During its July meeting, several air conditioning manufacturers and other stakeholders requested that CARB delay the effective date for the 750 GWP limit for new stationary air conditioning equipment from January 1, 2023, to January 1, 2025, and they have submitted alternative proposals for achieving emissions reductions. The reasons they cited for this request include:

1.  Allowing additional time for a/c manufacturers to transition refrigerants;
2. The A1 alternative (R-466A) may require more time to be ready as a substitute refrigerant, and
3. The California Building Standards Code may not have the necessary updates to allow A2L refrigerants to be used in 2023. These stakeholders have provided ideas for incorporating an additional compliance pathway in addition to the 2023 compliance pathway.

Air conditioning manufacturers and other stakeholders have proposed achieving needed emissions reductions through use of refrigerant reclaim in new equipment, servicing existing equipment, refrigerant destruction, as well as potential crediting system based on type of refrigerant used to account for charge and GWP reduction. In response to these proposals, CARB staff are considering incorporating a compliance pathway, although CARB staff intend to keep the 2023 date for those that can comply with that date.

An additional compliance pathway for a/c manufacturers and other regulated entities could include the allowance of a two-year delay or temporary exemption from the 750 GWP requirement for a/c manufacturers if the manufacturer is able to offset the CO2 equivalent amount of refrigerant equal to the initial refrigerant charge size through the purchase and use of reclaimed refrigerant in equipment placed on the market in California during the delay. If reclaimed refrigerant is not used in equipment during the delay, then manufacturers would need to offset the initial charge, plus the anticipated additional service gas for the lifetime of the exempted equipment within five years. In addition, manufacturers would need to show the following:

• Contractual agreements to purchase reclaimed refrigerants for use or distribution with reclaimers or distributors;
• All activities related to the exemption or delay are subject to verification and reporting. CARB staff is considering this verification being done through a third-party audit, reporting on an annual basis to CARB, or annual self-certification to CARB; and
• Non-compliance is subject to strict liability penalties equivalent to the California cost of carbon estimates per CO2e offset not met.

CARB is evaluating the feasibility of these additional compliance pathways, as well as a hybrid option, from the standpoint of enforcement, implementation, and emissions benefits. CARB may consider needs for collecting research and development information for specialized systems, and staff may also consider other changes to the sections affected during the course of this rulemaking process. Any changes to the proposal would be presented to the Board for consideration during the hearing scheduled for December 10.

Interested members of the public who would like to comment on the proposed regulatory action may do so by mail or by electronic submittal before the hearing. The public comment period began on October 23, 2020, and comments must be received no later than December 7, 2020. CARB requests that written and email statements be filed at least 10 days before the hearing to give CARB staff and Board members additional time to consider each comment. Comments may be mailed to:

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

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