Comment Log Display

Refrigerants in commercial stationary applications (chiefly grocery
stores) pose a major potential global warming risk. I am happy that
the CARB is proposing ways to reduce that risk.

I would prefer that CARB adopt Alternative 1, but with
modifications that would increase the number of stores able to
retrofit their refrigeration systems (through incentives, technical
assistance, and training) and would move the industry toward use of
natural refrigerants. These refrigerants will result in far less
risk to our climate; we will undoubtedly move toward them at some
point, and the sooner the better both for our climate and for the
business models of grocery stores, which often have an annual
profit margin of one percent or less. 

Particularly important as a modification to Alternative i would be
assistance in the form of financial incentive to grocers in areas
of "food desert" conditions, typically low-income neighborhoods.
Obviously these stores provide a much needed resource for their
local areas and often run at a somewhat lower margin than stores in
areas more economically blessed. I recognize that this would likely
require legislative action to enact, and that should be a
recommendation of CARB. 

Thank you for the opportunity to provide these comments.