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EPARulemakingEPA-HQ-OAR-2021-0044

Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act

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U.S. Chamber of Commerce filings
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U.S. Chamber of Commerce filed 1 comment on this docket between Jul 7, 2021 and Jul 7, 2021. 68 other organizations filed here. The comment window closed 1848d ago.

What U.S. Chamber of Commerce filed (1)

Jul 7, 2021· Comment submitted by U.S. Chamber of Commerce et al.· EPA-HQ-OAR-2021-0044-0171

Re: Comments on Proposed Rule: Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading; 86 FR 27150 Dear Administrator Regan: We, the undersigned organizations, are pleased to provide the attached comments to the proposed "Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading" rule. This rule would implement the first and most significant step to phasedown hydrofluorocarbons (HFCs) under the American Innovation and Manufacturing Act of 2020 (enacted as part of H.R. 133, the Consolidated Appropriations Act of 2021, P.L. 116-260). We appreciate the opportunity to provide input on the important role of phasing down HFCs to contribute to our recovering economy and to address climate change. The allocation approach outlined in the proposed rule should provide long-term regulatory certainty. This would ensure that U.S. manufacturers remain global leaders. The rule should also apply to our foreign competitors in a manner consistent with the Kigali amendment to the Montreal Protocol, as we transition out away from high global warming potential (GWP) HFCs. HFCs are compounds typically used as refrigerants, foam-blowing agents, etchants, solvents, propellants, and fire suppressants, providing critical services to society. The market for next generation products and equipment (e.g., HFC substitutes) is globally integrated, highly competitive, and rapidly growing. Phasing down HFCs requires products manufacturers and OEMs to invest in the transition, and there are estimates that some sectors could directly add 33,000 U.S. manufacturing jobs over the next decade. In addition, this proposal is the first step in growing the U.S. share of the world market for some types of heating, air-conditioning, and commercial refrigeration equipment by 25%. Implementing the HFC phasedown globally would reduce a significant source of emissions that contribute to climate change, avoiding up to 0.5 degrees C in temperature increases by 2100. If the Administration is to achieve its ambitious climate goals, collaboration with American businesses to phase down HFCs must be part of the solution. Completion of this rule on time with these modifications is critical for the environment, the regulated industry, and the U.S. economy. In conclusion, this rule should provide equipment U.S. producers, importers, and users predictability, regulatory certainty, and a flexible approach. These critical components will allow manufacturers U.S. producers and their customers to the ability to reduce emissions in the most cost-effective way, while maintaining their competitiveness in world markets. Thank you again. We stand ready to support the agency as it works towards finalizing this rule. Sincerely, Alliance for Automotive Innovation Alliance for Responsive Atmospheric Policy American Chemistry Council Air-Conditioning, Heating & Refrigeration Institute Association of Equipment Manufacturers Association of Home Appliance Manufacturers Truck and Engine Manufacturers Association U.S. Chamber of Commerce

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Abstract

This rule will implement the hydrofluorocarbon (HFC) phasedown under the American Innovation and Manufacturing (AIM) Act, enacted on December 27, 2020. This rulemaking will: establish the hydrofluorocarbon production and consumption baselines based on historical data; establish the allowance allocation program to phase down hydrofluorocarbon production and consumption; determine an initial methodology to allocating allowances and allowing for the transfer of those allowances; establish provisions for the international transfer of allowances; establish requirements to support compliance with phasing down hydrofluorocarbon production and consumption; establish recordkeeping and reporting requirements; release certain data to provide transparency and support implementation of the program; and, address certain other elements related to the effective implementation of the Aim Act.

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