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Comment 51 for Comments on initial draft report of the AB 398 Compliance Offsets Protocol Task Force (ab398offsetreport-ws) - 2nd Workshop.


First Name: Kristen
Last Name: Taddonio
Email Address: ktaddonio@igsd.org
Affiliation:

Subject: Comment from IGSD
Comment:
IGSD STRONGLY SUPPORTS and is GLAD TO SEE the proposed
Modification(s) to Ozone Depleting Substances (ODS) protocol adding
R-22, R-134a, R-125, R-32, and R-143a as eligible.

We also strongly suggest that the protocol be clarified that
avoided emissions--such as avoided annual/operational R-22 leakage
from supermarkets not yet required by regulation to switch--be
eligible under the protocol.

Our read of the existing protocol suggests that this might already
be the case, since the protocol includes "reductions in "Emissions
of ODS from leaks and servicing through continued operation of
equipment."  However, additional clarity on that point could be
very helpful.

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Date and Time Comment Was Submitted: 2021-02-28 09:44:34



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