Selection Software | Products Industries Approach R&D About Request a Quote HFC Phasedown Rule Final; EPA Lays Out Schedule, Allowances [Transcript] Posted by Ken Allen on Nov 19, 2021 10:50:13 AM Share Note: the following is a transcript of a podcast recorded on November 8, 2021. To listen, check out the SRC Podcast here or wherever you get your podcasts. Hello and welcome to another SRC podcast. On today's episode, we'll be talking about a new EPA rule regarding the phasedown of hydrofluorocarbons. We touched on this in our last recording, and since, there has been developments in terms of at that time, it was a proposed rule. It has now progressed to the point where it is a final rule. Since that development, we thought it'd be a good time to revisit this topic. Today, we're going to be talking about exactly what the implementation of that rule will look like, and then we'll also quickly review the contents of the rule. And then we will talk about the final rule in three main areas – EPA's consumption and production phasedown schedule, affected industries and allowances, and some information regarding compliance. We'll also finish with some takeaways and talk about what could be coming next. To do that, I need to introduce my colleague and friend, Ken Allen, who will be lending his insight to this conversation. Ken's an HVAC engineering lifer having worked in the industry since the '90s. He serves as senior sales application engineer for SRC and is based in our Richmond, Virginia, division. How's it going, Ken? Ken Allen: Great, Nate. Thanks for setting this up and it's going to be a great conversation today. Nate Budryk: Yes, sir. Well, thank you for doing this. With that, I guess let's just get right into it. Last time, we chatted at length about the AIM Act of 2020 and how it included a directive to the EPA to phase down HFC production and consumption. One of the big things we talked about in the last episode was that prior to the AIM Act, the EPA didn't have the authority to do that. So, basically, AIM Act gave them the authority. The rule was proposed when we spoke about it last time and they were saying, "We're getting some plan together," or, "We plan to get a schedule in place to phase down HFCs," and now this is more of the, "We said here's what we're going to do, and now, this is more of the here's how we're going to do it." Is that fair to say? Ken Allen: That is correct, yeah. Nate Budryk: We'd be remiss if we didn't talk about or at least outline the refrigerants that we're going to talk about. It's a long list so bear with us, we did it last time. So, there's 18 on the list and they are HFC-134a, 134, 143, 245fa, 365mfc, 227ea, 236cb, 236ea, 236fa, 245ce [Phonetic 00:02:57], 43-10mee, HFC-32, HFC-125, 143a, 41, 152, 152a, 23. So, that's all of them, 18 in total. And in terms of one of the biggest developments and most notably is the consumption and production phasedown schedule from the final rule. Ken Allen: You mind if we talk a second about those refrigerants real quick? Just hear me out on this one. The 18 refrigerants you just listed, most of our listeners today are going to know nothing of the majority of those refrigerants. For our industry, HVAC and refrigeration, the majority of those refrigerants aren't used alone in any instance. 134a, we understand that one, it was used in automobiles for years, it's already been phased out of automobiles. We use it in some medium-temp refrigeration. You see it around, right? 125, the thing about 125 is it's really not used alone, but when you mix it with 32, you got R-410A. So, there's a lot of refrigerants that are in here that are used in blends that we do use every day. And that's the important thing to remember is you don't see R-410A on this list, but what you do see are the components that make up 410A. Nate Budryk: And do you think – I don't know this answer and it may have yet to be answered by EPA – but are you aware of any sort of plan that's currently in place that will address that dynamic that you're talking about? Ken Allen: Well, and I think we'll talk about it more as we go, what they're planning on doing is they're phasing out high GWP. It's going to be measured in terms of GWP, not measured in terms of which refrigerant they phase out. So, as it goes, you'll be limited based on the GWP number, not on refrigerant specific in itself. So, what you'll see is, for instance, 410A will probably be phased out over time because there are other lower-GWP alternatives to use. Nate Budryk: And 410A is the combo that's 125 and 32, right? Ken Allen: Yeah, that's correct, 50/50 blend. Nate Budryk: But do you think there's anything like... So, you're using half of a soon-to-be-phased-down refrigerant to make that blend. But it's kind of in the name of creating a lower GWP refrigerant? I think there's some gray area there that the EPA has yet to, at least in my research, explicitly address. Ken Allen: Yeah. Well, if you look at the GWP of each of these refrigerants, for instance – and I don't have the numbers in front of me – but 32 and 125, they're the components of 410A, right? 32 is one of the up-and-coming refrigerants to be used. Not so much in the US yet, but in Asia I think it's very popular. And the reason we didn't use it here in the United States standalone is because the flammability issue. So, R-32 has a great heat transport ability and it's good energy-efficient, as far as refrigerants go, but the flammability was the issue. So, the 125 was added to it because it's a similar pressure operating condition and it limits the flammability issue down so 410A becomes an A1 refrigerant. What you'll see is that 125 contributes to the higher GWP, so if you take that out and just use a 32, you have a much lower GWP refrigerant that does the same thing, but now I think it's an A2L. So, we have to learn how to deal with the lower limits of flammability for these A2L refrigerants. Nate Budryk: Got you. Yeah. And I think this is still very early in the process. I mean, it's a final rule but there's still a petitioning period, there's a lot that has to go on in terms of things like that, so it may be addressed during that period, I guess we'll see. Ken Allen: Yep, we'll see, we'll see. There's always going to be people that have interests that they're going to talk about or ask for certain things to be done. But I think the writing's on the wall. Nate Budryk: All right. Well, so next let's talk about exactly what EPA's outlined with their consumption and production phasedown schedule. But to do that, I think we need to zoom out a little bit. We currently have a regulatory landscape that's a bit like a patchwork quilt, if you will, where different states are abiding by different laws and there's real no consensus nationally. So, I'm going to turn it over to Ken. Ken, how did we end up with this kind of disjointed patchwork and why are you encouraged to see the federal government kind of putting their foot down and saying, "We're going to one standard"? Ken Allen: Yeah. I think it's really important that when you're operating here in the United States, that we do have a relatively strong federal government that sets the standard for lots of things. I think states' rights are super-important, but when you come down to trade from one border to another, it's pretty tough when you might have 50 different rules that you have to... The reason we got there is because back in, I think, 2016, the federal government, the EPA, decided they were going to work on a phasedown rule for HFCs. They wrote Rules 20 and 21 which did that. Subsequently, they were sued by manufacturers of refrigerant saying that the EPA did not have authority. And they were right. The EPA is like any other branch of the government, they are authorized by Congress to do certain things. And their charter did not give them the right to regulate HFCs. So, when they were sued, they had to pull back on Rules 20 and 21, they couldn't put them into place. And as they fought that out through Congress for the next couple of years, the states, or some states, looked at it and said, "We need to do something. Something is better than nothing." And so you have 10 or 12 states that were in the Climate Alliance and they started putting together rules internally about how to deal with HFCs in some kind of phasedown. So, a lot of them looked at those Rules 20 and 21 and basically used that as the framework. And what we're going to see now is that the federal government will be setting the regulations for the entire country. Hopefully, that takes this patchwork of laws that are in other states and pulls them more cohesive together with the rest of the country. Nate Budryk: And speak a little bit too about what does some of the disruption look like that's caused by that patchwork. Like you'd be working on a project in California, you're obviously going to need a different skillset almost to work on equipment that's going to be installed in California versus Texas versus Massachusetts verse Colorado. Ken Allen: Yeah. Absolutely. Of course, if you think of the people that maybe work out of their van or work for a company, they might not work across borders anyway, so it might not be as big a deal. But you still have all these technicians and things have to be trained on new systems, new refrigerants, and that's going to have to take place anyway. I think back to the manufacturers. Let's say that there's a manufacturer in, I don't know, Tennessee, that builds refrigerators. And they want to sell them anywhere in the United States. You don't want to just sell them in Tennessee, so you have to make them capable of being sold anywhere within the 48, or 50 if you're going to ship to Alaska and all that. So, you have to think about all the laws in all those states that could prohibit you from doing it a certain way. Think of just the manpower that goes into finding all those regulations out and how they're changing. Will I not be able to sell in California in 2022? If I want to sell to California, do I have to use this refrigerant versus that refrigerant? Is the building code in other states set up to allow me to use this new refrigerant? Because if you want to use a flammable or slightly flammable refrigerant, the building codes also have to be amended to allow you to use it. So, let's say that California says, "Okay, A2L's that lower flammability are perfectly okay. All of our building codes are set up to allow it. You can use them." And the guy in Tennessee's like, "Fantastic, I'm going to use them." But the other 47 states haven't amended their building codes to allow for A2L's. So now you have to build a California-compliant unit and a everywhere else unit. Nate Budryk: Yeah. Well, cool. Thanks for that background. So, a lot of this was kickstarted by the Kigali Amendment to the Montreal Protocol. And the Montreal Protocol, we covered some of it at least in the last podcast we did on this topic. Montreal Protocol was established to eliminate refrigerants that caused ozone depletion, so the ODP was the value they used to determine that, and they went hard after those refrigerants. Sort of the next logical step, it seems, that this newest rule from the EPA is designed to address refrigerants that have GWP issues, which is global warming potential. Ken Allen: If we back up to Montreal, which you mentioned, the science that came out said that CFC's, which are R-12, R-11, R-502, three mainstays of refrigerant spec in anywhere from the '60s to the '90s, it said that those refrigerants cause damage to the ozone. Remember that? Nate Budryk: ODP, yeah. Ken Allen: Yeah. Ozone depletion potential, exactly. And if you think about those, R-11, it's the worst. Of all of the ones that they had out there, R-11 was the worst. So, if you look at the Ozone Depletion Schedule, that range, I think it's zero to one, but whatever it is, R-11 was the top. That was their measure of the highest one. Nate Budryk: Yeah, public enemy number one. Ken Allen: Public enemy number one. So, those refrigerants were phased out and that was part of the Montreal Protocol. That brought in HCFCs. So like the R-22 was used. R-22 had a very low ODP and it actually had a lower GWP than a lot of the refrigerants we use today, but it still had some ozone depletion potential and therefore it was slated to go away. It did go away and R-410A came in to replace it. So, the HCFCs were phased out and the HFCs were brought in. But many of the HFCs had a higher global warming potential than the HCFCs that they replaced. So they're next on the chopping block, and that's where the Kigali Amendment came in and said, "Look, we've gotten rid of all the ODP stuff, we're good on that, but now we have to combat the global warming potential refrigerants that we have replaced them with." And so they're going after the high-GWP stuff. And so if you look at this consumption and production phasedown schedule that the EPA has put together, they're actually doing this on a measurement of the GWP. Nate Budryk: Yeah, in millions of metric tons of exchange value equivalent, right? Ken Allen: Yeah, so they're equivalent to CO2, basically. If it were CO2, how many pounds of CO2 would one pound of your refrigerant equal? And I forget the number, I don't have it right here in front of me, but let's say that 410A is like 4200 maybe GWP. So that GWP equals 4250 pounds of CO2. See what I'm saying? Nate Budryk: Its impact on global warming is the equivalent of as if we were using... Ken Allen: Yeah, 4250 times that of one pound of CO2. Nate Budryk: Yeah, I got you. Ken Allen: If you look at the metric ton equivalency, that's where they're getting that from. Nate Budryk: Yep, yep, okay. So there's also some measurement uniformity that's being established too. Ken Allen: I mean, I think that's a good thing. Nate Budryk: Oh, yeah. Ken Allen: Because then that gives us the ability to maintain refrigerants that have a lower GWP and find meaningful ways to use them. There's no way to get to zero GWP. There's only a few refrigerants out there that allow us that – ammonia. And nobody's putting ammonia widespread in their house, we're not building ammonia air conditioners. Ammonia is a great refrigerant, fantastic energy efficiency, it's cheap, it's awesome, but you can't put it in copper tubes and you can't put it in somebody's house where it could leak out, because it is toxic too. Nate Budryk: Yeah. I'm sure carbon monoxide might be a great refrigerant too. Ken Allen: It might, I don't know. [Laughter] Ken Allen: Probably not putting that in an air conditioning unit. Nate Budryk: Yeah. Fair. Ken Allen: So we're stuck with the refrigerants that are safe and nontoxic for humans. Even the naturals, like I said, if you look at the GWP of CO2, it's called 1. If you look at the flammable refrigerants, they're like a GWP of 3. Which is fantastic and I think you'll see those used a lot more in refrigerators and units that use little small amounts of refrigerant. Nate Budryk: Like 290, you're talking about? Ken Allen: Mm-hmm, 600, 600a, 290, you're talking isobutane, butane, propane. These refrigerants are fantastic. They're low pressure, they're inexpensive, and they work great. And they're natural. So, if you release them, it's not that big a deal, the GWP is very low. As we go along, this measurement of GWP is going to allow manufacturers to start using or have a reason to start using these natural refrigerants to lower the number of GWP units that they use every year. Nate Budryk: Yeah, got you. Okay. So, now that we've talked more about the rule itself, the phasedown schedule is what a lot of people are going to be interested in and so we have that. Remember, the goal is to get to 15%, it's a reduction by 85% by 2036 and beyond. And so to do that, step one is a reduction of 90%. So it's tiered, right? It's like a stairstep. And then 60%. So 90% by 2023, 60% by 2028, 30% by 2033, 20% by 2035, and then the 15 – 2036 and beyond. So the consumption and production numbers, we're looking at about between 2020 and 2023, the consumption be 273.5 MMTEVe and then production of 344, and the idea being to get down to 45 consumption MMTEVe and 57.4 production. And just to clarify, consumption in this sense equals production plus imports minus exports. I heard a good way of describing that was that basically that's the supply. Ken Allen: Right. Yeah. Nate Budryk: Okay. Ken Allen: I think the interesting thing about how they've done this, and maybe the part that'll concern a lot of listeners, is that when we talk consumption and production, we're talking of companies that produce, manufacture, import, or export material. We're not talking about the actual consumers. For instance, we're not talking about General Electric that makes refrigerators, we're not talking about Trane that buys refrigerant, or me, if I went down the street and bought refrigerant. We're not talking about those. You can still buy all the refrigerant you want from your standard suppliers. But what's going to happen is those suppliers are the ones that have the EPA regulations thrust upon them. The people that import, the people that export, and the people that chemically produce the refrigerants here in the US are the ones that will have the quotas and the limitations put upon them. Nate Budryk: Yeah, and I think that's a perfect segue into the affected industries and then we can touch on the allowance portion of the discussion. Ken Allen: Mm-hmm. Nate Budryk: So, of the affected industries, we're going to get to those in a sec. The AIM Act did call out six application-specific, I believe? Yeah, six application-specific allowances, and some of those are for consumer products like defense spray like bear mace, propellants in metered-dose inhalers, and then there's also quite a bit for semiconductor production, as well as mission-critical military uses, and onboard aerospace fire suppression. So, I think you can largely call those mission-critical, things that the government has decided are important to the level that they will be less affected than whoever falls outside those six. Ken Allen: Yeah. Nate Budryk: Fair to say? Ken Allen: And honestly, most of our listeners probably are going to be in HVAC, in our industry, and those areas I don't think really affect them. They're being held open, my guess is because...or "addressed," excuse me, addressed specifically because the stuff that's coming to replace them is not yet proven or available or able to be applied easily to those industries. Nate Budryk: Yeah, so it makes sense. Especially now that we've seen the impact, it makes sense to, I guess, not protect them but just put them in a different category. Ken Allen: Yeah. It impacts the entire economy whether it affects you directly or not. Nate Budryk: Yeah, yep, for sure. So, part of what we talked about last time, and part of the portion of the rule that had yet to be determined was that they would establish an initial methodology for issuing allowances for next year, 2022, and then 2023. And so they have, I think, gone ahead and done that. Ken Allen: Yeah. Nate Budryk: Yeah, they have, with the final ruling. So, the allowances to companies that produced and/or imported HFCs in 2020 will be based on the three highest nonconsecutive years of production between 2011 and 2019. Ken Allen: Correct. That is my understanding. Nate Budryk: Okay. And then we talked about the six application-specific. And then the EPA will use an allowance as the unit of measure that controls production and consumption. So, this is how they're going to measure it. EPA will issue allowances that will be valid between January 1 and December 31 of a given year, also known as a calendar year allowance. A calendar year allowance represents the privilege granted to an entity to produce or import regulated substances in that year. And then entities will need to expend allowances in order to produce or import bulk HFCs. Producing HFCs will require expending both production allowances and consumption allowances. Importing HFCs will require expending only consumption allowances. Anything in there that stands out to you? Anything that you have further questions about? Anything that caught your eye? Ken Allen: When I first started reading that, I was kind of confused, and so I looked further into what the EPA was talking about. That was that pie chart that I sent you earlier. And in that pie chart, if you look at the production and the consumption, it's manufacturers. It's Honeywell, it's Chemours, it's all these other companies that actually make the refrigerants or import refrigerants from other countries. So, they're the ones that are going to be directly impacted because they're the ones given those production and consumption allowances, if you will. Of course, it's going to affect the rest of us because your ability to get these higher-GWP refrigerants will be impacted over time. But it's not like me as somebody that might buy a can of refrigerant or, say, Trane that buys a bottle of refrigerant, is going to be directly impacted. But they will be impacted and they know that. And so that's why companies that use lots of refrigerant are going to, if they're not already doing so, look for refrigerants with lower GWPs. Nate Budryk: Yep. Ken Allen: Supply and demand drives price. And so if more people are still demanding to buy 410A than their allowance is to produce or import, then the price is going to go up. It just makes sense. Nate Budryk: Yeah, and I think a good way to think about it is that this legislation is meant to do exactly what you're saying, which is to spur innovation, to prompt these bigger chemical companies or refrigerant suppliers to find more environmentally sustainable refrigerants. But it's also meant to slash demand. There's less demand for it, they work in concert basically to get us to that 85% reduction is the idea, right? Ken Allen: You remember what you said the main driver, the authorization of the EPA was? The AIM Act. Do you remember what that stands for? Nate Budryk: American Innovation in Manufacturing. Ken Allen: Innovation, right? Nate Budryk: That's right. Ken Allen: Look, when you start looking at some of these patchwork laws like California or Washington State or New York has put in place, and they're calling for, say, a refrigerant under 150 GWP. Remember I said there's not a lot of refrigerants out there that have that. So, immediately, you start going, "Okay, which refrigerants are out there that are lower than 150?" And there's only a couple that are synthetic-type refrigerants. There's a bunch that are natural but if it's CO2, it's high pressure. If it's propane, it's flammable. So, there's all these other caveats that you have to use. So, the reason I asked you what AIM stood for is that innovation part. So, I think what you're going to see is... Oh, and by the way, Chemours doesn't make propane and Chemours doesn't make CO2. At least I don't think they do. They are naturally-occurring substances. So, if Chemours wants to keep producing lots of refrigerant, they have to come up with refrigerants that are going to be not on that level of being phased...eating up their allowance. If they can produce a pound of some refrigerant that's 150 GWP versus a pound that's 4250, then they get to sell more pounds, therefore make more money. Otherwise, if they burn through their allowance in a year, either they can purchase some, I think, there was some trade method, or they can't produce anymore. And most companies I know, they like to make money, and to do it they sell product. So, obviously, they want to sell product that is going to make them be allowed to produce the most refrigerant or the most product that they can. Nate Budryk: Yeah, yeah. And I think that's a great way of looking at it. I think there is kind of an instinct to hear this mandate and think, "What the hell are we going to do? We're a refrigerant producer or we're an HVAC OEM that uses... Our systems are built for these refrigerants." I think a good way to look at that is more like, "Well, I guess it's up to us to innovate to a point where we can..." This is the new playing field, right? Ken Allen: Yep. Nate Budryk: You got to make stuff that works on this playing field or you can't play. Ken Allen: I'm definitely not one that likes writing laws or longwinded, but I really like the way they've put this together. And the reason I say that is because it hasn't told people, "This is what you will use or this is what you will not use." It has told people, "Here's how much you can make. Figure out how to make it the best for your business." And so we don't know what California will do with this. California could say, "Hey, we love this federal law. We're going to vacate what we're doing." I don't know. They probably won't. But it would be great if this became the prevailing law in the land and every other state just folded up under it. Because it sets a good framework to allow for companies to choose what works for them. But they're going to have to innovate if they want to stay current. Nate Budryk: Yeah. It's basically a global engineering challenge, right? Ken Allen: Yeah, it seems like it. Nate Budryk: All right. I think another thing that people are going to – and we'll probably wrap up with this – but I think another thing that folks are going to want to know about is exactly how it will be enforced and how compliance will be, I guess, dictated, or how to be compliant, or some of the measures that are going to revolve around compliance. So, EPA has outlined some of those so I think there's four or five here that we can run through and then I can get your take on them. Ken Allen: Okay. Nate Budryk: This new final rule, part of it, what it does is it establishes an electronic tracking system for the movement of HFCs through commerce. It requires the use of refillable cylinders and container labeling requirements as well. It also establishes administrative consequences. For example, revocation or retirement of allowances for noncompliance that would be in addition to any civil or criminal enforcement action. The rule also requires third-party auditing of companies' recordkeeping and reporting, as well as they must provide transparency of HFC production and consumption data for the general public and participants in the market, and also support enforcement and compliance efforts. So, I'm not very well-versed on how it's regulated now, but that seems pretty sweeping, pretty comprehensive. Ken Allen: It seems pretty in depth. Nate Budryk: Yeah. Ken Allen: Some of that's going to take a while to be put into place. Like that first one you mentioned, the electronic tracking system. I think they've said that that's going to not be in place or isn't required to be in place until 2027. Nate Budryk: Okay. Ken Allen: That's going to take a bunch to put together, right? Right now, if you go buy a can of refrigerant from the supplier down the street, you have to show your refrigerants license and they record it because they have to keep up with it but I don't think it's electronic. Part of this thing is it's supposed to be able scan, I think it said a QR code. So, you actually scan with, I guess, maybe your phone? That's why it's not in place. And maybe it goes to a federal database so that everybody knows where everything went. I don't know. Maybe that's why they need till 2027 to put it into place. But the third-party auditing, I don't think that has been a part of it now. You have to have recordkeeping that you have to produce for material you buy and use on a yearly basis, if you use a certain amount under the current law, I think. But this rule is going to be much more, I think as you said, sweeping. What exactly that means to the average guy that's running around on three service tech trucks, I don't know, I don't know. But for the bigger companies, I'm sure it's going to be a lot of recordkeeping and you're going to have third-party audits of your stuff, so you better have your stuff in place and correct. Otherwise, like it says, it can lead to civil fines, criminal fines, or criminal enforcement and revocation of some of your allowances. Nate Budryk: Well, I reckon that's just about it. I don't know if you wanted to touch on anything like looking towards to the future, if you had any speculation. We want to, I guess, avoid speculation in its pure sense. But I guess my question would be where do you see this, what's next? I know there's a petition period and I know several petitions have already been submitted by I think a lot of industrial representatives, manufacturers. Ken Allen: There's a bunch of stakeholders. When you think of the different areas of manufacturing out there and everybody has a manufacturing group. The air conditioning people have AHRI, they talk to the EPA, they do petitions. And then you have guys that make appliances, I think it's called AHAM. Every one of these. And the IIAR which was originally for ammonia refrigeration but has since become kind of a standard-setting body for natural refrigerants. They've petitioned them on some stuff. I don't know where it's going to go. I think at the end of the day, everybody has in mind to get to a lower GWP, how we get there is just a different story. It's going to be through innovation of whether it's the working fluid, the refrigerant, or the appliance that we do. If you thought changing from R-22 to 410A was hard, because things had to change because of the pressure difference, imagine you're going from R-404A, which is an A1 refrigerant, to propane. And you have to put a half-a-million dollar charging station in your plant. And that's just one charging station. Nate Budryk: At one plant. Ken Allen: At one plant. So, if you're producing 1,000 units a day, you need multiple charging stations, so it's multiple $500,000 outlays. And people have already started making these changes because they knew the writing was on the wall with Kigali, even though it took us a long time to ratify it, with the EPA not being able to regulate HFCs. People knew that the writing was on the wall. That's where we're going, it's just legal mumbo jumbo to get there. So, if you're looking at natural refrigerants, and they call those future-proof because you're under that 150, and that 150 GWP to me seems like it's where everybody wants to go. There's just no practical road there yet for a lot of areas. It exists for some refrigeration. It doesn't exist for home air conditioner yet. Nate Budryk: And that's the big one. The pharmaceutical companies want to prescribe stuff for chronic back pain because everybody's got it. You want to get something that can get into residential. Ken Allen: Residential and light commercial stuff. I may be wrong, I don't have it in front of me, but I think R-32 is like 675 GWP. Nate Budryk: I think that is exactly right. Ken Allen: Okay. It seems like a great refrigerant, it works well, it's energy-efficient. The down side is it's an A2L. But it's still 675. That's what I'm getting at. There's no really great path to that 150 for air conditioning yet. Nate Budryk: Yeah. Ken Allen: Yet. Nate Budryk: Yet. Ken Allen: I think this will stir people and companies to start working on that, because they know they're going to... Yeah, 750 might be given as a place today we want to be, but that's just for the day. Nate Budryk: Yep. There's still some ink that needs to dry. We'll see when it comes time for this to all go into effect. We'll see how it looks and we'll keep learning as we go. Ken Allen: Yep, absolutely. Nate Budryk: And with that, Ken, I think we'll wrap up. Appreciate your participation, as always. Always enjoy these and learn some good stuff and so, yeah, we'll see you on the next one. 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