First Name: | Keilly |
---|---|
Last Name: | Witman |
Email Address: | keilly@kwrms.com |
Affiliation | KW Refrigerant Management Strategy |
Subject | Comments on ARB's Draft Aliso Canyon Climate Impacts Mitigation Program |
Comment |
These comments are related to the types of projects that should be prioritized under Program Concentration #2: Promoting Sustainable Energy Infrastructure The draft mitigation program states that ‘[p]rojects in this sphere would sponsor or otherwise promote enhanced energy-efficiency measures ... especially in the transportation, commercial, and residential sectors. One of the quickest and most effective ways to generate energy efficiency benefits in the commercial sector is through refrigerant retrofits of existing high GWP refrigerant systems to a lower GWP HFO refrigerant. A refrigeration system that uses an HFO blend refrigerant is about 10% less energy intensive than a system that uses a high GWP HFC refrigerant gas. According to the Energy Star Program, an average supermarket uses approximately 2,346,000 kilowatt hours of electricity per year. Approximately half of that consumption is due to the store’s refrigeration system. Therefore, a 10% energy efficiency improvement in that system translates into a savings of almost 120,000 kwh per store, per year. In addition to an expected 10% energy efficiency gain that would be achieved by converting a supermarket refrigeration system to use a more efficient refrigerant, each of these projects also generates an immediate greenhouse gas benefit by lowering the direct emissions of the refrigerant. Stores that currently use R-404A or R-507A, which both have a GWP of approximately 4000, leak on average about 1,000 pounds of that refrigerant. That translates into approximately 4,000,000 lbs. or about 1,800 metric tons of CO2 equivalent per store (the annual electricity use of approximately 250 houses). A store that converts its refrigeration system to use an HFO blend refrigerant can reduce its direct CO2e emissions to 1,300,000 lbs or 520 metric tons of CO2e (the annual electricity consumption of about 80 houses). The greenhouse gas benefit just from the reduction in store refrigerant emissions is the same as turning off the electricity for 170 houses. It seems much easier to retrofit a grocery store than to try to achieve the same reductions through residential energy efficiency measures. The average cost of a refrigerant retrofit is about $50,000 per store. For $1,000,000, you could retrofit about 20 stores, which equals a reduction in electricity demand of 2,400,000 kWh per year (about 600 tonnes of CO2e annually) and a greenhouse gas reduction from direct emissions of 25,600 metric tons. The total reduction for 20 stores is 26,200 tons of CO2e - per year! Over a ten year span, these 20 stores save 262,000 tons of CO2e! Stores are unlikely to retrofit out of these high GWP refrigerants voluntarily. There is no regulatory mandate that they do so. In other words, all of these CO2e benefits will not happen without funding through the mitigation plan. HFO blend refrigerants are fairly new to the supermarket industry. While some supermarkets are conducting trials on these refrigerants, a program to fund 20 store retrofits would greatly expand the body of knowledge and data available on the retrofit process and the environmental benefits. This will help expand the use of these refrigerants across the nation faster than would otherwise be the case. This project would yield CO2e savings immediately. Twenty stores can be retrofit in a 3 month period, which will generate benefits much quicker than many other projects that might be funded by the mitigation program. Refrigerants used in supermarkets are F-gases, which are short-lived climate forcers, so the inclusion of these projects in the mitigation program advances California’s goal of reducing these greenhouse gases. |
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Original File Name:
Date and Time Comment Was Submitted: 2016-03-24 16:33:28 |
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