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Dear Administrator Regan
Administrator Michael Regan
U.S. Environmental Protection Agency
1301 Constitution Avenue, NW
Washington, DC 20004
 
 
cc:  	Ms. Cindy Newberg
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        	Mr. Chris Grundler
        	Mr. Joseph Goffman
Letter of Support for the EIA Petition for Technology Transitions under AIM Act Consistent with Restoring U.S. Climate Ambition
Dear Administrator Regan,
350NYC submits this letter of support for the petition on technology transitions under subsection (i) of the American Innovation and Manufacturing Act of 2020 (AIM Act) submitted by the Environmental Investigation Agency (EIA) and its co-petitioners. 
Hydrofluorocarbons (HFCs) are highly potent greenhouse gases. It is estimated that 95% of the HFCs produced end up in the atmosphere. Two interventions mandated by the AIM Act should be enforced immediately and could reduce the global warming potential of refrigerants significantly by 2035. Firstly, the AIM Act will enforce a transition to low GWP refrigerants and 350NYC urge Administrator Regan and the EPA to adopt and specify the same HFC emission targets proposed in California SB1383, http://www.leginfo.ca.gov/pub/15-16/bill/sen/sb_1351-1400/sb_1383_bill_20160919_chaptered.pdf. 
Secondly, the AIM Act also gives the EPA the authority to enforce the service management of large refrigerant systems and we urge the agency to include the following regulations.
a. Conduct state-level inventories to determine quantities and sectoral breakdown of Ozone Depleting Substances, ODS, and HFC refrigerant banks. 
b. Require uniform refrigerant management and training practices for HVAC technicians in the state for leak detection and repair, which can be verified in the central database. 
c. Extended Producer Responsibility Schemes and Other Incentives States could also consider imposing a take back obligation requiring producers and distributors to `take back' refrigerants from contractors at little or no cost. Examples of these programs are in place in France and Germany. 
d. End-of-Life: Recovery, Reclamation, and Destruction There are a number of other potential policies aimed at increasing rates of recovery, reclamation, and destruction of used refrigerant, recommended in the Environmental Investigation Agency (EIA) report,  https://eia-global.org/reports/20190214-search-reuse-destroy.
 HFC emissions from supermarkets and other commercial enterprises account for over 50% of HFC emissions in the United States. Although there are a few supermarket chains, such as ALDI's, which have committed to transitioning to low GWP refrigerants, the majority of large chains has been slow to invest in this important transition. Furthermore, management of large supermarket systems is poor, resulting in excessive loss due to leaks. Disposal of equipment at end-of -life is not monitored stringently by local municipalities. A national program that can only be only be monitored by the EPA and the regional offices is essential to the success of this goal.

Thank you for considering our input. 
Margaret Perkins 
Steering Committee 350NYC
c/- 180 West End Ave, Apt 27F
New York, NY 10023
