Post on 08-Jan-2016
description
Negative Impacts of
EPA’s SNAP Regulation
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Who is NAFEM ?
The North American Association of
Food Equipment Manufacturers Represents:
550 foodservice equipment & supplies manufacturers
220 members w/annual revenues of $5M or less;
78 members w/annual revenues of $5-10M;
89 members w/annual revenues of $25-10M.
NAFEM Members Manufacture:
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NAFEM Members Manufacture:
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SNAP Basics
The Significant New Alternatives Policy (SNAP) Program is authorized by Section 612(c) of the Clean Air Act.
SNAP is designed to protect the stratospheric ozone layer by phasing out ozone-depleting chemicals.
To meet this goal the EPA publishes and updates lists of acceptable and unacceptable substitutes for class I or class II ozone-depleting substances.
Status of substances is determined by EPA’s determination a less harmful alternative is available.
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Industries Targeted by SNAP
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SNAP Basics:Proposed Alternative Refrigerants
Equipment Considered Proposed Additions Previously approved 12/20/11 76 FR 78832
Retail food refrigeration (new stand-alone only)
* doesn’t apply to large CRE systems such as multiplex direct expansion systems, WICF due to charge limits
Isobutane (R-600a)Limit 150 gr (5.29 oz.)R441A
Propane (R-290)
Very low temperature refrigeration and non-mechanical heat transfer (new stand-alone only)
Ethane (R-170)Limit 150 gr (5.29 oz.) multi systems
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Retail food refrigeration(condensing units and supermarket systems)(new)(condensing units and supermarketsystems)(retrofit)*
No new proposed additions --
Vending machines (new)
Isobutane (R-600a), Propane (R-290)Limit 150 gr (5.29 oz.)R441A
CO2 (R-744)
Household refrigerators and freezers (new only)
Propane (R-290)Limit 57gr (2.01 oz.)
Isobutane (R-600a)R-441
Residential and light commercial AC and heat pumps. (new)
Propane (R-290)Difluoromethane (HFC-32, R-32)R-441Limits vary-see table 3-6 in NPRM7
Issues with Proposed Alternative Refrigerants
Not “Drop-In” Replacements
Flammable
High Pressure
Unavailable in US Market
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Refrigerant Evaluation Factors
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SNAP Blowing Agent Issues
What is the EPA is specifically delisting? – R134A
What alternatives are Available?– Water based & Cyclopentane
Why the alternatives don’t work?– Foam Formation/Filling Issues
– Decreased Thermal Resistance Leads to Increased Heat Loss
Why a supplier switch would be necessary? – Suppliers are choosing one substitute over another
Costly Extension to Time it Takes to Manufacture Each Product & Sales Per Year
May Impact Foodservice Heating Equipment
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Executive Branch Over Regulation
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2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017-2018
DOE Final Rule on
ACIM Test Procedure
EPACTEnacted
DOE Final Rule on ARI &
ASHRAE Energy Use Calculation
Ice Maker ECS
Effective Date*est*
DOE Test Procedure NOPR Ice
Makers
Ice Maker ECS
NOPR
DOE Final Rule on Ice Maker ECS
EPA SNAP Stakeholder
Meetings
DOE Test Procedure Final Rule
Comm. Refrig.
DOE ECS CRE
WIC/FDates
DOE ECS Ice Cream
Freezers NOPR
DOE Ice Maker
Final Rule
DOE ECS Ice Cream Freezers Final Rule
DOE NOPR ECS
Vending Machines
DOE Final Rule
Vending Machine Effective
Date
EPA V 3.0 Energy Star
Compliance Date
DOE & EPA Regulations
EPA has announced the review of hot food holding cabinet ratings & is exploring blast chill freezers as potential products to add to the program.
Executive Branch Over Regulation
DOE’s Automatic Commercial Ice Makers Energy Conservation Standards Rulemaking, Docket No. EERE-2010-BT-STD-0037
DOE’s Commercial Refrigeration Equipment Energy Conservation Standards Rulemaking, Docket No. EERE-2010-BT-STD-003
DOE’s Walk-in Coolers and Walk-in Freezers Energy Conservation Standards Rulemaking, Docket No. EERE-2008-BT-STD-0015
EPA’s Protection of Stratospheric Ozone: Listing of Substitutes for Refrigeration and Air Conditioning and Revision of the Venting Prohibition for Certain Refrigerant Substitutes, Docket No. EPA-HQ-OAR-2013-0748-0001
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Markets SNAP will Impact
Restaurants/Chains
(990,000 in the US)
Corporate Facilities
Correctional Facilities
Health Care
Lodging & Casinos
Schools
Science, Floral, etc.
Supermarkets
Mass Transportation
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SNAP Unintended Consequences
• Marketplace Variety Reduction
• Unknown User & Operator Safety & Health Risks
• Costly Infrastructure Changes to Plants
• Trapped Inventory Through Supply Chain
• Gives Advantage to Foreign Companies Importing Products
• Lab Testing Shortages Causes Noncompliance
• Passes Direct Costs to Customers
• Limits Product Innovation
• Increased Insurance, Placement, & Servicing Costs for
Customers
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Stakeholder Impacts:Small Business Questions
• Are your costs “as-incurred”?
• Do you have limited or uncertain financing options?
• How much will this raise your insurance premiums?
• What training will be required and how will you pay for it?
• Have your 2015 budgets and capital requests been made?
• Do your local building and fire codes and regulations support flammable refrigerants?
• Can your current facility run concurrent operations while transitioning?
• Can small companies compete (from a technical resource pool standpoint) with the salary and benefits offered to develop these products?
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Request to EPA
Extend the compliance deadline:
– To prevent dramatic and sudden price increases.
– To allow time to ensure product lines are safe.
– To allow time for product testing.
– To allow time for training.
– To allow time for components & refrigerants to become
available in the US market.
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Coalition Action: Next Steps
Letters Requesting Extension from Hill
Committee Outreach: 2014 Hearings & Legislation
Develop Coalition Materials
Weekly Meeting/Membership Outreach
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SNAP Coalition
Thank you for taking time to learn about SNAP and how it will impact each of your industries.
NAFEM looks forward to working with you as a voice demanding common sense in the
regulatory process.
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Contact:Annie McCarthyNAFEM Government Relations202.714.6162amccarthy@smithbucklin.com