Great Comment Supporting EPA Regulations

Having read through the comments submitted to the EPA thus far, I found this comment to be succinct and to the point. I am looking forward to seeing more comments supporting the current regulations.

To all it may concern,

While Title VI of the Clean Air Act was implemented with a focus on addressing ozone depletion, the general provisions (Title III) of the Clean Air Act states that an "air pollutant" includes chemicals [7602(g)] and that the Clean Air Act considers effects on welfare to include climate [7602(h)].

HFCs are chemicals that have been proven to cause unnatural effects to the climate if emitted into ambient air.

Section 608(a) and (b) [7671g] do not explicitly state that the regulations should or should not extend to substitute substances, however section (c) does explicitly state that it shall be unlawful to knowingly vent or release any substitute substance. Therefore, it seems rational and consistent that the EPA should extend parts (a) and (b) to "(A) reduce the use and emission of such substances to the lowest achievable level, and (B) maximize the recapture and recycling of such substances." This would also be in alignment with the mission of the EPA to protect human health and the environment.

To interpret This difference between section 608(a) and 608(c) ... as a manifestation of Congressional intent to distinguish between the categories of substances covered in these respective provisions and to only convey authority to address substitute refrigerants under 608(c), not 608(a) seems a hypocritical argument, clearly not stated in the Section 608 text, when the reasons for potentially receding the legislation is due to specific wording, or the lack of. Further, to conclude that if this was the intent in 1993 it should prevent the progress of legislation in 2018, 25 years later, demonstrates a lack of responsibility to keep legislation up to date with evolving situation, technology and general human understanding of the physical world, ultimately making legislation fundamentally redundant.

Addressing the "taking comment whether the agency should rescind the entire extension of the sub-part F requirements to non-exempt substitutes", then this is a proposal to changing an existing Law, rather than a proposal to change the interpretation of it. If changing the law is in question, then the law should be changed to clearly empower the EPA to make regulations as stewards of human health and the environment, and to formally extend Section 608 of the Clean Air Act to include substitute substances, or define an additional law to achieve the same effect without undue delay.

The proposed rule states that the new ruling would save a burden close to $40 million, for the U.S. economy. The U.S. economy is currently sized at over $20 trillion. Applying this burden solely to the Food Retail market (because this is a focal area of the EPA with Greenchill), this total represents under 0.005% of 2018 revenue of this single industry. This equates to a little over $1,100 per store ($789 Billion; 35,930 stores; see: https://www.chainstoreguide.com/csgonline/industryinformation/supermarket.pdf). The financial benefits of this ruling are minimal and can hardly be considered as justification for this action. The confusion and extra time spent applying regulations to some equipment and not others is likely to exceed this value for the food retail sector, let alone the certified technician, manufacture, equipment suppliers and all supporting industries. The burden that is claimed to be relieved will actually increase the burden on industry as individual businesses will now need to identify, manage and enforce a standard themselves. The business justification in this proposal is simplistic, demonstrates a lack of understanding of industry in practice and a poor allocation of tax payer resources to deliver value to US business and the public.

I kindly request the EPA drop this proposal to rescind the currently expected 2019 extension and to strengthen Section 608 of the Clean Air Act if it is deemed necessary to empower the EPA to operate responsibly and effectively to protect human health, the environment and support US business.