First Name | Michael |
---|---|
Last Name | Klein |
Email Address | mklein@efproducts.com |
Affiliation | EF Products, L.P. |
Subject | Scoping Plan Comment about Upstream Mitigation Fees |
Comment | November 26, 2008 Members of the California Air Resources Board: The employees of EF Products, L.P., 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. EF Products is one of the leading members of ARPI (the Automotive Refrigeration Products Institute) and a driving force in the mobile refrigeration industry. Since 1992, we have responsibly 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 and are currently working to support the industry’s coming transition from R-134a and to a new, low-GWP refrigerant. In the revised Scoping Plan, CARB identifies four Discrete Early Action measures to reduce greenhouse gas emissions of the refrigerants used in car air conditioners, semiconductor manufacturing, air quality tracer studies and consumer products. Also identified were reduction opportunities associated with commercial and industrial refrigeration, changes to the refrigerant used in auto air conditioning systems and ensuring that existing car air conditioning systems and stationary refrigeration equipment do not leak. For the past two years, our company and trade associations have been working cooperatively with ARB’s Research Division to craft proactive, effective and affordable solutions to mitigate climate change impacts associated with our products used by consumers to service mobile vehicle air conditioning (MVAC) systems. This work is very close to yielding a workable AB32 regulation that will provide 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: • Development and commercialization of an industry-first self-sealing valve to mitigate accidental and installation emissions of refrigerant from small containers. • A first of its kind, self-administered small-can return/recovery/recycling program with economic incentives for consumers to return used containers for processing. • 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, EF Products and ARPI had discussed with CARB staff the possibility of a fee in lieu of the regulation. We 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 substantially. 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, we must recognize that incremental regulatory costs and fees are ultimately passed to consumers through higher prices. This may render our products uneconomic, constituting a de facto product ban, creating an adverse impact on minorities and those on fixed incomes. This is contrary to the original objectives we and CARB staff defined in developing alternative regulations for servicing of MVACs by non-professionals. In conclusion, you should know that we continue to support a balanced, cost-effective plan to reduce greenhouse gas emissions. EF Products 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 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, Michael J. Klein President and CEO EF Products / An IDQ Company 8200 Springwood Drive / Suite 255 Irving, Texas 75063 mklein@efproducts.com Phone: (972) 444-0422 ext.112 FAX #: (972) 831-8891 |
Attachment | www.arb.ca.gov/lists/scopingpln08/833-arpi_ef_products_scoping_plan_comments_-_klein.112608.doc |
Original File Name | ARPI EF Products Scoping Plan Comments - Klein.112608.doc |
Date and Time Comment Was Submitted | 2008-11-26 11:13:45 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.