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; Prop osed 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 ma nufacturers including BMW Gr oup, Chrysler Group LLC, Ford Motor Company, General Motors Company, Jagua r Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche, Toyota and Volkswagen.

Importance of the ne w HFO-1234yf Refrigerant

Automobile manufacturers urgen tly require availability of low Global Warming Potential (GWP) refrigerants for use in new vehicle air conditione rs 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 Averag e 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 Corpor ate Average Fuel Econo my 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 would2 typically introduce 2012 models ear ly in the 2011 calendar year. Gi ven that typical automobile development lead times for these air conditioner systems extend approximate ly three years prior

to start of production, there is an urgent need for prompt fina lization 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 S ection 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 Janu ary 2011 use an air conditioner refrigerant with a GWP below 150. HFO-1234yf is the only practical alte rnative 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 ai r 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 th erefore support the EPA' s determinations regarding new uses for HFO-1234yf. Under these determinations, init ial 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-1234y f would also be done only by CAA Section 609- certified technicians using CAA Section 609-cer tified refrigerant handling equipment. In addition, no containers smaller than 20 pounds (net weight) woul d be sold or distributed.

We would note that the training and equipment re quirements currently in Section 609 relative to other refrigerants would not be necessary for environmentally safe us age of HFO-1234yf during initial charging in an automobile assembly plan t. Section 609 certifi cation is not currently required for automobile assembly plants workers or equipment, and manufacturers perform their own training programs. OSHA requirements fo r handling flammable substances already fully address the flammability-related HFO-1234yf worker safety issues in automobile assembly facilities. Therefore, while the Alliance does notwish to delay the current approval to use HFO1234yf in motor vehicles, we antic ipate that, working through th e 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 wi th 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 Aftermar ket Industry Associa tion (AAIA). These organizations conclude, based on their available information, that “concerns expressed by OPPT regarding potential health ri sks 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 stat e that they “recognize that additional scientific assessment and effort may be n eeded ... to persuade OPPT” concerning this conclusion. We respectfully re quest that EPA not delay appr oval 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 to3 proceed with implementation of this low globa l warming refrigerant, and the conditions for usage can be made more permissive in the future.

If you should have any questions about our comme nts, please contact Gied rius 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