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Comment 1 for Small Containers of Automotive Refrigerant (smallcans2016) - 15-2.

First Namedave
Last Namehamel
Email Addressdavebhamel@gmail.com
Affiliation
Subjectsmallcans2016
Comment
Please abolish the special small can requirements for CFC's that
are part of California law.  The existing system in California
increases the emissions of these chemicals, and increases cost to
the end user without environmental benefit.

The unintended consequence of this legislation is that private
parties purchase the refrigerant they need when out of state, to
avoid the CA deposit and the fiddly fixtures needed for the CA
compliant cans on recharging equipment.  Commercial shops buy the
material in bulk containers that do not have deposits.  The real
intent of this legislation is in my opinion an attempt to
discourage or eliminate home mechanics from doing this work.  Many
cans are returned partially full, to get the deposit back before it
expires, which wastes chemical.  Some people I have encountered
empty the cans prior to return or over charge the systems.

The cost of 134a in CA is significantly above the cost out of state
due to the special packaging. A can is less than $6 on sale
anywhere except CA.  Here it runs $12 plus the deposit.  I do my
own refrigeration work on my cars due to problems I have had with
shops conducting this work, and will continue to do so as long as I
can.  I do not believe the intent of this program is being
achieved, and the CA EPA mission will be enhanced if this program
is realistically evaluated and revised to make sense.

Dave

Attachment
Original File Name
Date and Time Comment Was Submitted 2016-10-24 12:24:49

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