Indeed, most cold storage facilities in the U.S. are large industrial facilities averaging over 100,000 cubic meters in size, said Sara Stickler, president and CEO of the Global Cold Chain Alliance (GCCA), in a letter to EPA. “Losing access to low-GWP HFCs and blends currently used in cold storage systems would be highly disruptive. “Current natural refrigeration systems can easily meet the phase-down schedule proposed by EPA, particularly for cold storage applications where they are already in active, majority, and expanding use,” said Schrift. “The cold storage sector does not require a relaxation of the 150 GWP limit. TT RuleThe comments weren’t limited to cold storage refrigerants — several stakeholders weighed in on the TT rule as a whole.