First Name | Mitchell |
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Last Name | Bolinsky |
Email Address | mbolinsky@id-usa.com |
Affiliation | Interdynamics, Inc., an APRI Member |
Subject | Statement of Concern for Punitive Effects of Upstream Fees on Cooperative Partners |
Comment | November 25, 2008 To the Members of the California Air Resources Board: The employees of Interdynamics, Inc., a U.S. manufacturer of products for consumer Do-It-Yourself maintenance and repair of automobile air-conditioning systems respectfully submit the following comments relating to the Revised Draft AB 32 Scoping Plan. Interdynamics is a leading member of the Automotive Refrigeration Products Institute (ARPI) and a driving force in the mobile refrigeration industry, with a track record of environmental and social responsibility. Since 1992, we have supported reduced use and replacement of ozone depleting refrigerants such as R-12. ARPI members designed the unique can and fittings for R-134a and other SNAP approved, non-CFC refrigerants. We have also leveraged innovation to mitigate the environmental impact of our products by improving our packaging and inventing self-sealing dispensing valves. Our company and trade groups have been working cooperatively for the past two years with the ARB’s Research Division to craft proactive, effective and affordable solutions to mitigate climate change impacts associated with our consumer products. Our work with staff will directly yield a workable AB32 regulation, providing real emissions reductions and, at the same time, not disadvantaging low income Californians. We are proud to have set a cooperative example for other industry groups to follow and look forward to further supporting Alberto Ayala, Richard Corey and Tao Huai’s Research Division team at our upcoming January 22, 2009 Early Action Board hearing. But our work has not been easy and will not have been achieved without significant cost. Our alternative measures plan includes: • An industry-first, self-administered small-container return/recovery/recycling program with economic incentives for consumers to return used containers for processing. • Development and commercialization of an industry-first self-sealing valve to mitigate accidental and installation emissions of refrigerant from small containers. • A California-specific consumer education campaign, including print and website. We ask you to consider the costs and efforts expended by our company and industry in being amongst the first AB32 “cooperators”. Consider the potential punitive effects the Scoping Plan’s proposed “upstream fees” could layer on top of the already significant costs borne by the first industry to voluntarily participate in a self-regulating exercise. In early 2008, Interdynamics and ARPI had discussed with CARB staff the possibility of a fee in lieu of the regulation but were told that emissions reductions were the primary objective of AB32 measures. Now, on the eve of adoption of the regulation the prospect of a fee is raised, noting that an upstream fee would ensure that the climate impact of these substances is reflected in the total cost of the product. Since the fee will follow the regulation, the “total cost” of the products will have already increased exponentially. We disagree with the fee on top of our newly-promulgated cooperative regulation and have grave concerns that such a fee penalizes us for our proactive approach. Additionally, the Board and we recognize that incremental regulatory costs and fees are ultimately passed to consumers through higher product prices. This may precipitate a tipping point to render these products uneconomic, constituting a de facto product ban, thus ensuring an adverse impact on minorities and those on fixed incomes. This is contrary to the original objectives we and CARB staff had set out in the development of alternative regulations on the servicing of vehicle air conditioners by non-professionals. In conclusion, please know that we support a balanced, cost-effective plan to reduce greenhouse gas emissions. Interdynamics and ARPI are already playing a meaningful role in helping the state meet its policy goals for reducing green house gas emissions in California through participation in the early action rulemaking on Reduction of Refrigerant Emissions from Non-Professional Servicing and will continue its work with CARB staff on the rulemaking. We continue to stand ready, with the Board, to implement a regulatory scheme aimed at reducing greenhouse gas emissions while not devastating our industry. We want to be part of the solution, but not if the price is our businesses. Thank you in advance for your attention, consideration and support. We welcome further discussing this issue with you and invite you to contact me for further information about this issue. Sincerely, Mitchell Bolinsky Director of Marketing Interdynamics, Inc. 560 White Plains Road Tarrytown, NY 10591 mbolinsky@id-usa.com office: 914/798-7932 fax: 914/798-7971 |
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Date and Time Comment Was Submitted | 2008-11-26 06:52:24 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.