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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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