Comment Log Display

Page 57, figure 8. Please note that commercial air conditioning and
commercial refrigeration are apparently lumped in together. They
are very different industries with significantly different
historical treatment of refrigerants. Commercial grocery stores,
for example, have historically had a much higher proportion of
leaks and refrigerant usage than virtually any commercial air
conditioning system. Similar comment applies to figure 9, page 59.

Page 58, section A, "progress to date".  Please recognize that AB
32 is virtually unknown in the field. As an example, I am regularly
trying to educate customers regarding quarterly refrigerant leak
check requirements under AB 32, and have found that few end users
are willing to spend the money for this. Another unknown and
unenforced regulation.

Page 61, Incentive programs. The data noting more than 2,400
facilities using R-22 in the state is a joke. Their are more than
2,400 facilities in Los Angeles county alone that use R-22.
Please also recognize that commercial AC systems do not "use"
refrigerant. Refrigerant is only lost in the event of mechanical
failure, with for commercial AC equipment (unlike automotive AC
equipment) is relatively uncommon. Finally, if you wish to move
away from R-22 to an acceptable alternative, an incentive of some
sort is probably a good idea.