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Comment 22 for Short-Lived Climate Pollutant Strategy (slcpstrategy-ws) - 1st Workshop.


First Name: Liz
Last Name: Whiteley
Email Address: lizwhiteley@gmail.com
Affiliation:

Subject: Comments on ARB's SLCP Reduction Strategy
Comment:
To whom it may concern:

I applaud ARB's commitment to reducing HFC use 80% by 2030 here in
California. In your concept paper you state, "HFC emission
reductions could be achieved through sector specific prohibitions,
where feasible and cost effective alternatives are available, by
imposing a mitigation fee on sales of high-GWP HFCs, or other
potential options." 

I believe it is worthwhile to explore all feasible options;
however, I would strongly encourage ARB to consider incentives and
programs to promote environmentally-friendly alternatives to HFCs,
instead of taxing or banning certain HFC uses. 

For example, in commercial and retail food refrigeration there are
many good, low-GWP alternatives to HFCs (including hydrocarbons for
stand-alone refrigerators and freezers, CO2 and ammonia). Often
referred to as "natural refrigerants" these alternatives offer many
benefits: significantly lower (or even zero) GHG emissions from
refrigerant leaks, lower refrigeration and maintenance costs for
equipment operators, and improved energy efficiency (which not only
lowers a store's overall GHG footprint, but also lessens demand on
the electric grid). 

ARB should help drive market uptake of these new technologies, for
example, by helping fund the installation of natural refrigeration
technology in new grocery stores. ARB could use GGRF money to help
supermarkets install new systems, or offer rebates to stores that
install these low-GWP, energy efficient refrigeration systems. By
incentivizing installation of these systems, California will help
drive the market transformation and economies of scale we need here
in the U.S. to make natural refrigerants the "natural"
choice--better for stores' bottom-line and better for the
environment.

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Date and Time Comment Was Submitted: 2015-06-12 08:58:39



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