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Comment 37 for Draft Proposed First Update to the Climate Change Scoping Plan (proposed-sp-ws) - 1st Workshop.
First Name: Alexandra
Last Name: Maratou
Email Address: alexandra.maratou@shecco.com
Affiliation: Deputy Public Affairs Manager, shecco
Subject: Comments on Proposed First Update to Climate Change Scoping Plan -Addressing HFCs
Comment:
shecco welcomes California’s Proposed First Update to the Climate Change Scoping Plan and the consideration of measures to limit emissions of short lived climate pollutants (SLCPs), and in particular hydrofluorcarbons (HFCs), the fastest growing sector of greenhouse gas (GHG) emissions in California. We also commend California Air Resources Board for envisioning the drawing up in 2015 of a detailed strategy to address short-lived climate pollutants including HFCs. Additional measures on HFCs have the potential to position California among the world leading regions for innovation in and implementation of climate friendly technology with HFC-free natural refrigerants. A package of measures would be necessary for effectively reducing HFC emissions in California, including: • Minimising refrigerant leakage from HFC systems (as in California’s existing Refrigerant Management Program) • Low-GWP use requirements that would ensure that high-GWP HFC-based equipment is no longer placed on the market in sectors where they are no longer necessary (where alternatives are commercially available) • A phase-down (or phase-out) of HFCs with GWP ≥ 150 • A fee on high-GWP HFCs (GWP ≥ 150) that would among other things reduce the chances of overallocation of HFC quotas and windfall profits under an HFC phase down • Measures Incentivising the reclamation and recycling of HFCs (and ODSs) In the attached briefing we provide comments in relation to the specific type of measures for addressing HFCs and promoting the use of HFC-free technology, drawing examples and best practices from other world regions with similar measures already in place. In addition we highlight the links and synergies between action on HFCs and other cross-cutting issues in the draft update (green buildings, public procurement, support for households and businesses).
Attachment: www.arb.ca.gov/lists/com-attach/44-proposed-sp-ws-AnEAblA0VGQHYlU6.pdf
Original File Name: shecco comments to California’s Proposed First Update to the Climate Change Scoping Plan_April 2014.pdf
Date and Time Comment Was Submitted: 2014-04-28 09:54:06
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