Global Automakers provided comments to the Environmental Protection Agency (EPA) on its August 6, 2014 proposed rule on Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program. In its comments, Global Automakers:
- Recommends that the Environmental Protection Agency (EPA) revise the rulemaking to exempt vehicles produced for export to markets that have not adopted provisions for alternative refrigerants and that do not have sufficient infrastructure to support such refrigerants.
- Recommends that EPA revise the rulemaking to delist HFC-134a following the end of MY 2025.
- Provides a few ancillary comments regarding servicing the legacy fleet.
- Notes that the ability to comply with EPA’s proposed SNAP rule is contingent upon the availability and adequate supply of alternative refrigerants.