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In regards to the fastest growing source of GHG emissions, F-Gases,
the solution is the promotion and use of Natural Refrigerants
including Ammonia, CO2, Hydrocarbons and Air. Some of these
refrigerants have been in use for 120-140 years, so their
properties and effects to the environment are well known. While
there are some additional safety aspects required when using these
refrigerants, they have been proven to be safe and reliable with
properly designed and installed systems. With  chemical based
refrigerants such as CFC's, HCFC's, HFC's and now HFO's, it takes
us 20-30 years to figure they are harmful to our environment,
therefore requiring another ban and introduction of new synthetic
refrigerants all at a great cost to the environment and to the end
users. Natural Refrigerants offer a wide temperature applications
range from ultra low temp to bldg. water chillers so they can be
used to replace existing chemical based refrigerants systems. In
addition with low charge (under 500 lbs total) technology, Ammonia
systems can be installed and operated safely as many manufacturers
now offer equipment with very low leakage rate. Co2 is an excellent
secondary refrigerant that when used properly in a cascade type
system, offers very high energy efficiency regardless of the
ambient conditions. The concept paper outlines 54% of GHG emissions
comes from the Commercial and Industrial refrigeration sectors,
therefore using Natural Refrigerants targeting these areas would
contribute significantly to SB-605 goals on an accelerated
schedule. Last, Natural refrigerant based systems are highly energy
efficient systems that can save end users 10-30% in total energy
costs, so the promotion using energy savings and low to no GHG
emissions would be recommended. These systems can be retrofit or
new applications. Many manufacturers are taking the steps necessary
to offer these safe, reliable and energy efficient systems to
California and much has been done with new technology in just the
last 2-3 years. Therefore I highly support Governor Brown's efforts
to reduce overall SLCP's and look forward to the implementation of
SB-605.