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 effort to 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 of climate 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 of climate change. 

We are expressing concerns that EPA has lost their way with respect to ensuring the 

use of accurate data as it vets and presents these rules to the public for approval. 

There is a need to look at the history and work that EPA took to phase out 

chlorofluorocarbons, CFCs. In fact the phase-out of CFCs was accomplished five years 

sooner than required. EPA was able to accomplish an accelerated phase-out and 

brought enforcement of venting as one of the most important parts of that 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 of that action was to understand the use and demand of CFCs 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 out the "worst first "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 of this Clean Air Act Requirement must be 

considered as a great cornerstone to the successful1995 production and consumption 

phase-out of CFCs. 

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 years before EPA 

attempted to verify what was widely known to be an oversupply. 

The entrepreneurial spirit of those companies that develop alternative refrigerants 

further supported aggressive 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 of our concerns are: 

The failure of this rule to create a sustainable path forward for reclaimation, 

through the requirement of recovery of all 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 C02 e 

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 of current 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 

of the 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 of all 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 of the new chemicals will not be fully captured. 

The jump to these new products does not ensure that we have made the best choices, 

what it does say is that in our haste EPA has not given entrepreneurs a chance to 

advance new technologies to strengthen United States Environmental Policy. 

When EPA approves a new class of chemicals do they require the same type of 

warning labels that food and drug administration does? There are no studies in the 

docket that address the toxic side of some of these products. 

We support action on this rule but at the same time suggest that we forge a balanced 
approach to the effects of these chemicals between the new and better controlling the 

current product. 

We look forward to commentating further to the docket.