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Comment 78 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.


First Name: Kevin
Last Name: Fay
Email Address: fay@alliancepolicy.org
Affiliation: Alliance for Responsible Atmospheric Pol

Subject: Alliance Comments on Draft Short-Lived Climate Pollutant (SLCP) Reduction Strategy
Comment:
October 30, 2015

Mr. Richard Corey, Executive Officer
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: Alliance Comments on Draft Short-Lived Climate Pollutant (SLCP)
Reduction Strategy

Dear Mr. Corey,

The Alliance for Responsible Atmospheric Policy (Alliance) is an
industry coalition organized in 1980 to address the issue of
stratospheric ozone depletion.  It is the leading voice of
manufacturers, businesses and trade associations who make or use
fluorinated gases for the global market.  Today, Alliance member
companies are leading the development of safe, efficient,
next-generation, climate- and ozone-friendly technologies and
applications.  According to a recent study, the US fluorocarbon
using and producing industries contribute more than $158 billion
annually in goods and services to the US economy, and provide
employment to more than 700,000 individuals with an industry-wide
payroll of more than $32 billion.  The Alliance represents
companies across several sectors engaged in the development of
economically and environmentally beneficial international and
domestic policies regarding fluorinated gases.  A list of members
is attached.

The Alliance is proud of its extensive history of working in a
constructive manner with the Air Resources Board (ARB), the US
government and international bodies on the protection of
stratospheric ozone and the mitigation of climate change.  Having
submitted comments in response to ARB’s SLCP Reduction Strategy
concept paper before and after meeting directly with ARB staff to
exchange views on the reduction strategy, the Alliance is pleased
to provide these considerations with regards to the draft
strategy.

The Alliance commends ARB staff on its commitment to an effective
process of stakeholder consultation.  The Alliance appreciates the
sincere engagement and information exchange with industry which has
taken place, consistent with the provisions of SB 605.

The Alliance is generally supportive of efforts to reduce
high-global warming potential (GWP) HFCs.  ARB’s efforts, however,
should also be considered in the context of their contribution to
an effective global approach.  The Alliance encourages ARB to
ensure that its strategy chosen balances a focus on direct
greenhouse gas emissions from refrigerants with the fact that the
vast majority, possibly as much as 95 percent, of emissions related
to HVAC is from the energy necessary to operate the equipment.

The Alliance welcomes the agreement it shares with ARB that the
most effective means of reducing the future climate change
contribution of HFCs should be global in nature.  It also must do
so in a manner that is orderly, and in a flexible fashion which
allows companies to continue to fulfill consumers’ need for
products and technologies which are vital to public health, food
safety, energy conservation, comfort and productivity.  The
Alliance agrees with ARB that national and international agreements
provide the best way to reduce the supply of and emissions from the
use of refrigerants with high GWPs.  The US EPA has signaled its
intent to take additional steps to address the use of HFCs, and a
uniform federal standard is more desirable than a state-by-state
effort.  On that note, the Alliance encourages ARB to carefully
consider whether to encourage local and regional regulation of HFCs
as seen in the draft strategy.  The benefit of a global solution is
that it avoids a broad patchwork of sub-global policies, which
could lead to inconsistent requirements between regions and added
costs of compliance being passed to consumers.

The Alliance recognizes, however, that there is uncertainty over
whether the Montreal Protocol will be amended to phase-down HFCs
and, as a result, sub-global jurisdictions have begun to address
HFCs in order to reduce emissions of high-GWP HFCs.  The Alliance
appreciates ARB’s decision to allow international negotiations
under the Montreal Protocol to play out this Fall before
determining precisely how California can take actions to support
and complement global efforts.  The Alliance remains available to
provide updates on the state of negotiations under the Protocol as
helpful.

The Alliance notes ARB’s interest in pursuing additional reductions
beyond those which may be achieved under the Montreal Protocol.  It
is important that any such measures carefully and fully consider
relevant environmental and economic impacts, including the
challenge faced by a number of sectors in adopting lower-GWP
alternatives.

The Alliance appreciates ARB’s willingness to incorporate a
potential phase-down in California’s supply of HFCs which aligns
with similar efforts in Australia, Canada, Europe and Japan.  The
Alliance remains available to serve as an informational resource in
the design of such potential structures.

As indicated in the draft strategy, important progress on SLCPs has
been made in the Climate and Clean Air Coalition (CCAC).  Public
and private sector coalition partners, including the Alliance, have
developed innovative ways to address this element of the climate
change challenge.

In line with ARB’s emphasis on developing early voluntary actions
to achieve earlier reductions, the Alliance is proud to have been
central to the launch of two CCAC initiatives: the Global Food Cold
Chain Council and the Global Refrigerant Management Initiative. 
These industry-led initiatives will reduce the unintended climate
change contribution of HFCs in the food cold chain and servicing
sector consistent with the goals of the HFC amendment to the
Montreal Protocol.

The Alliance appreciates ARB’s recognition of the significant
private sector commitments to reduce the climate change impact of
HFCs which were made at the White House in September 2014.  Many
Alliance member companies participated in that important event and
the Alliance is pleased to note that a follow-up event was convened
by the White House earlier this month.  At that event, Alliance
member companies announced significant progress towards their 2014
commitments as well as new actions, including plans by the Alliance
and other industry partners to develop a Reclaimed HFC Credit
Bank.

Refrigerant management, including reclamation, will likely receive
a great boost given that the US EPA, at the same White House event
this month, announced that it issued a proposed rule as a response
to the Alliance’s January 2014 petition requesting that the
provisions of Sec. 608 of the Clean Air Act be extended to HFCs. 
It remains the most viable strategy for near term emissions
reductions.  California must do more to minimize service and
disposal emissions and enhance reclaim or reclaimed refrigerants.

The Alliance believes the reclamation of refrigerants can be a
useful tool to reduce emissions while providing a source for the
continued servicing of installed equipment.  To that end, the
Alliance appreciates that ARB’s proposal to “prohibit the sale or
distribution of refrigerants with very-high GWP values” may include
an exemption for refrigerants certified to be reclaimed or
recycled.  This is a reasonable exemption that minimizes
environmental costs while potentially creating economic value.

On incentive programs, the Alliance reiterates that the specific
mechanism and cost implications must be carefully considered as
well as the impact on energy efficiency of low GWP alternatives
that might be incentivized.  The Alliance encourages ARB to explore
incentives for using low-GWP refrigerants which benefit all sectors
in lieu of fees based on usage of certain refrigerants.

On potential bans on the use of high-GWP refrigerants, the Alliance
reiterates that companies will comment individually on the
feasibility of sector-based controls since diverse views exist
among Alliance members regarding such measures.  Again, the
Alliance believes that if ARB moves forward with sector controls,
those controls must incorporate the necessary flexibility to enable
compliance, avoid the imposition of significant implementation
costs and allow consumers to transition to alternative technologies
with net-equal or improved energy efficiency.  On that note, the
Alliance appreciates that ARB notes the connection between energy
efficiency and refrigerant choice in appliances and HVACR systems. 
It is also important to recognize that manufacturers will need
alternatives available which allow them to meet increasingly
stringent energy efficiency standards.

For any potential HFC controls, the Alliance encourages the Board
to take into account the timelines necessary for changes to any
relevant codes and standards, including the model building, fire,
mechanical and residential codes used in California after adoption.
 This important factor has often been a secondary concern for
policymakers attempting to address HFCs, but is key to implementing
a successful transition from high-GWP HFCs.  Technology reviews
must look both at the state of technology as well as what is
allowed under the above mentioned codes for commercial and
residential properties.

The Alliance would like to emphasize its concern regarding the use
of both 20-year and 100-year GWPs in the draft strategy.  Although
ARB states in the draft strategy that 20-year GWPs “better
[capture] the importance of the SCLPs and give a better perspective
on the speed at which SLCP emission controls will impact the
atmosphere relative to CO2 emission controls,” the Alliance notes
that consistency in this respect can promote common understanding
and consensus-building with affected stakeholders.  From a
comparative perspective, the 100 year time horizon has been
successfully relied upon in both the Montreal Protocol and UN
Framework Convention on Climate Change for consistency of
decision-making and should continue to be utilized.

As far as suggestions for future information gathering, the
Alliance continues to encourage ARB to develop graphic projections
which explain the concern that an amendment alone would be
insufficient to address emissions from the installed base. 
Additionally, the Alliance continues to encourage ARB to
graphically communicate what emissions reductions can be achieved
with each sector proposed for the draft strategy.

Although ARB seeks to harmonize its HFC phase-down with the North
American amendment (NAA) proposal in the Montreal Protocol, ARB’s
phase-down is emissions-based and the proposed NAA is consumption
based.  The Alliance continues to encourage ARB to resolve this
disparity and communicate how ARB has done so.

The Alliance very much looks forward to ARB’s proposed strategy and
draft Environmental Analysis and continuing to be a resource for
ARB staff as it advances these important policies.  As a final
suggestion, the Alliance reiterates that any policy measure should
be assessed based on the following factors:
•	Technical feasibility,
•	Ease of implementation,
•	Ease of enforcement, and
•	Anticipated
o	Environmental Impacts, and
o	Economic Impacts on Consumers, Small businesses (including
contractors, distributors, and retailers), and Industry

While the Alliance supports concerted global action to avoid
significant future growth in the greenhouse gas emissions
associated with the use of HFCs in their various applications, it
is important that those emissions are avoided in a manner that
ensures industry is able to continue to deliver critical societal
and lifecycle climate benefits provided by their products.  ARB’s
actions to control HFCs should be carefully pursued and incorporate
the important considerations we have cited above.

The Alliance remains available to assist ARB staff as it develops
its proposed strategy.  The Alliance appreciates the opportunity to
provide input on ARB’s draft strategy and looks forward to working
with the agency in a constructive manner to achieve and implement
an environmentally beneficial, safety enhancing, and economically
viable strategy.


Sincerely,
Kevin Fay
Executive Director
Alliance for Responsible Atmospheric Policy

Attachment: www.arb.ca.gov/lists/com-attach/84-slcpdraftstrategy-ws-VjdRO1Q5AjhRNgNt.pdf

Original File Name: Alliance Members.pdf

Date and Time Comment Was Submitted: 2015-10-30 12:46:41



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