Document bOvRV69Jpgowpb6yJK423N26k

To: scheduling[scheduling@epa.gov]; Hupp, Sydney[hupp.sydney@epa.gov] Cc: Kevin Fay[fay@alliancepolicy.org] From: Stephen Van Maren Sent: Wed 5/17/2017 2:28:19 PM Subject: Administrator Meeting Request Alliance Letter to EPA Administrator APR2017.pdf Dear Ms. Hupp, I hope this finds you well. We would like to follow up on our attached letter submitted to the Administrator on April 14. We are now looking into an opportunity to bring together a delegation of CEOs from our member companies to meet with the Administrator for further discussion on the topics contained in the letter. Please advise as to how we should go about setting up such a meeting. Thank you in advance for your help. Respectfully, Stephen Van Maren Director Alliancefor Responsible Atmospheric Policy 2111 Wilson Blvd., 8th Floor Arlington, VA 22201 Tel: (703) 516-4118 Fax: (703) 243-2874 Email: vanmaren@alliancepolicy. org Website: ww. alliancepolicy, org Follow us on Twitter: @AtmosPolicy --------- Forwarded message---------- From: Stephen Van Maren <vanmaren@alliancepolicy.org> Date: Fri, Apr 14, 2017 at 12:44 PM Subject: Alliance Views on CAA Title VI and the Montreal Protocol To Cc: hillary.lassiter@mail.house.gov, michael.mets@mail.house.gov, I < H ri i mli mi e'jn " j', iil'jmmiA >r r am ,r w, dim I il_i <@) ii hi j p.ili i < d i a ne.gov, 1 mb jjjd j ,t < irto m i P , 11 11 all i >im *i iv o , Kevin Fay 17cv1906 Sierra Club v. EPA ED_001523B_00005461-00001 Administrator Pruitt, Please accept the attached views from the Alliance for Responsible Atmospheric Policy on budgetary considerations regarding Title VI of the Clean Air Act and the Montreal Protocol. Thank you. Respectfully, Stephen Van Maren Director Alliancefor Responsible Atmospheric Policy 2111 Wilson Blvd., 8th Floor Arlington, VA 22201 Tel: (703) 516-4118 Fax: Email: vanmaren@alliancepolicy. org Website: ww. alliancepolicy, org Follow us on Twitter: @AtmosPolicy 17cv1906 Sierra Club v. EPA ED_001523B_00005461-00002 The Alliance_____ for Responsible Atmospheric Policy April 14, 2017 The Honorable Scott Pruitt Administrator US Environmental Protection Agency Office of the Administrator, Mail Code 1101A 1200 Pennsylvania Avenue, NW Washington, DC 20460 Administrator Pruitt: On behalf of the members of the Alliance for Responsible Atmospheric Policy (Alliance), I congratulate you on your confirmation as US EPA Administrator. We wish you success in your role as the EPA Administrator and we look forward to working with you and your staff in the coming months and years. Organized in 1980, the Alliance is the leading voice of manufacturers, businesses and trade associations who make or use fluorinated gases for the global market. The US fluorocarbon using and producing industries contribute more than $158 billion annually in goods and services to the US economy and provide employment to more than 700,000 individuals with an industry-wide payroll of more than $32 billion. Alliance member companies are leading the development of safe, efficient, nextgeneration technologies and applications that benefit the US economy and consumers. A list of members is attached. I am writing in support ofEPA's activities to implement US obligations under the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), its enabling framework, the Vienna Convention for the Protection of the Ozone Layer and Title VI of the Clean Air Act Amendments of 1990. For more than three decades, industry has worked with EPA to incorporate US competitiveness into vital efforts to protect the stratospheric ozone layer. It is critical to continue and fund this work. As you are finalizing your FY 2018 budget and program proposals, we ask that you support the continued effective implementation of the global Montreal Protocol, including the technology assistance to developing countries directed through the Protocol's Multilateral Fund. For several decades, it has been a priority of the US to join with other developed countries to provide funding for the developing country transition away from ozone-depleting compounds and into beneficial technologies, many of which are developed and exported by Alliance member companies. The Multilateral Fund has been both vital and successful in assisting developing countries to make the necessary transition toward beneficial technologies that incorporate US innovation. In addition, Senate ratification of the Kigali Amendment is a key issue to be addressed when timing is appropriate. This will demonstrate US leadership in driving a timely transition. Without leadership from the US government and industry, other countries may fill the void and promote the introduction of 2111 WILSON BOULEVARD, 8TH FLOOR, ARLINGTON, VIRGINIA, USA 22201 Phone: +1-703-243-0344 Fax: +1-703-243-2874 Web: www.alliancepolicy.org 17cv1906 Sierra Club v. EPA ED_001523B_00005462-00001 alternative technologies that benefit their own exporting industries, and are not as safe and energy efficient. The global effort to protect the Earth's ozone layer by phasing out chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) is one of the signature environmental policy successes of the last 40 years, first initiated by President Ronald Reagan and his administration. Every administration since has supported the Montreal Protocol and the amendments associated with it. At the foundation of the Protocol's success is a long history of effective collaboration among industry, government officials and the environmental community. While it is rare for domestic regulatory initiatives toinclude economic issues as factors in their deliberative process, they are an established component under the Montreal Protocol, at both the global and domestic policy levels. Over the last three decades, our collaborative efforts have enabled US industry to lead the global technology transition from CFCs to HCFCs to hydrofluorocarbons (HFCs). Policies to implement the Montreal Protocol and Title VI of the Clean Air Act amendments have led to industry's invention of new compounds and technologies that prevent further atmospheric buildup of ozone-depleting compounds while allowing innovative manufacturers to provide high-performance products that are safe, effective and affordable for air-conditioning, refrigeration, fire suppression, foam insulation, solvents, and medical devices. US industry has been the leader in these sectors, which over the last several decades have been significant contributors to a positive balance of trade, valuable jobs for the American workforce and a high quality of life for American consumers. A more comprehensive list of the benefits from advances in those sectors is attached. Especially in the refrigeration, air-conditioning, and foam insulation sectors, there has been a concurrent transition to higher-efficiency equipment and products, leading to positive impacts for the US energy landscape and American consumers. These technologies have been at the cutting edge of modem industrial development, and identified by many emerging economies as critical to their economic growth In fact, US industry sees immense opportunities in these emerging economies for the export and dissemination of new US technology. Although the transition away from ozone-depleting substance is for the most part complete in developed economies, it is only in its early stages in emerging economies. This is of particular concern with regards to the larger emerging economies, including China and India, where the scale of the pending transitbn has significant technological, economic and environmental implications Now that the transition into HFCs is advanced in developed economies, there is global pressure to move once more, this time into new fluorinated and not-in-kind technologies due to concern in many markets for the potential growth in greenhouse gas emissions from HFCs. This latest effort was the subject ofthe Kigali Amendment adopted by the parties to the Montreal Protocol last October with significant US and global industry support. The amendment fulfills the need of businesses for a sensible, marketbased approach to introducing HFC-alternative technologies. We recognize that the effort underway to right-size the federal budget is fully in line with the campaign commitment of the new administration to make the US government more efficient. As it relates to the EPA budget, the funds utilized for participation in and implementation of the Montreal Protocol have very efficiently met their environmental objective, while helping to sustain US technological leadership in markets worldwide. We desire efficient and cost-effective implementation of government regulatory initiatives that allows industry to have a voice in the process. Much work remains to be done, particularly with regard to the continued approval of new technologies, the improvement of refrigerant leak-reduction programs and, 2 17cv1906 Sierra Club v. EPA ED_001523B_00005462-00002 consistent with domestic regulatory requirements, implementation of the global phasedown of existing materials and applications under the Montreal Protocol, all while ensuring continued US industrial leadership and success. We are also prepared to make suggestions on ways to improve the administration of the programs at the domestic and international level to achieve the desired efficiencies. We appreciate you taking the time to consider our views, and we hope to meet with you in the near future to discuss these important matters. Thank you. Respectfully, Kevin Fay Executive Director Enclosure 1: Alliance Members List Enclosure 2: Societal Benefits CC: Sen. Mike Enzi, Chairman of the Senate Budget Committee Sen. Bernie Sanders, Ranking Member of the Senate Budget Committee Rep. Diane Black, Chairman of the House Budget Committee Rep. Todd Rokita, Ranking Member of the House Budget Committee Sen. Thad Cochran, Chairman of the Senate Appropriations Committee Sen. Patrick Leahy, Ranking Member of the Senate Appropriations Committee Rep. Rodney Frelinghuysen, Chairman of the House Appropriations Committee Rep. Nita Lowey, Ranking Member of the House Appropriations Committee Sen. John Barrasso, Chairman of the Senate Environment and Public Works Committee Sen. Tom Carper, Ranking Member of the Senate Environment and Public Works Committee Rep. John Shimkus, Chairman of the House Environment and Commerce Committee Rep. Paul Tonko, Ranking Member of the House Environment and Commerce Committee 17cv1906 Sierra Club v. EPA ED_001523B_00005462-00003 The Alliance_____ for Responsible Atmospheric Policy Members AGC Chemicals Americas A-Gas/RemTec Air-Conditioning, Heating & Refrigeration Institute Airgas American Pacific Corp. Arkema Association of Home Appliance Manufacturers Auto Care Association Bard Manufacturing Company BASF Brooks Automation, Inc. Cap & Seal Company Carrier Corporation Center for the Polyurethanes Industry Chemours Combs Gas Consolidated Refrigerant Solutions Daikin America Daikin Applied Danfoss Dynatemp International Emerson Climate Technologies E.V. Dunbar Co. Falcon Safety Products FP International Golden Refrigerant Halon Alternatives Research Corporation Heating, Air-conditioning & Refrigeration Distributors International Honeywell Hudson Technologies Hussmann ICOR International Ingersoll-Rand International Pharmaceutical Aerosol Consortium Johnson Controls Lennox International Mexichem Midwest Refrigerants Mitsubishi Electric National Refrigerants Owens Coming Specialty & Foam Products Center Rheem Manufacturing Company Ritchie Engineering Solvay Spectrum Brands Sub-Zero The Dow Chemical Company Whirlpool Corporation Worthington Cylinder 2111 WILSON BOULEVARD, 8TH FLOOR, ARLINGTON, VIRGINIA, USA 22201 Phone: +1-703-243-0344 Fax: +1-703-243-2874 Web: www.alliancepolicy.org 17cv1906 Sierra Club v. EPA ED_001523B_00005462-00004 The Alliance_____ for Responsible Atmospheric Policy Societal Benefits of Alliance Member Products The role of Alliance members' products in our society goes well beyond their contribution to global and regional economies from a manufacturing and employment perspective. They are sold into a variety of industrial markets and incorporated into many products, providing a tremendous value to downstream industries and consumers. Listed below are some ways in which Alliance members' products and industries have provided significant societal benefits: Air-conditioning has played a key role in increasing worker productivity, enhancing health and reducing heat-related illness over the past half-century by keeping individuals comfortable and healthy in hot climates. In fact, MIT researchers have identified a direct correlation between the introduction of air-conditioning in the 20th century and a greater than 80 percent reduction in deaths due to exposure to very high temperatures (Barreca, Clay, Deschenes, Greenstone and Shapiro, 2012). Metered dose inhalers (MDIs) utilizing fluorinated compounds allow for the safe, effective delivery of critical medicines for the treatment of asthma and chronic obstructive pulmonary disease (COPD), which currently do not have a cure. Refrigeration units preserve and protect food for societies around the world. The growth of this technology will enhance the life of products and ensure that the food is reaching a larger percentage of the population. Blowing agents, which provide for increased thermal insulation in foam products, are helping to increase energy efficiency. Mobile air conditioning has become a necessity for passengers' comfort and safety in some one billion vehicles worldwide. The transport of food, drugs, and other products, which require climate control, is possible due to the use of refrigerants. Climate control assures that goods arrive without deterioration and do not endanger public health. The safe application of many materials is enabled through the use of aerosols, which are efficient and easy to use. Our industries provide solutions for novel applications in the solvent and fire extinguisher markets where safety is of critical importance. S Our industries have available technologies for the safe, clean destruction or conversion of fluorinated compounds that have reached the end of their life. 2111 WILSON BOULEVARD, 8TH FLOOR, ARLINGTON, VIRGINIA, USA 22201 Phone: +1-703-243-0344 Fax: +1-703-243-2874 Web: www.alliancepolicy.org 17cv1906 Sierra Club v. EPA ED_001523B_00005462-00005