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This is a regulation especially needed for large stationary
commercial refrigeration plants, like supermarket freezers and
refrigerated sections.  Today, it is too easy, probably because of
cost pressures, to continue to use leaky, poorly designed and/or
maintained refregirant systems.  29% of commercial refregiration
systems in the South Coast Air Quality Management District leak
yearly and lose on average 65% of their charge annually.  This is a
very high level of potent ghg and ozone depleting gases going into
the atmosphere every year just in the South Coast Air Quality
Management District.  If this same level of refregirant leakage
holds across the state, it would represent a severe environmental
and health problem that must be addressed as soon as possible.  The
U.S. EPA's GreenChill Program has proven over several years that it
cost markets and other stores much less to operate a clean and
efficient system than a polluting one, even under the current cost
pressures.  I think that something that will go along way in
winning support for the new refrigerant systems is an incentive
program similar to some now in use by CalEPA and USEPA where a
portion of the cost of buying and installing the new systems is
paid either by the state, the federal government or some from each
so small family owned markets don't have the full costs to pay for
out of pocket.  Thank you.  Michael E. Bailey.