Comment Log Display

Dear CARB,

I support the proposed rules to require reclaimed refrigerant in
MVAC small cans that contain a refrigerant with a GWP over 150.
Although more stringent policies would likely be easier to enforce
and yield increased environmental benefits, such as Washington's
prohibition on sale of small cans with refrigerant with a GWP >150,
requiring reclaimed refrigerant is a next best option.

CARB may wish to consider, at the outset, ways to mitigate the
potential for misconduct. Online sales and cross-state-border
shipments could post a threat to successful implantation of the
reclaimed refrigerant requirements. CARB should coordinate with its
enforcement division and/or other authorities within California to
develop a robust plan to minimize and mitigate cheating. 

Additionally, CARB may wish to consider methods to assure that
reclaimed refrigerant is not simply virgin refrigerant charged into
and then immediately recovered from a large system for purposes of
counting it as "reclaim." This scenario has been discussed in
industry forums as a method to meet the demand for recovered
refrigerant, and as a possible lucrative option if prices of
reclaimed refrigerant happen to exceed the price of virgin
refrigerant. 

Best regards,

Kristen Taddonio
Director of Climate Control
IGSD