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

--

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