Comment submitted by Bradford Beauchamp, Stephan Company

See attached letter regarding comments to proposed rule making. While Stepan is in favor of the intent of the rule making, we ask that the EPA accelerate the proposed date to January 1, 2007 for polyurethane foam. The rationale being that viable alternatives exist from manufacturers (systems houses) for each given end use and that these are already being used by other end use customers within the given market segments cited by the EPA (i.e. Sandwich Panels). Therefore making the only reason for systems houses and end users to remain in HCFC22 blown polyurethane foams being one of cost, placing viable environmentally friendly alternatives at a competitive disadvantage.