Good morning my name is Peter Williams, with the New Era Group

. New Era is a nonprofit consulting group representing the interests and concerns of refrigerant reclaimers, alternative refrigerant manufacturers and distributors throughout the United States

. Our clients have invested significant resources in an effortto support the United States clean air act. They are the very safety net that the nation needs to support a viable environmental policy on the issues within this rule
. The New Era Group agrees with the Presidents recent Climate Change Policy
. The issue ofclimate change is relevant and significant to all Americans
. EPA's latest challenge is to establish regulatory policy, which will achieve the goals set forth by the administration on the matter ofclimate change
. We are expressing concerns that EPA has losttheir way with respect to ensuring the use ofaccu r ate data as it vets and presents these rules to the public for approval. There is a need to look atthe history and work that EPAtook to phase out chlorofluorocarbons , CFCs

. In fact the phase-out of CFCs was accomplished five year s sooner than required. EPA was able to accomplish an accelerated phase-out and brought enforcement ofventing as one ofthe most important parts ofthat rule. It is notable to recall that EPA had a tool to prevent the stockpiling of CFCs, the ODC Tax
. In 1993 the rule referenced the need for data collection throughout the document. The significance ofthat action was to understand the use and demand ofCFCs in order to form the best public policy and set forth the most environmentally beneficial phase-out. The Agency's stated policy in the 1993 rule brought outthe "worstfirst "doctrine
. It was this doctrine that led all to believe there would be an aggressive HCFC phase-out. EPA is to be commended for the work done with respect to the Significant Alternative Program, SNAP

. The implementation ofthis Clean Air Act Requirement must be considered as a great cornerstone to the successful1995 production and consumption phase-out ofCFCs

. In addition to this success the nation saw recovery and reclamation grow. Unlike the prior phase-out periods EPA, having vacated their prior process, did not seek any data from the industry on the needs or the inventories of HCFC

. The baseline was too high. The stockpiling of products like R-22 went on for over 18 year s before EPA attempted to verify what was widely known to be an oversupply
. The entrepreneurial spirit ofthose companies that develop alternative refrigerants further supported agg ressive refrigerant management. These SNAP approved products provide a hedge for the United States consumer against high prices
. No one holding a patent had the illusion that these alternatives would last forever.Some ofour concerns are: The failure ofthis rule to create a sustainable path forward for reclaimation , through the requirement of recovery ofall refrigerants. For every molecule that is recovered and reclaimed there is less demand or emphasis on a molecule to be produced
. No clear policy on what we are regulating i.e. ozone depletion, global warming , green hose gases not to forget C02e HCFC issue is unsettled this rule and other EPA actions are predicated on the HCFC phase-out EPA has chosen to allow the mobile applications until the year 2021 to adjust and at the same time EPA is pulling the plug on SNAP product in 2016. Recordkeeping and reporting must be placed into these rules for proper understanding ofcurrent and future inventories and demands
. Labeling of products on safety issues to included any side effects. This rule seeks to limit the use of HFC products at the same time HCFC-22 and all of its direct and indirect effects go on being produced
. HCFC 22 has a lower GWP than some ofthe SNAP chemicals, but unlike the SNAP products HCFC 22 has an ozone-depleting factor that SNAP products do not. We feel that EPA has to rethink the policy on recordkeeping and reporting
. We have been constant in our request that EPA require all holders sellers and processors report the amount ofall these chemicals on an annual basis
. EPA instituting a national survey/data collection will allow the public to know what the inventories are. This action will allow the public to make comments based on fact not assumptions
. We suggest that EPA is not giving the American public all the benefit of research and development. The haste to write this rule to phase-out a class of products in favor of only a few new HFOs and flammable materials may result in some new products being left on the sideline and issue ofthe new chemicals will not be fully captured. Thejump to these new products does not ensure that we have made the best choices, what it does say isthat in our haste EPA has not given entrepreneurs a chance to advance newtech nologies to strengthen United States Environmental Policy. When EPA approves a new class ofchemicals do they require the same type of warning labels thatfood and drug administration does? There are no studies in the docketthat address the toxic side of some ofthese products. We support action on this rule but at the same time suggest that we forge a balancedapproach to the effects ofthese chemicals between the new and better controlling the current product. We look forward to commentating further to the docket.