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This regulation is a small step in the correct direction.  The one
component missing from this and all other refrigerant regulations
is enforcement. Based upon my observations as someone intimately
involve with refrigerant management on a daily basis, the vast
majority of appliance owners and contractors do not take the
existing, or this proposed regulation too seriously as they know
that the Feds, and local government agencies, do not actively audit
records, investigate reports of purposeful venting, or for all
intents and purposes, enforce the law.

The phasing of the regulation, based upon the size of the
refrigerant charge, does soften any financial blow and allow
businesses time to plan for changes in their operations. This is a
good and generous allowance.

One question I have relates to how the fee revenue is to be spent.
 I would propose that it be used to hire audits/investigators for
enforcement purposes, which would add some sorely needed teeth to
the regulation.

Thanks,

Tim Frazee
Rapid Recovery