Comment Log Display

We at True Manufacturing strongly support the incentive proposal
for natural refrigerants.  We see the need to reduce the use of
high GWP refrigerants.  

Markets do not move without drivers.  The EPA SNAP regulations will
drive the Self-contained Commercial Refrigeration to low GWP
refrigerants, but will not drive the markets away from the "F"
gases, which are questionable at best.  The regulations  allow the
high GWP equipment to be manufactured and marketed for up to 4 1/2
more years.      

Many customers do not want to change gases because of market
acceptance of the traditional refrigerants that have high GWPs.
Without some reason to change before the 2019/2020 deadlines, they
will continue to use the "known technology,"  until they are forced
by regulation, to buy alternates.

Many manufacturers claim that there will be no supply of equipment,
if the SNAP and/or California proposals goes forward.  We disagree
with these comments.  We have completed the design and listing of a
relatively complete line of glass door and solid door commercial
units.  

R-290 and R-600A refrigeration units are much more energy efficient
than the R-134a or R-404A equipment in the market today.   (10% to
40% less power) 

The California proposal would do several things.  It could help
cover any additional costs for the new technologies, it would get
buyers to notice that there are alternates available and it would
reduce the total electrical load of the equipment.