Comment Log Display

To Whom it may concern:

I am writing today with regards to the recent news I was provided
concerning the planned update and requirement that as of January
1st 2023 all AC equipment must comply with the new GWP limits
proposed to reduce greenhouse gas emissions within California by
the year 2030. 

Let me start off by stating that as a life-long resident of
California I am wholeheartedly for the reduction of greenhouse gas
emissions and am in agreement with CARBs goal to improve our health
and environment. 

I operate a small air conditioner rental business for commercial
clients. My company supplies emergency climate control services to
customers throughout California. The equipment we provide is often
used to provide real comfort as well as critical solutions to
thousands in need of cooling in the event that their existing air
conditioning equipment fails or needs maintenance. We supply
equipment to schools as well as hospitals and nursing homes where
children and the elderly might otherwise be left without any
conditioning to their environment and become sick. We supply
equipment to data centers that can fail from heat overload costing
clients and customers untold sums of time and money. We supply
equipment to office spaces and retail locations as well as
restaurants that might otherwise be forced to shut down as the lack
of air conditioning can present a health hazard to customers and
staff. 

My concern is that the timeline provided for this exchange will
place an enormous stress as well as cost on the manufacturers who
supply our air conditioning equipment which will in turn fall upon
us as well as our customers. The price of materials to manufacture
and purchase this equipment has already increased vastly just
within the last year while many of us are still recovering from the
effects of COVID upon our state. 

I am not asking that you reconsider the reduction of greenhouse gas
emissions, only that your board kindly consider providing more time
for manufacturers to update and supply this equipment.  Generally,
the timeline for a redesign is easily 5+ years.  Rushing the
process could result in potential recalls and equipment that fails
to meet previous standards which in turn will place more burden and
cost on the consumers who are the residents of California, to whom
we are aiming to help.  If there is a delay or cease of production
the impact on our business and the people of this state will be
tremendous. 

I do sincerely thank you for your time and consideration.