The primary question being asked in the proposed rule, Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes, is whether or not the EPA has the authority to regulate anything beyond ozone-depleting substances (ODS).
source https://www.achrnews.com/articles/140153-the-epas-call-for-comments-stirs-up-the-hvacr-industry
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