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Comment 106 for Auction Proceeds Investment Plan Public Process (investplan2015-ws) - 1st Workshop.
First Name: Jeff
Last Name: Cohen
Email Address: jcohen@eosclimate.com
Affiliation:
Subject: Incentive for low GWP refrigeration equipment
Comment:
Our company is focused on reducing emissions of fluorochemicals used in refrigeration and air conditioning (R/AC) and in other applications. In addition to California's refrigerant management program to reduce leaks of fluorinated gases from refrigeration equipment, there are several important ways that California can reduce emissions of these gases and promote transitions to low GWP alternatives. However, we believe subsidizing installation of low-GWP refrigeration systems for California businesses would have limited impact and would not be a cost-effective use of cap-and-trade revenue. First, beginning in the 3rd quarter of 2015, there will be "incentives" for installation of such systems via carbon credits. Direct subsidies by California would fail to provide a scalable solution given the capital expense involved, i.e., unless the State decides to invest tens of millions of dollars into this, there would likely only be enough funds for a handful of new systems. Also, defining a "California business" based on location of its corporate headquarters would unfairly exclude many businesses who have supermarkets, food production facilities, etc in the state, resulting in an uneven allocation of funds. A more efficient approach would be for California to recognize verified GHG credits generated via 3rd party standards for installation of advanced, low-GWP refrigeration systems, and for use of reclaimed HFC refrigerants for servicing of the thousands of existing HFC systems that will continue to operate in the State for decades to come.
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Date and Time Comment Was Submitted: 2015-08-31 21:02:14
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