Dear
CARB,
It is my
understanding that on June 23, 2022, CARB will be holding a public
meeting to solicit comments on its upcoming 2022 Climate Change
Scoping Plan. While I cannot attend this meeting, I would ask
the board to please consider changing the regulations regarding
consumer product propellants. Currently CARB requires that
propellants used in consumer products meet specific low VOC
criteria. While this is a worthy regulation for limiting
smog, etc., the industry alternative to traditional propellants has
become HFC 152a. This propellant is a particularly potent
greenhouse gas, and when scaled to nationwide use over the next 30
years it will likely result in the equivalent of releasing 5
megatons of CO2 into the atmosphere. We would be better off
simply using CO2 as a propellant.
Please
reconsider and fix this regulation as soon as possible. It
will be an easy fix with a huge effect.
Thanks for
your consideration,
Jeffrey
Beeman
(retired)
scientist
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