Between
EPA
and
APAA
2000
omplex
501
3rd
Street
/

;
Director
Office
of
Atmospheric
Programs
(
OAP)
ratospheric
Protection
Division
(
SPD)
hief,
Program
Implementation
Branch
(
PIB)

TOPIC
Update
on
proposed
rule
Protection
of
Stratospheric
Ozone;
Substitute
Refrigerants
(
63
FR
32044)
June
1
I,
1998
AL
ss
MC
ss
JB
PS
AL
JB­
APAA
requested
meeting
in
order
to
receive
an
update
on
the
substitutes
rule
and
to
meet
new
personnel
anticipate
rule
becoming
effective
Fall
2000
will
a
sales
restriction
on
HFC­
134a
be
included
in
the
rulemaking?

At
this
date
there
is
more
work
to
be
done.
The
Agency
has
not
decided
on
a
sales
restriction.

SPD
will
provide
APAA
with
a
request
for
documents
supporting
their
position
against
a
sales
restriction.
,

Budget
restrictions
and
personnel
changes
have
slowed
the
rule
making
process.
OAP
is
not
as
contractor­
dependent
as
other
offices
of
EPA.

Retrofit
rates
have
greatly
decreased
since
1998.

How
will
a
decrease
in
retroffiting
affect
the
rulemaking?

AL
&
MC
The
RIA
is
based
upon
cross
contamination
due
to
DlYers
attempts
at
If
retrofits
are
decreasing
then
the
need
for
a
sales
restriction
JB
The
first
vehicles
with
OEM
MVACs
should
be
nearing
the
end
of
their
life
spans,
shouldn't
this
have
an
impact
on
EPAs
decision
to
restrict
sales
of
a
substitute
refrig
e
rant?
o
not
believe
that
those
rea
the
ends
of
their
lifespans.

L
No
response.

SS
Yes
they
will.

MC
APAA
has
surveys
stating
that
DlYers
are
environmentally
consc
DH
Does
APAA
have
empirical
including
the
current
beha
'
ir
position
on
a
sales
restriction,
ulation?

SS
How
will
a
DlYer
perfo
recovery
refrigerant
without
I
.
recyclingkecovery
eq
uipm
AL
There
is
no
evidence
ians
use
the
required
recycling
equip
men
t
.

DH
EPA­
Office
of
Mobile
states
otherwise.
There
have
not
been
industrial
and
commercial
I
many
enforcement
actions
a
Also
violation
tips
ten
sectors,
not
MVAC
shops
icians
with
recycling
equipment.

MC
Are
these
inspections
blind
PS
Yes
they
are
blind
inspections
MC
This
regulation
has
no
teeth.
The
Agency
should
not
go
after
individual
users
for
venting
.

AL
We
prefer
mandatory
labeling,
education
at
the
point
of
sale,
and
unique
fittings.

DH
How
is
education
at
the
pont
of
sale
more
effective,
than
a
structured
course
followed
by
testing
and
eventual
certification?

EPA
has
no
data
to
support
that
technician
certification
equates
to
compliance.
It
is
an
argument
that
APAA
has
presented
earlier.
AL
