Advocacy comments on EPA’s proposed phasedown of HFCs required by the American Innovation and Manufacturing Act
On May 19, 2021, the Environmental Protection Agency (EPA) published a proposed rule titled “Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program Under the American Innovation and Manufacturing Act.” The letter below constitutes the Office of Advocacy’s (Advocacy) public comments on the proposed rule.
A wide range of small businesses will be affected by this proposed rule, from importers and blenders, to equipment servicers and reclaimers, and eventually the owners and operators of refrigeration equipment. Because of this diversity of views and effects, Advocacy believes that EPA should be evaluating alternatives for the long-term health of a future market for hydrofluorocarbons (HFCs), including minimizing transaction costs and encouraging innovation. EPA should recognize that allowances have a market value and give small business blenders and reclaimers reasonable preferences in their allocation to aid their long-term viability. EPA should reconsider its proposed HFC tracking system and ban on disposable cylinders since they raise transaction costs significantly.
 86 Fed. Reg. 27150 (May 19, 2021)