Comment Log Display

Comments on DRAFT CONCEPTS FOR PUBLIC DISCUSSION: Cap-and-Trade
Auction Proceeds Second Investment Plan 

The following comments are in support of the CA Air Resources
Board’s suggestion to provide incentives to assist California
businesses with installing low-GWP refrigeration equipment. 

I can attest to the financial barriers that prevent supermarkets
from choosing natural refrigerant systems for all newly constructed
stores. While I have participated in several supermarket pilot
projects with natural refrigerants, the high equipment costs and
installation and maintenance costs prevent most from choosing these
technologies. Even though natural refrigerants are the right choice
for the environment, supermarkets have a duty to their shareholders
that often prevents us from spending extra money on technologies
that are not yet price competitive.

We are in a catch-22 situation. Supermarkets cannot pay the higher
prices for natural systems, so they are waiting for prices to come
down; yet equipment manufacturers cannot lower prices until they
achieve more volume and economies of scale.

An incentive program would get us out of that catch-22. If
cap-and-trade money is used for a short time period, approximately
3-5 years for instance, to stimulate volume, component
manufacturers would invest in US operations, and equipment
manufacturers would lower manufacturing costs. Service contractors
would also have a market for technicians who are skilled in natural
refrigerant systems, so they would invest in training to meet that
market demand.  

In summary, I feel that using cap-and-trade dollars to subsidize
the additional costs related to natural refrigerant equipment is
exactly what is needed to accelerate the uptake of these
environmentally-friendly systems. Subsidies in CA would not only
help CA achieve greenhouse gas reductions; they would lead to
increases in the uptake of these technologies nationwide.

Sincerely, 

Tristam Coffin