I’d like to update you on the efforts Environmental Defense Fund (EDF) is undertaking in California to accelerate the transition to new cooling systems with dramatically reduced global warming potential. This year, we are sponsoring a bill in the California Legislature that will require thorough analysis of available technologies and identify ways to incentivize the use of environmentally friendly refrigerants like CO2.
As part of the state’s landmark Global Warming Solutions Act signed into law in 2006, the California Air Resources Board (CARB) has created a statewide greenhouse gas emissions inventory to target major sources of global warming pollution. CARB’s inventory suggests that emissions of high global warming potential (high-GWP) gases are expected to grow from nearly 15 MMTCO2e in 2004 to more than 45 MMTCO2e by 2020 if no action is taken. Nearly all of this growth can be attributed to the increased use of HFCs that replace HCFCs being phased out under the Montreal Protocol.
During development of the Scoping Plan, the guiding implementation document for achieving statewide emission reduction targets, CARB outlined their strategy for mitigating the effects of high-GWP gases. The state’s three-tiered approach would:
1. Establish a stationary refrigerant management program to register large refrigeration and air-conditioning (RAC) systems with the state, institute periodic leak checks, and require leak repair to limit the emissions from leaky systems.
2. Institute an upstream GHG mitigation fee on the sale of refrigerants used to charge cooling equipment.
3. Establish new specifications for buildings and equipment using refrigerant technologies.
The state’s strategy is laudable, but the overall result will not be the truly transformational change that California needs. While minimizing leaks is a worthy goal, it allows high-GWP material to stay in circulation and nearly assures that a considerable portion will end up in the atmosphere. Furthermore, chasing leaks puts a regulatory and administrative burden on state agencies to train inspectors, register systems, collect data, and perform a wide range of ongoing maintenance services without offering any alternative. Similarly, a mitigation fee will collect revenue that can be used to offset high-GWP emissions, but the fee will not guarantee a slowdown in the overall growth of HFC use.
The leak check program has already been delayed and the mitigation fee is likely to face strong resistance as well. In the end, neither approach is likely to reduce refrigerant emissions at the rate necessary to meet statewide climate targets.
Setting new standards for buildings and appliances will be important in establishing a minimum threshold for system performance, but we need to go further than that if we are to tackle high-GWP emissions quickly and effectively. There is little indication that such standards would require installation of low-GWP and natural refrigerant systems that are quickly becoming the norm in other parts of the world.
California needs a fresh assessment of emerging technologies that are safe for the ozone and much less harmful to the climate. Now is the time to start making the transition to truly environmentally friendly cooling systems.
Our bill will require the California Energy Commission to assess alternative low-GWP technologies as part of their efforts to update building and appliance standards. The Commission would examine the energy efficiency and environmental impact of cooling systems, including the effect of direct emissions of high-GWP gases used as refrigerants.
Drawing on CARB’s expertise, the commission will produce a report identifying the most technologically feasible and cost-effective approach to reducing high-GWP emissions and develop demonstration and pilot projects as needed to test new technologies.
Once completed, this report will indicate the most viable path forward for regulating high-GWP emissions in California. Our hope is that the bill will fill any future regulatory gaps not covered by the development of the leak check program, mitigation fee, or new specifications and will jumpstart the market for climate friendly cooling systems.
The support of other organizations, especially R744 advocates and equipment manufacturers, is essential to getting this bill passed and promoting alternative refrigerants more broadly. Please don’t hesitate to contact us with any questions or to find out how you can help California transition to environmentally friendly cooling systems.
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