Comment Log Display

These comments are related to the types of projects that should be
prioritized under Program Concentration #2: Promoting Sustainable
Energy Infrastructure 

The draft mitigation program states that ‘[p]rojects in this sphere
would sponsor or otherwise promote enhanced energy-efficiency
measures ... especially in the transportation, commercial, and
residential sectors. 

One of the quickest and most effective ways to generate energy
efficiency benefits in the commercial sector is through refrigerant
retrofits of existing high GWP refrigerant systems to a lower GWP
HFO refrigerant. A refrigeration system that uses an HFO blend
refrigerant is about 10% less energy intensive than a system that
uses a high GWP HFC refrigerant gas.

According to the Energy Star Program, an average supermarket uses
approximately 2,346,000 kilowatt hours of electricity per year. 
Approximately half of that consumption is due to the store’s
refrigeration system. Therefore, a 10% energy efficiency
improvement in that system translates into a savings of almost
120,000 kwh per store, per year. 

In addition to an expected 10% energy efficiency gain that would be
achieved by converting a supermarket refrigeration system to use a
more efficient refrigerant, each of these projects also generates
an immediate greenhouse gas benefit by lowering the direct
emissions of the refrigerant.

Stores that currently use R-404A or R-507A, which both have a GWP
of approximately 4000, leak on average about 1,000 pounds of that
refrigerant. That translates into approximately 4,000,000 lbs. or
about 1,800 metric tons of CO2 equivalent per store (the annual
electricity use of approximately 250 houses). A store that converts
its refrigeration system to use an HFO blend refrigerant can reduce
its direct CO2e emissions to 1,300,000 lbs or 520 metric tons of
CO2e (the annual electricity consumption of about 80 houses). The
greenhouse gas benefit just from the reduction in store refrigerant
emissions is the same as turning off the electricity for 170
houses. 

It seems much easier to retrofit a grocery store than to try to
achieve the same reductions through residential energy efficiency
measures. 

The average cost of a refrigerant retrofit is about $50,000 per
store. For $1,000,000, you could retrofit about 20 stores, which
equals a reduction in electricity demand of 2,400,000 kWh per year
(about 600 tonnes of CO2e annually) and a greenhouse gas reduction
from direct emissions of 25,600 metric tons. The total reduction
for 20 stores is 26,200 tons of CO2e - per year! Over a ten year
span, these 20 stores save 262,000 tons of CO2e!

Stores are unlikely to retrofit out of these high GWP refrigerants
voluntarily. There is no regulatory mandate that they do so. In
other words, all of these CO2e benefits will not happen without
funding through the mitigation plan. 

HFO blend refrigerants are fairly new to the supermarket industry.
While some supermarkets are conducting trials on these
refrigerants, a program to fund 20 store retrofits would greatly
expand the body of knowledge and data available on the retrofit
process and the environmental benefits. This will help expand the
use of these refrigerants across the nation faster than would
otherwise be the case. 

This project would yield CO2e savings immediately. Twenty stores
can be retrofit in a 3 month period, which will generate benefits
much quicker than many other projects that might be funded by the
mitigation program.

Refrigerants used in supermarkets are F-gases, which are
short-lived climate forcers, so the inclusion of these projects in
the mitigation program advances California’s goal of reducing these
greenhouse gases.