Meeting Summary—Meeting Between EPA Staff and Representatives of
Aftermarket Organizations

Date:	December 1, 2009

Participants:

Michael Conlon, Conlon, Fratz & Phelan

Aaron Lowe, Automotive Aftermarket Industry Association

Douglas Wheeler, Hogan and Hartson (on behalf of IDQ)

Julius Banks, EPA/SPD

Yaidi Cancel, EPA/SPD

Drusilla Hufford, EPA/SPD

Cindy Newberg, EPA/SPD

Margaret Sheppard, EPA/SPD

Mr. Conlon, Mr. Lowe, and Mr. Wheeler indicated that their organizations
intended to submit comments on the proposed SNAP rule on HFO-1234yf.

 

Topics discussed in the meeting included:

The relationship between the proposed rule on HFO-1234yf under the
Significant New Alternatives Policy (SNAP) program and an upcoming
Significant New Use Rule (SNUR) under the Pre-Manufacture Notice (PMN)
program.

The basis for the concern about the toxicity of HFO-1234yf.

Flammability of HFO-1234yf.

Possible future rules related to servicing of motor vehicle air
conditioning (MVAC) systems.

What would be needed in order for EPA to consider retrofit use of
HFO-1234yf in MVAC.

Aftermarket representatives’ concern about potential restriction of
servicing by “do-it-yourselfers” under the upcoming SNUR.

Options for the aftermarket representatives if the SNUR is not published
before the end of the public comment period for the SNAP rule on
HFO-1234yf.

Other EPA rules that might potentially affect the aftermarket (e.g.,
SNAP rule for CO2 as an automotive refrigerant, rule on HCFC reductions.

