Comment Log Display

Our company is focused on reducing emissions of fluorochemicals
used in refrigeration and air conditioning (R/AC) and in other
applications. In addition to California's refrigerant management
program to reduce leaks of fluorinated gases from refrigeration
equipment, there are several important ways that California can
reduce emissions of these gases and promote transitions to low GWP
alternatives. However, we believe subsidizing installation of
low-GWP refrigeration systems for California businesses would have
limited impact and would not be a cost-effective use of
cap-and-trade revenue. First, beginning in the 3rd quarter of 2015,
there will be "incentives" for installation of such systems via
carbon credits. Direct subsidies by California would fail to
provide a scalable solution given the capital expense involved,
i.e., unless the State decides to invest tens of millions of
dollars into this, there would likely only be enough funds for a
handful of new systems.  Also, defining a "California business"
based on location of its corporate headquarters would unfairly
exclude many businesses who have supermarkets, food production
facilities, etc in the state, resulting in an uneven allocation of
funds. A more efficient approach would be for California to
recognize verified GHG credits generated via 3rd party standards
for installation of advanced, low-GWP refrigeration systems, and
for use of reclaimed HFC refrigerants for servicing of the
thousands of existing HFC systems that will continue to operate in
the State for decades to come.