ENVIRONMENTAL PROTECTION AGENCY

	

	Public Hearing

Greenhouse Gas Mandatory Reporting Rule, 

Additional Sources of F-Gases Subparts I

(Electronics Manufacturing), L (Fluorinated Gas

Production), DD (Electric Transmission and

Distribution Equipment Use), QQ (Imports and

Exports of Fluorinated GHGs inside

pre-charged equipment and closed-cell foams) and

SS (Electrical Equipment Manufacture or

Refurbishment)

	9:05 a.m. to 11:55 a.m.

	Tuesday, April 20, 2010

1310 L St, NW

Washington, DC

	C O N T E N T S

                                        

                                             PAGE

Welcoming Remarks

  Paul Gunning, Presiding Officer...............3

Introductory Remarks

  Paul Gunning..................................4

	Morning Public Comments

David Stirpe, 

  Alliance for Responsible Atmospheric Policy...8

Thomas Diamond, 

  Semiconductor Industry Association...........12

Peter Zalzal, Environmental Defense Fund.......25

Daniel Chartier, Edison Electric Institute.....29

	- - -

	P R O C E E D I N G S

	Welcoming Remarks

	MR. GUNNING:  Good morning everybody.  I am Paul Gunning with the
Environmental Protection Agency here in the Climate Change Division, and
I welcome you all here this morning to our public hearing on the
Mandatory Reporting Rule specifically additional source categories
covering the fluorinated greenhouse gases.

	Thank you all, first of all, for coming this morning.  We are looking
forward to hearing your comments and insights and perspectives on these
proposed subparts for Mandatory Reporting Rule.  

Introductory Remarks

	As you well know, the purpose of the hearing today is to receive your
comments and we are looking forward to hear those comments.  We’re
specifically covering five subparts under the Mandatory Reporting Rule,
specifically Subpart I which covers electronics manufacturing, Subpart L
which covers fluorinated gas production, Subpart DD which covers
electric transmission and distribution and equipment use, Subpart QQ
which covers importers and exporters of fluorinated greenhouse gases
contained in charged equipment and closed-cell foams and finally Subpart
SS, electrical equipment manufacture or refurbishment.  See if I said
that right this morning with my coffee.

	Of course we’re covering this hearing and holding this hearing today
in accordance and in support of the Clean Air Act which does provide
interested parties the opportunity to present their views, arguments and
perspectives on this proposed rule.  We also of course had an open
docket and are requesting and encouraging you to also submit written
comments.  This hearing this morning provides the opportunity for your
oral presentations.  

	As you’ll note with the mikes – I know it’s a very small room,
but we are recording this public hearing and we will be developing a
transcript that will be made available and put in the docket.

	As a point of note the docket and the docket number is HQ – if
you’re interested in finding this – OAR-2009-0927.  And again,
we’ll make that transcript available and the docket will also be
available electronically on regulations.gov.

	So this morning we’ll be conducting this hearing in an informal
manner.  We will not be applying the official rules of evidence.  I will
be the presiding officer.  

	We have several other EPA officials in the room here today this morning
that have worked hard and diligently on the proposed rule and will be
working to make this a final rule.  I’d like to just quickly introduce
those folks who have put a lot of effort into this rule, Debbie
Ottinger, Kirsten Kappel, Scott Bartos who is not here this morning –
I’m looking around the room – there’s Sally Rand, okay, Sally
Rand, and is that everybody that’s here this morning?  Okay.  So
they’ll be here and listening closely to the comments you’re
providing.  

	In terms of the process and the order for this morning, I’d like to
ask everyone to try to keep their comments and thoughts to around ten
minutes.  I’d like to please ask everybody to turn off your cell
phones, cell phones and Blackberries.  They do disturb the hearing.

	A number of you have signed in already.  I will be calling folks up in
order of who signed up.  And please in advance of delivering your
comments, note your name and your organizational affiliation if
appropriate. 

	In addition, again, to emphasize this is an opportunity for oral
statements.  We will ask clarifying questions, but we also encourage you
to submit your comments to the docket especially if there is a variation
between your written and oral presentations.

	It looks like at the moment we only have a few speakers signed up this
morning, so as a point of order we’ll just proceed and see if there
are additional individuals that are interested in commenting and take
breaks accordingly.  One other logistical note, the restrooms are
located just right down this hallway if you haven’t found them
already. 

	And let me return to my seat here and we’ll begin the hearing.  Okay,
so I will start introducing the first person, David Stirpe.  I’d like
to invite you to come up please for your comments.

	One additional note, obviously we’re dealing with many subparts this
morning and I realize that some of you may be commenting on several
subparts.  So, as you deliver your comments, please preface them with
which subpart or subparts you’re addressing this morning.  Thank you.

	MR. STIRPE:  Good morning.  My name is Dave Stirpe and I’m with the
Alliance for Responsible Atmospheric Policy.  On behalf of the Alliance
and the industry coalition, I am pleased to make some comments regarding
the proposed rule addressing mandatory reporting of certain fluorinated
greenhouse gases. I’m going to comment mostly on Subpart L.

	The Alliance is an industry coalition that was organized in 1980 to
address the issue of stratospheric ozone depletion.  It is composed of
manufacturers and businesses including associations that produce and
rely on CFCs, HCFCs and HFCs.  Today, the Alliance coordinates industry
participation and the development of reasonable international government
policies regarding ozone protection climate change.

	The Alliance has a long history of working in a positive manner with
EPA on these issues.  We believe that accurate and timely data is
necessary when decision makers and businesses work to formulate policy. 


	In addition to working with EPA over several decades to voluntarily
report and ascertain certain emissions of HCFCs and HFCs, Alliance
members are mindful of efforts to reduce emissions of these compounds
including containment, recovery, recycling, reclamation and destruction.
 We’ve always advocated the responsible use of these compounds in ways
that have significantly reduced emissions, allowed the phase down of
HCFCs, encouraged a smooth transition of alternatives and provided
societal value for citizens who rely on energy-efficient air
conditioning, refrigeration and foam insulation.

	The Alliance appreciates EPA’s careful consideration of the public
comments submitted by the Alliance and its members last year on the
original proposal to report greenhouse gases.  

	We thank you for revising and re-proposing significant pieces of the
proposal.  It appears to us that EPA addressed many concerns including
the monitoring and emissions reporting procedures that appear to have
improved.

	We plan to more close examine the rule of the next days and we will
elaborate on our comments in writing by June 11th.

	The Alliance appreciates EPA’s efforts to integrate Subpart L and
last year’s Subpart OO to minimize overlap.  Both the proposed Subpart
L and the final Subpart OO require fluorinated greenhouse gas reporting.
 EPA should develop a method to consolidate production reporting between
the two subparts.

	As much of the required reporting information is confidential business
information, the Alliance supports EPA developing appropriate
confidential business information protections in the pending part 98
reporting tool.  

	The Alliance appreciates EPA allowing best available monitoring methods
for the entire 2011 calendar year since there’s a large amount of
preparation, monitoring and record keeping, that each reporting facility
must establish to comply with proposed Subpart L.  However, some may be
concerned that a one-year implementation period may not be adequate. 
The Alliance will examine the requirement for importers and exporters of
pre-charged equipment and closed cell foam to report their imports and
exports to EPA and may elaborate on this further in written comments.  

	Thank you for the opportunity to comment today. 

	MR. GUNNING:  Thanks, David.

	Okay.  The next speaker, I’d like to ask Tom Diamond to come up,
please.  Thank you.

	MR. DIAMOND:  My name is Tom Diamond.  

	[Pause.]

	Good morning.  My name is Tom Diamond.  I’m the Director of
Environmental Health and Safety for the Semiconductor Industry
Association.  On behalf of the SIA, let me take this opportunity to
thank you for this opportunity to testify today on the mandatory of
reporting of greenhouse gases.

	The SIA understands that the USEPA faces a mandate from Congress to
develop regulations for reporting greenhouse gas emissions information. 
We want to work cooperatively with the Agency as we have in the past
under our voluntary MOU program.  We give our full support to its
implementation of this mandate.  

	We also greatly appreciate EPA’s responsiveness to our comments on
the original proposal and decision to defer greenhouse gas reporting
regime for our industry and to engage in additional rulemaking.  The SIA
is now engaged in an internal process with our members to evaluate
carefully the reporting rule re-proposal. 

	As you know, for the original proposal, SIA commissioned a survey by an
independent entity, the International SEMATECH Manufacturing Initiative,
with whom the USEPA itself has partnered on a mission reporting method
development.  That survey indicated compliance with the original
proposal would have necessitated extensive operational and
infrastructure changes which where technically feasible, would far
exceed the $3.6 million estimate by the USEPA and instead would run into
the tens of millions.  Moreover, under no circumstance, could those
changes have occurred in the reporting timeframe specified in the
original proposal.  The SIA has commissioned a supplemental survey by
ISMI keyed to address the technical requirements and costs that would be
associated with the re-proposal.  We expect to have a preliminary report
from ISMI on the supplemental survey by mid May.  At that time, we will
share those results with the Agency and engage in further dialogue. 

	In addition to the ISMI supplemental survey, the SIA has been working
with our members to analyze the re-proposal from a technical, policy and
legal standpoint.  We have not yet completed our analysis process, but I
can highlight today several aspects of the re-proposal that our members
have identified as being of potential concern.  

	The reporting threshold equation.  The equation for semiconductor
manufacture is to calculate whether or not a facility exceeds the 25,000
tons of carbon dioxide equivalent reporting threshold appears flawed. 
The equation itself lacks a CO2e conversion step based on the global
warming potential of the individual gases. It also appears to constitute
a potential to emit equation based on 100 percent of the manufacturing
capacity factor as opposed to an actual emission calculation that should
serve as a trigger for reporting obligations.

	Process categories.  The re-proposal sets out nine semiconductor
manufacturing process categories and subcategories.  The re-proposal
would require annual reporting on both usage and mass emission
information for each of these categories and subcategories on an
individual gas by gas basis as well as for a tenth, nitrous oxide, other
category.  The SIA appreciates the re-proposal in contrast to the
original would allow semi-conductor manufacturers to calculate emissions
instead of requiring individual tool measurements or continuous
emissions monitoring neither of which are technically or economically
feasible at this time.  

	Nevertheless, the re-proposal process-based reporting scheme raises
several potential concerns.  First, protection of trade secret
information – information about which gases a facility uses and which
processes and the amount would reveal competitively valuable trade
secret information.  Indeed, such details of greenhouse gas usage and
emissions by process would provide those familiar with our industry
specific knowledge of proprietary device designs and manufacturing
process, and also effectively may reveal customer sensitive product
information based on manufacture or loading.  Annual production levels
and/or facilities capacities also could be used by competitors to
characterize manufacturing efficiencies and to influence prospective
customer decisions.  Under the circumstances, our members likely would
have no choice but to claim much of the information that would be
required under the re-proposal as confidential including the mass
emission information broken down by gas and by process.

	We understand the EPA may wish to receive some of this kind of
information from our members to verify their compliance.  We question,
however, the need of the Agency to receive it routinely especially in
view of the trade secret nature of the information. 

	CO2 equivalent conversion.  The re-proposal would appear to require gas
by gas reporting of usage and emission information by process category
or subcategory on a mass basis without any CO2e conversion.  The SIA is
concerned this reporting approach in particular, the re-proposal
provides no indication of whether the EPA plans to make this information
publicly available or instead will undertake to convert it to CO2e.  

	If the EPA intends to undertake a conversion, the SIA would question
what methodology and what GWP factors will get used and how the
resulting numbers will get displayed and explained to the public. 

	Compliance burden and cost.  As noted above, the SIA greatly
appreciates that the re-proposal would allow for an emission factor
approach and also is responsive to the SIA’s suggestion in our
comments on the original proposal to allow gas usage fuel factors based
on cylinder-change triggers.  The re-proposal, however, may end up
imposing an equal or even greater burden as compared with the original
proposal.  

	In particularly, the re-proposal would require semi-conductor
manufacturers to break emissions down on a gas by gas basis for each of
the nine process categories plus the tenth nitrous oxide category. 
Moreover, the re-proposal would mandate that such breakdown occur based
on quantifiable indicators and not based on engineering judgment.  This
reporting scheme may result in significant compliance burdens and cost. 
The ISMI supplemental survey aims to assess these burdens and costs. 
Based on the supplemental survey results, the SIA will address whether
these burdens and costs are reasonable or not in view of the USEPA’s
apparent objective to reduce uncertainty.

	Default factors.  The re-proposal would not adopt the SIA’s suggested
alternative in our comments to the original proposal.  Under that
alternative, facilities would report emissions based on the
Intergovernmental Panel on Climate Change or the IPCC emissions
assessment methods that are now being used by our industry but with
several enhancements.  Instead, the re-proposal envisions that the USEPA
would establish its own default emission factors for each of the process
categories and subcategories on an individual gas basis.  The
re-proposal provides little detail on how the Agency will derive these
factors.  

	We understand that the USEPA has solicited information from equipment
suppliers to our industry through the Semiconductor Equipment
Manufacturers International or SEMI trade association.  But the process
by which this solicitation occurred has not been transparent to the SIA.
 We were informed during the USEPA’s electronics industry sector
outreach teleconference last week that all the information provided by
SEMI through the solicitation has been claimed as confidential and
therefore is not available to us.  

	Although the USEPA indicated in the re-proposal that it may issue a
notice of availability of data for comment on the default emission
factors, it does not commit to do so and indeed suggests the agency may
decide in the interest of time simply to include the factors as part of
the final rule without any notice and opportunity for comment.  The SIA
does not believe that this approach would comport with basic
administrative process mandates of the Clean Air Act and Administrative
Procedures Act.

	Moreover, as stated in our February 25th letter to the EPA, SIA would
consider supporting the development in the future of process specific
emission factors through a collaborative effort such as the next IPCC
evaluation by working with our tool suppliers to gather more data and to
share the cost of testing.  This approach would provide the best path
forward. Not only would it provide an international collaboration and
acceptance that is necessary to avoid serious damage to competitiveness
of the U.S.-based semiconductor operations, but it also would ensure
greater transparency and burden sharing.  Indeed, the SIA continues to
believe that until an international community moves beyond the current
IPCC factors, a reporting rule that allows existing sources to use the
IPCC Tier 2B factors would provide a robust scheme for semiconductor
manufacturing, greenhouse gas emission reporting with suitable accuracy
to satisfy the agency’s objectives.  Under the circumstances, the
burdens and cost associated with other approaches in the name of greater
precision are difficult to justify, particularly given that greenhouse
gas emissions from the semiconductor industry are less than 0.1 percent
of the U.S. inventory of greenhouse emissions, perfluorocarbons are
critical to the semiconductor manufacturing process, and that the
re-proposal would impose greenhouse gas reporting burdens far exceeding
other regions of the world and therefore would place the domestic
semiconductor industry, the country’s second leading export sector and
source of approximately 200,000 high-paying jobs, at a distinct
competitive disadvantage.

	Abatement technology.  The re-proposal would prohibit semiconductor
manufacturers from obtaining full credit for the emission reductions
provided by the greenhouse gas abatement devices unless the source
undertakes the following measures on an annual basis.  First,
certification that each abatement system has been installed and is
maintained and operated in accordance with the manufacturer’s
specification. Second, an accounting of each system’s up time.  Third,
a random sampling of three units or 20 percent of the installed units
whichever is greater following the EPA’s DRE protocol.  

	The SIA is concerned that the foregoing measures would require
semiconductor manufacturers to generate a large amount of information on
an annual basis for the hundreds of point of use abatement devices used
for greenhouse gas control on individual process tools.  Doing so would
provide quite costly and burdensome.  

	We acknowledge that the re-proposal would allow the use of default DREs
in lieu of the foregoing and appreciate the EPA’s willingness to
provide this option in contrast to the original proposal which had not
provided any such option. The re-proposal’s 60 percent default DRE
value, however, falls well short of the GHG control offered by our point
of use devices and therefore penalizes semiconductor manufacturers who
have operated voluntarily in good faith under our MOU and other
greenhouse gas reduction programs to install and maintain control
devices. 

	The ISMI supplemental survey, the SIA hopes to gain a clearer picture
of the cost associated with the re-proposal’s abatement requirements
and looks forward to discussing the alternative approaches and a more
appropriate DRE value.  

	In closing, we look forward to continuing to work with the EPA to meet
the objectives of the rule.  We believe that the objective can be met
with an alternative reporting structure that is more closely aligned
with the capabilities of our sector.  Thank you.

	MR. GUNNING:  Thanks for your comments.

	Okay.  Our third speaker, I’d like to ask Peter Zalzal.

	MR. ZALZAL:  Good morning.  My name is Peter Zalzal.  I’m an attorney
with the Environmental Defense Fund and thank you for the opportunity
for giving comments today.  

	I’m just going to touch on three brief points and they relate
generally to all the fluorinated greenhouse gas rules.

	First, I’d like to say we appreciate EPA’s action to require
reporting from fluorinated greenhouse gas sources given the nature of
these gases.  Fluorinated greenhouse gases are atmospherically
persistent and have an extremely high global warming potential.  In its
fourth assessment report, IPCC recognized that non-CO2 gases from
manufacturing – HFCs, PFCs, SF6 and N20 are increasing and such gases
have extremely long lifetimes – thousands of years and GWP values
thousands of times those of CO2 resulting in virtually irreversible
atmospheric impacts.

	EPA has recognized he critical nature of these gases given their
potency and long atmospheric lifetimes.  EPA has entered into voluntary
partnerships with industry aimed at reducing fluorinated greenhouse
gases.  And EPA’s ozone protection regulatory programs are working to
limit emissions through mandatory recycling or use restrictions.  

	The proposed greenhouse gas reporting rule will provide EPA with
indispensable data as it moves forward with these and other efforts to
address high GWP gas omissions in the most effective manner.

	Second, I’d like to talk briefly about the scope of the rule.  EDF
applauds EPA’s inclusion of manufacturers or refurbishers of
electrical equipment and importers and exporters of pre-charged
equipment and closed cell phones. Inclusion in the MRR of refrigeration
and air conditioning equipment that holds large banks of fluorinated gas
omissions is a key step towards improving the responsible disposal and
destruction of high GWP gases contained within them. 

	Likewise, given their potentially significant greenhouse gas footprint,
EDF supports the Agency’s proposal to include fluorinated greenhouse
gases emitted as a byproduct of the production of CFCs and HCFCs, and
fluorinated greenhouse gases emitted as a feedstock or byproduct of a
transformation process.  

	EDF also encourages EPA to include fluorinated gases that while neither
reactants nor products are generated as byproducts, are intermediaries
of another reaction.  

	Finally, where there are very high numbers of sources in many different
locations as is the case for SF6 from electrical equipment, it may be
appropriate to provide an alternative facility definition.  And we look
forward to providing more detailed written comments on effective
approaches to address the applicability of the emissions reporting
requirements for this sector. 

	Lastly, EDF shares the Agency’s interest in accurate, reliable data
and we recognize that system-wide accuracy can often be achieved through
a combination of monitoring methods.  We know that EPA has generally
expanded the monitoring methods available to fluorinated gas facilities
including proposing a refined method for estimating emissions factors
from semiconductor facilities in lieu of the 2006 IPCC Tier 3 method and
allowing producers of fluorinated greenhouse gases increased flexibility
in using mass balance measurements to monitor their emissions.  EDF
encourages the Agency to ensure that these revised methods do indeed
provide accurate data and we look forward to providing more detailed
analyses of the proposal in our written comments.

	EDF greatly appreciates the Agency’s leadership in developing the
Fluorinated Greenhouse Gas Reporting Rule which will provide extremely
important data.

	Thank you again for the opportunity to testify today and we look
forward to offering more detailed comments on the Agency’s proposal in
our written submissions.  Thanks.

	MR. GUNNING:  Thanks, Peter.  I’d like to ask Dan Chartier to come
up, please. 

	MR. CHARTIER:  Good morning.  My name’s Dan Chartier.  I’m here
today representing the Edison Electric Institute or EEI as it is also
known.  

	I appreciate the opportunity to address EPA’s revisions to the
greenhouse gas reporting requirements for sources of fluorinated gases
specifically Subpart DD on electric transmission and distribution
equipment use.

	The Edison Electric Institute is the association of U.S.
shareholder-owned electric utilities.  Our members serve 95 percent of
the ultimate customers in the shareholder-owned segment of the industry
and represent roughly 70 percent of the U.S. electric power industry
over all.  We also have more than 70 international electric companies as
affiliate members and more than 200 industry suppliers in related
organizations as associate members. 

	In addition to generating electricity, EEI’s members own and operate
electric power, transmission and distributions that use a fluorinated
gas, sulfur hexafluoride or SF6 for short as insulation and would be
required to report SF6 emissions once this part of the mandatory
reporting rule is finalized.

	EEI provides these preliminary comments on the proposed revision now
and intends to file written comments at the appropriate time.  EEI notes
that EPA’s initial proposal for reporting SF6 emissions from
electrical transmission and distribution equipment used a definition of
the term “facility” that is dependent on the physical proximity of
possible emission sources.  This definition which makes sense for other
source categories is difficult to apply to transmission and distribution
systems which can span hundreds if not thousands of miles.

	Moreover, transmission and distribution system components from the
point at which electricity is generated to the point at which it is
delivered to the ultimate customer, may have multiple owners or
operators.  For this reason, in comments filed last year in EPA’s
initial proposal, EEI urged the Agency to require reporting of SF6
emissions at the corporate level consistent with the methodology
employed by the voluntary SF6 emissions reduction partnership program. 

	In comments filed last year, EEI also noted other practical concerns
for using the facility approach to SF6 reporting.  EEI appreciates
EPA’s recognition of the concerns and the Agency’s prior decision
not to finalize the initial proposed rule for this source category at
the end of last year.  EEI also appreciates the Agency’s willingness
to revisit the definition of source category and the term “facility”
as they relate to SF6 emissions in the current proposal.

	In the proposed revisions, EPA does not adopt corporate level reporting
for SF6 emissions and instead focuses on system-wide reporting.  EEI is
in the process of reviewing EPA’s proposed definition of “electric
power system” and considering the implications distinguishing between
electric power systems on the basis of ownership or control.  EEI will
address these issues in more detail in its written comments. 

	Also at this time, EEI raises the following concerns.

	First, there are a myriad of ownership and operational relationships
for electric power systems across regions and companies.  Some of these
may be quite complex and not amenable to reporting the system-wide
level.

	Second, given the unique definition of “facility” that EPA proposes
to use for reporting emissions from only electric transmission and
distribution equipment, EPA should not include this subcategory in the
list of all in sources in 40 CFR of Section 98 2A1.  Moreover, assuming
for the sake of argument that reporting is required at the electric
power system level, EPA should clarify that SF6 emissions need only be
reported by the appropriate electric power system and need not be
included in the facility-level reports that are required by other
subcategory of emission sources.

	EPA’s proposal to hold both owners and operators of electrical power
systems responsible for SF6, may lead to double counting of emissions.
If EPA continues with this approach, the Agency should provide guidance
in how to minimize or eliminate that double counting. 

	EEI looks forward to continuing to work with EPA and crafting workable
reporting schemes for SF6.  And we wish to thank you for the opportunity
to provide these oral comments today.

	MR. GUNNING:  Thanks, Dan.  

	At this point, we’ve gone through the list of signed-up speakers and
I’d like to ask additional folks if they would like to make comments
this morning.  Anybody.  Everybody’s here to listen.  That’s good.  

	Okay, so in lieu of that, we are open for comment until noon today. 
What I’d like to do at this point is take a 10 minute break and see if
there are additional folks after that break that are interested in
commenting.  And then we will be here and available through noon today
if there are additional comments that folks would like to provide.  So,
we’ll take a ten-minute break and then we’ll touch back in to see if
there’s more people that want to address.

	[Break.]

	MR. GUNNING:  Okay, everyone.  If I could reengage for a moment.  I
want to check in now to see if there are – I know a couple of people
are walking in and out – additional individuals that would like to
make comments this morning at this point.  No.  Okay.  

	What I’ll do at this time is I am going to be transitioning the
hearing over to Debbie Ottinger.  We will have – we will be here armed
and ready to listen to your comments through approximately noon today.  

	And if at this point moving forward if there are individuals that would
like to make comments, I’d ask that you just please come up and notify
Debbie of your desire to do so and we will open up the mike again for
your thoughts.  So at this time, we’ll break indefinitely until
someone approaches us with additional comments.  And for those of you
here today and before I leave, I just want to thank everybody for
coming. These subparts are really important, we believe, to a full,
robust, successful mandatory reporting rule and program.  And I’d like
to thank you all for the thoughts that you offered today.  And I also
encourage you and emphasize that we have an open door policy, and these
are in many cases, re-proposals.  We do our best to make sure that we
reflect comments and respond to comments diligently to make our rule the
most efficient and effective it possibly can be.  So in the coming
weeks, days, if individuals would like to meet with us to discuss your
perspectives and thoughts further, we welcome that.  We believe that
will make a more effective rule in the end. So I encourage you to
contact me or Debbie or Kirsten or Sally or any of the EPA staff
involved in these rulemakings.  We welcome that and we appreciate that
and it’ll make our jobs easier and more effective eventually.  

	So thank you for those who came this morning.  We will take a pause
now.  And again, to reiterate, if you have additional comments you’d
like to offer, please approach Debbie and we’ll open up the floor
again for additional commenters.  Thank you.

	[Waiting – 9:51 to 11:54.]

	MS. SIBOLD:  Hello.  This Katherine Sibold.  It is 11:54 in the
morning.  We have completed this public hearing for the additional
sources of F-gases.  There have been no persons in the room for roughly
the last two-plus hours, so we are going to go ahead and close this
public hearing at this time. 

	[Whereupon, at 11:55 a.m., the Public Hearing concluded.]

 

 

	OLENDER REPORTING, INC.

	1100 Connecticut Ave., N.W., Suite 810, Washington, D.C. 20036

	Washington:  (202) 898-1108 / Baltimore:  (410) 752-3376

	Toll Free:  (888) 445-3376

		 page \* arabic 1 

