| First Name: | Kristen |
|---|---|
| Last Name: | Taddonio |
| Email Address: | ktaddonio@igsd.org |
| Affiliation | |
| Subject | Comment from IGSD |
| Comment |
IGSD STRONGLY SUPPORTS and is GLAD TO SEE the proposed Modification(s) to Ozone Depleting Substances (ODS) protocol adding R-22, R-134a, R-125, R-32, and R-143a as eligible. We also strongly suggest that the protocol be clarified that avoided emissions--such as avoided annual/operational R-22 leakage from supermarkets not yet required by regulation to switch--be eligible under the protocol. Our read of the existing protocol suggests that this might already be the case, since the protocol includes "reductions in "Emissions of ODS from leaks and servicing through continued operation of equipment." However, additional clarity on that point could be very helpful. |
| Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2021-02-28 09:44:34 |
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