Comment submitted by FluoroFusion Specialty Chemicals, Inc.

Summary: FluoroFusion Specialty Chemicals, Inc. supports the EPA's reconsideration of the Technology Transitions Rule, arguing that circular refrigerant solutions like their patented R-4106A provide supply chain resilience and cost benefits. They request that the EPA adopt a lifecycle GWP methodology for reclaimed components and consider TFA formation rates as an evaluation criterion, while also highlighting potential anticompetitive practices in current industry evaluation programs.