Comment Log Display

It comes as no surprise that California is forging ahead to
regulate F-gases after the EPA's SNAP standards were foiled by
federal court, and the Trump administration has squelched progress
on this vital issue. However, the new CARB proposal for reducing
the GHG emissions from non-residential refrigeration systems must
go further in order to accomplish a significant reduction. 

According to its own report, CARB's Preferred Alternative will
reduce HFC emissions from refrigeration and AC by forty to fifty
percent by 2045. This leaves quite a gap to be accomplished in the
next five years, and it must be accomplished to achieve
California's goal of carbon neutrality by 2045. 

The cost-benefit ratio used by CARB drastically understates the
cost of continued emissions from HFCs. Using 100 year GWP values
instead of 20 year GWP values disguises and diminishes the nature
of HFC emissions, and the impact they will have during the next
thirty years--which are absolutely crucial. Furthermore, CARB's
staff report notes that the social costs of GHG emissions were
based on CO2. I cannot understand the rationale for this,
considering how much more potent HFCs are at trapping heat. Indeed,
it would be hard to overstate the difference--yes, the effect of
HFCs occur over a much shorter term than CO2, but again, the short
term is crucial.

Page 130 of the Staff Report and page 101 of the Standardized
Regulatory Impact Assessment describe Alternative 1, which would
far outstrip the impact of CARB's Preferred Alternative. Its
standard is a GWP of 10 or less, and that can only be accomplished
by converting to natural refrigerants such as propane, carbon
dioxide or ammonia. Considering that it must be done at some point
if California is to achieve carbon neutrality by 2045, delaying is
counter-productive.  

The natural refrigerants do require bigger and more expensive
upgrades of equipment. A combination of technical help and
subsidies could facilitate the conversion. Taxing the emissions of
large systems could incentivize the large operations. 

If there must be a two-tiered approach, why not require big
operations to switch to natural refrigerants by 2030 but allow
smaller operations more time? Smaller operations tend to run
systems that use less than 50 lbs anyway. These smaller systems
should convert as soon as possible, but making a priority of the
larger systems makes sense. 

HFOs and other blends have a GWP of 1400. They are an incremental
improvement that simply do not make the grade. Encouraging
operators to use them instead of truly low-GWP substances furnishes
no incentive for the industry to research, refine, and move
aggressively towards natural refrigerants.  Four years after the
Kigali Amendment, Trader Joe, Wal-Mart, and Costco--big
corporations with lots of money--all continue to emit high amounts
of HFCs. Apparently, the capital costs of replacing their
refrigeration equipment--an estimated 1% of total costs--is enough
to discourage these large corporations even though the financial
advantages of natural refrigerants more than repay the investment.


Many scientific circles consider HFCs to be the #1 threat as our
world heats up and people increasingly need cooling substances for
air and food. It would be difficult to overstate the importance of
moving aggressively towards low GWP solutions. 


Thank you.
Martha Walden