Comment Log Display

May 27, 2015


Mr. Bart Croes
Division Chief
Research Division
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: Short-Lived Climate Pollutant Reduction Strategy Concept Paper

Dear Mr. Croes:

I am writing on behalf of the Alliance for Responsible Atmospheric
Policy (“Alliance”) to provide comments regarding the Short-Lived
Climate Pollutant (SLCP) Reduction Strategy concept paper produced
by the Air Resources Board (ARB).

The 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 more
than 100 companies across several sectors engaged in the
development of economically and environmentally beneficial
international and domestic policies regarding fluorinated gases. 
Many of our members are active in the California market.

A list of Alliance member companies appears below, some of whom may
also submit written comments.  As our members would be most
impacted by the HFC components of the SLCP reduction strategy, it
is on that area of the concept paper that these comments will
focus.

The Alliance is proud of its extensive history of working in a
constructive manner with ARB, the US government and with
international bodies on the protection of stratospheric ozone and
the mitigation of climate change.  Our membership worked closely
with US Senator Chris Murphy in the development of his SLCP
legislation introduced in 2014 and the Alliance is active as a
non-state actor in HFC Initiative under the global Climate and
Clean Air Coalition (CCAC) to Reduce SLCPs (An Alliance statement
made during the recent CCAC High Level Assembly in Geneva is also
attached for reference).

Our membership believes that an effective means of reducing the
future climate change contribution of HFCs must be global in
nature.  It also must do so in an orderly, flexible fashion which
allows companies to continue to fulfill consumers’ need for our
products and technologies which are vital to public health, food
safety, energy conservation, comfort and productivity.  The
Montreal Protocol has met both of these standards when successfully
addressing CFCs and HCFCs.  We believe an amendment to address HFCs
would do so as well.

The Alliance appreciates the close attention ARB has paid to
developments in the Montreal Protocol.  We have sought to provide
timely updates to ARB on industry’s perspective towards progress in
Protocol amendment discussions and the significant effort industry
is contributing to facilitate the transition from high global
warming potential (GWP) HFCs.  That effort has taken the form of
directly supporting diplomacy towards a Protocol amendment, as
demonstrated by our participation on the India-US HFC Task Force,
as well as spending some $5 billion dollars over the next decade in
research, development and commercialization of new technologies for
the global market.

The Alliance believes the cap and reduction model reflected in the
amendment provides a far better approach for cost-effective action
than do unilateral sub-global command and control regulations.  The
Alliance has also advocated this global cap and reduction approach
as part of the Montreal Protocol process as a far better mechanism
than the use of the US Environmental Protection Agency’s (EPA)
Significant New Alternatives Policy (SNAP) de-listing authority
used in federal policy.  We encourage ARB to develop an SLCP
reduction strategy which is consistent with this cap and reduction
model rather than a series of command and control restrictions.

As the ARB is likely aware, Environment Canada earlier this year
responded to industry concerns over reliance on SNAP-like
sector-based prohibitions in developing its own HFC regulations. 
The department changed course and proposed a hybrid model, which
incorporates a gradual phase-down of HFCs consistent with the
phase-down schedule proposed by the North American parties to the
Montreal Protocol.

The Alliance appreciates ARB’s procedure of consulting with
interested stakeholders in advance of developing its SLCP reduction
strategy.  In order to achieve the environmental goal of these
potential regulations, it is critical to understand the variety of
challenges and opportunities present in the transition from
high-GWP technologies.  A global phase-down will allow the markets
to determine which technologies transition first, providing
certainty on the environmental benefits while providing adequate
transition time for sectors where alternatives are not yet readily
available.  The Montreal Protocol has succeeded because it has been
able to accommodate these nuances and has relied on long-term
management principles to achieve the desired environmental policy
objectives.

In terms of the timeline proposed in the concept paper, the
Alliance encourages ARB to ensure that benchmarks are chosen with
consideration of other critical timelines affecting the transition
from high-GWP HFCs, including the Montreal Protocol process, the US
EPA’s SNAP rulemaking schedule and the US Department of Energy’s
(DOE) efficiency standards rulemaking process.  Misaligned
transition dates impose significant and unnecessary cost, burden,
and complexity on industry.

On ARB’s proposed goals intended to form the foundation of the SLCP
reduction strategy, the Alliance especially supports: “Achieve
Scientific-Based Targets” and “Identify Practical Solutions to
Overcome Barriers.”  Both concepts resonate well with our belief
that while substitute technologies are evolving rapidly, HFC
management efforts must be based on actual technology
availability.

On the overall goal of exploring measures to reduce HFC use in
California by an additional 40 percent by 2030 on top of the 40
percent reduction expected as a result of AB 32 and proposed
federal rules, the Alliance believes that 2050 is a more feasible
target.  Achieving an 80 percent reduction by 2030 is sooner than
found in any of the current HFC phase-down proposals under the
Montreal Protocol.  Next-generation technologies and applications
must be developed, commercialized and widely deployed in order to
achieve significant reductions in high-GWP HFC use.  As part of
that process, those technologies must be adopted by domestic and
international code-setting organizations.  Existing code and
standards restrictions could pose challenges to companies
attempting to move towards lower-GWP alternatives, while meeting
the demand for their products from consumers in California. 
Combined, those elements of the transition require more time than
proposed in the concept paper.

ARB has proposed to consider measures to achieve further transition
to low-GWP alternatives in a number of specific sectors.  The
Alliance encourages ARB to specify its definition of “low-GWP.”  It
is important that ARB avoid unintended consequences by considering
to what extent alternatives meeting that definition are
commercially available.

On reducing leaks from existing equipment and at end-of-life, the
Alliance supports the responsible use of refrigerants.  We know
that the majority of refrigerant emissions occur during charging,
service and disposal of air-conditioning and commercial
refrigeration units.  That is why in January 2014, the Alliance
submitted a petition to extend the regulations under Section 608 of
the federal Clean Air Act to HFCs and other substitutes for class I
and class II ozone-depleting substances.  These policies have
proven effective in limiting ODS emissions and, as seen at EPA’s
November 2014 stakeholder meeting in response to our petition, most
stakeholders believe those provisions will be equally effective at
limiting HFC emissions.

As industry we are moving forward with voluntary measures to
promote the responsible use of refrigerants.  At the September 2014
UN Climate Summit, the Alliance, in conjunction with the
Air-Conditioning, Heating and Refrigeration Institute and ABRAVA,
the Brazilian Association for HVAC-R, launched the Global
Refrigerant Management Initiative under CCAC to reduce leaks and
service emissions throughout the industry’s global supply chain. 
In addition to exploring options to improve education, training and
certification, the initiative will promote the recycling, recovery,
reclaiming and end of life destruction of refrigerants and develop
additional policies to promote proper refrigerant management.  This
initiative has already received the support of industry
associations from 9 countries and the EU, representing 4
continents, and has begun initial activities in 2015.

On the proposed early action to reduce emissions from commercial
refrigeration, ARB suggests it may link this effort to existing
energy efficiency programs.  The Alliance encourages ARB to remain
technology neutral in the design of this linkage, but agrees that
consideration of the energy efficiency and life cycle climate
performance (LCCP) of equipment is critical to designing a
sustainable HFC climate policy.

The Alliance welcomes the opportunity to consult directly with ARB
to answer further questions relevant to its SLCP reduction strategy
to ensure that it is consistent with efforts in the Montreal
Protocol to address HFCs.  We are ready to work to ensure the
avoidance of the rapid global growth scenarios in the use of HFCs,
and to promote the development and implementation of substitute
technologies that allow for a manageable transition around the
globe.

The membership of the Alliance is proud of the industry
contribution to the development of alternatives to high-GWP
compounds and their implementation in equipment and products. 
Government, industry and other stakeholders must remain focused on
supporting a global transition to these alternatives.  The Alliance
thanks ARB for providing an opportunity to comment and looks
forward to working in a constructive manner to address HFCs.  If
you have any questions, please feel free to reach me at
fay@alliancepolicy.org or (703) 243-0344.


Sincerely, 
Kevin Fay
Executive Director
Alliance for Responsible Atmospheric Policy


Members:
 
AGC Chemicals Americas
A-Gas/RemTec
Air-Conditioning, Heating & Refrigeration Institute
Airgas
American Pacific Corp.
Arkema
Association of Home
Appliance Manufacturers
Auto Care Association
Bard Manufacturing Co.
BASF
Brooks Automation, Inc.
Cap & Seal Company
Carrier Corporation
Center for the
Polyurethanes Industry
Combs Gas
Consolidated Refrigerant
Solutions
Daikin Applied
Danfoss
DuPont
Dynatemp International
Emerson Climate
Technologies
E.V. Dunbar Co.
Extruded Polystyrene Foam Association
Falcon Safety Products
FP International
Golden Refrigerant
Heating, Air-conditioning &
Refrigeration Distributors
International
Honeywell
Hudson Technologies
Hussmann
ICOR International
IDQ Holdings
Ingersoll-Rand
International Pharmaceutical
Aerosol Consortium
Johnson Controls
Lennox International
Metl-Span Corporation
Mexichem Fluor Inc.
Midwest Refrigerants
Mitsubishi Electric
National Refrigerants
Owens Corning Specialty &
Foam Products Center
Rheem Manufacturing Company
Ritchie Engineering
Solvay
Sub-Zero
The Dow Chemical Company
Trane Company
Whirlpool Corporation
Worthington Cylinder