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Thank you for taking a moment to consider my concerns regarding the
"Replacement of high global warming potential (GWP) gases used in
fire protection systems with alternate chemical(s)."  I feel the
ARB has only heard one side of this issue, and that the overall
value of HFC's for fire suppression are being greatly understated.
 

HFC's are firstly the best performing clean fire suppression
products available on the market today.  Their transition to vapor
for effective three dimensional fire suppression is unmatched by
any other products on the market today.  Fluids and inert agents
are not as effective as fire fighting products for delicate
electronics and critical processes because they either take longer
to contain a fire event, or they do not "flash to a vapor" with the
necessary certainty that is required for a clean fire suppression
product.  Performance is measured in speed of extinguishment and
the ability to penetrate a fire as a three dimensional product. 
HFC's are easily the most effective from the performance
standpoint, and we have more than 13 years of experience to prove
this.

Secondly, HFC's in fire suppression are inherently a non-emissive
product.  They are released when a fire event requires their use,
which is rare.  HFC's are initially filled at UL Listed facilities
and they remain intact in most cases for a lifetime.  They are
present to protect critical assets, equipment and processes, and
are used because of their excellent performance and life safety
attributes.  To remove them from use for fire suppression on the
hope of lessening GHG emissions is like saying you would reduce
the amount of water in the ocean by taking out a thimble full of
water.  This action will not impact the desirable goal of reducing
GHG emissions.

On the contrary, eliminating HFC's will result in fewer systems
being installed to protect valuable equipment and processes, and
will also result in higher costs for individuals and organizations
that do install these types of systems (to reduce or minimize the
risk of a catastrophic fire event).

Other organizations and entities have already trumpeted the
positive steps taken by member orgaiznizations within the fire
suppression industry to limit accidental discharges, and to
demonstrate outstanding product stewardship as it relates to
potential environmental impact.  I will therefore let their
comments speak for themselves and close with one final, critical
point.

A well known chemical manufacturer stands to reap great commercial
gain if HFC's are eliminated.  The product that this manufacturer
espouses to be the "great environmental answer" for fire
suppression has a very limited history in this industry, and there
is little data available to show its effectiveness as a fire
suppression alternative.  You cannot minimize the effect this
decision will have on the industry as a whole when you consider
that there is only one manufacturer of this product, and by the
elimination of HFC's, will allow this manufacturer to reap
excessive profits due to a lack of competition.  We are already
seeing this in the California marketplace with the publishing of
the April 20th document, and it will only get worse in the coming
weeks if this action is pursued.  

HFC's are the best performing fire suppression products on the
market; they are non-emissive and provide no measurable impact to
the atmosphere; they have an unparallel tract record as an
effective fire fighting product that is essential for critical
services and industries; they contribute greatly to a free market
economy because they are manufactured by more than one
manufacturer; and they are an excellent example of how an overall
industry has taken measures (apart from legislation) to promote
responsible product stewardship.  

By continuing to pursue this item the ARB will only be penalizing
California businesses and organizations, and will be allowing a
manufacturer with patent rights to the only other viable product
to reap excessive gain.