i.e., SNUR for HFO-1234yf), 75 Fed. Reg. 16706 (April 2, 

2010) 

Dear Sir or Madam: 

The Alliance of Automobile Manufacturers hereby submits its comments on the abovereferenced Proposed Significant New Use Rule (SNUR) for HFO-1234yf. The Alliance is an 

association of 11 vehicle manufacturers including BMW Group, Chrysler Group LLC, Ford 

Motor Company, General Motors Company, Jaguar Land Rover, Mazda, Mercedes-Benz USA, 

Mitsubishi Motors, Porsche, Toyota and Volkswagen. 

Importance of the new HFO-1234yf Refrigerant

Automobile manufacturers urgently require availability of low Global Warming Potential (GWP) 

refrigerants for use in new vehicle air conditioners to meet both existing and pending regulatory 

requirements for reductions in greenhouse gas emissions globally. Prompt SNUR (and SNAP) 

approval of HFO-1234yf will be an essential step to enable some automobile manufacturers to 

comply with the recently released EPA/NHTSA Final Rule on Light-Duty Vehicle Greenhouse 

Gas Emissions Standards and Corporate Average Fuel Economy Standards. Use of HFO-1234yf 

represents approximately 70% of the proposed EPA Mobile Air Conditioning (MAC) credits, 

and according to EPA calculations would reduce total light-duty motor vehicle GHG emissions 

by approximately 4%. 

Urgent Need for Prompt EPA Action 

In its November 20, 2009 comments to EPA on the Proposed Rule on Light-Duty Vehicle 

Greenhouse Gas Emissions Standards and Corporate Average Fuel Economy Standards, the 

Alliance emphasized that EPA needs to remove any obstacles to commercially available 

alternative refrigerants for the 2012 model year. It is important to note that 2012 models can be 

introduced into the market as early as January 2011, and many automobile manufacturers would 
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typically introduce 2012 models early in the 2011 calendar year. Given that typical automobile 

development lead times for these air conditioner systems extend approximately three years prior 

to start of production, there is an urgent need for prompt finalization of the SNUR rule (and 

approval under SNAP), as well as finalization of all associated requirements, such as EPA rules 

for the vehicle service and end-of-life disposal sectors under Section 609 of the Clean Air Act 

(CAA). 

The urgency of prompt approval is also created by the European Union (EU) requirement that 

new vehicle designs introduced beginning in January 2011 use an air conditioner refrigerant with 

a GWP below 150. HFO-1234yf is the only practical alternative at this point that can meet these 

early dates for usage. Manufacturers that market vehicles in both the U.S. and the EU have 

strong incentives to use common air conditioner designs in both markets, and therefore have a 

strong desire for EPA to approve U.S. usage of this low-GWP refrigerant. 

In the interest of time, we therefore support the EPA's determinations regarding new uses for 

HFO-1234yf. Under these determinations, initial charging of MVAC units with HFO-1234yf 

would be done by the motor vehicle original equipment manufacturer using CAA Section 609-

certified technicians as well as certified refrigerant handling equipment. All servicing, 

maintenance, and disposal involving HFO-1234yf would also be done only by CAA Section 609-

certified technicians using CAA Section 609-certified refrigerant handling equipment. In 

addition, no containers smaller than 20 pounds (net weight) would be sold or distributed. 

We would note that the training and equipment requirements currently in Section 609 relative to 

other refrigerants would not be necessary for environmentally safe usage of HFO-1234yf during 

initial charging in an automobile assembly plant. Section 609 certification is not currently 

required for automobile assembly plants workers or equipment, and manufacturers perform their 

own training programs. OSHA requirements for handling flammable substances already fully 

address the flammability-related HFO-1234yf worker safety issues in automobile assembly 

facilities. Therefore, while the Alliance does not wish to delay the current approval to use HFO1234yf in motor vehicles, we anticipate that, working through the Section 609 process or other 

rulemaking processes, EPA would not seek to extend the Section 609 requirements into the 

assembly operation. This would be consistent with EPA’s position on other refrigerants that are 

used in the assembly plants.

EPA has received objections to these conditions from the Automotive Refrigerants Products 

Institute (ARPI) and the Automotive Aftermarket Industry Association (AAIA). These 

organizations conclude, based on their available information, that “concerns expressed by OPPT 

regarding potential health risks from the DIY use of HFO-1234yf are based on an assessment 

that overstates both the potential health hazards of the chemical and the potential exposures from 

DIY use.” (Comment to docket by Lynn L. Bergeson, March 2, 2010, Document ID EPA–HQ–

OPPT-2008–0918-0074.1). ARPI and AAIA further state that they “recognize that additional 

scientific assessment and effort may be needed ... to persuade OPPT” concerning this 

conclusion. We respectfully request that EPA not delay approval for use of HFO-1234yf in 

automobile air conditioners under the current proposal while it conducts further evaluations to 

explore less restricted usage. The automobile industry urgently needs approval at this time to 
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proceed with implementation of this low global warming refrigerant, and the conditions for 

usage can be made more permissive in the future. 

If you should have any questions about our comments, please contact Giedrius Ambrozaitis of 

my staff at (248) 915-8836. 

Sincerely, 

Julie C. Becker 

Vice President, Environmental Affairs 

Alliance of Automobile Manufacturers 

cc: Drusilla Hufford, EPA DC 

 Margaret Sheppard, EPA DC 

 Cynthia Newberg, EPA DC 

 Chris Grundler, EPA AA 

 Chet France, EPA AA 

 Bill Charmley, EPA AA