California Air Resources Board

Hi CARB FGAS Team,

Please find my answers to questions and my thoughts with articles attached -  

Section 5: Transport Refrigeration

20. What are the opportunities and barriers for transitioning existing TRUs to ultralow-GWP and/or no-GWP alternatives?

The barriers are the main transport refrigeration unit suppliers not supporting the transition to cleaner TRU's - trials are ongoing in the EU on natural refrigeration systems and the sale of Nitrogen type systems has been common in the Northern Europe region.

You cannot refit a old unit with new natural gases- we did some trials 30 yrs ago and we dropped Propane into a CFC unit with some minor adjustments and it worked well. It was not adopted due to the flammability question, but we proved the point.

Your best bet is to get people to refocus on the need for the cold chain on there products - read my article attached "Think of the Box" they will be numerous areas where the use of the Cold Chain is not required with adequate temperature monitoring, thus the need to have transport refrigeration units at all.      

21. What are the opportunities and barriers for transitioning new TRUs to ultralow-GWP and/or no-GWP alternatives?

There are no barriers - the use of natural refrigerant and non diesel powered transport refrigeration systems is all ready happening in the EU. The use of natural refrigerants in the Shipping container sector is common with thousands in service around the world built by some of the same companies that make transport refrigeration units in the USA. 

Engineers would need training, but the need then to reclaim gas and comply with FGAS laws and the risks of continued HFC gas prices goes. So the actual cost to run a unit will potentially reduce.   

Read my article called "Precautionary Stance" the risk to not going to non HFC - HFO gases is to high. The articles is based on a UK Health and Safety Executive study and it highlights that HFC- HFO gases and the risk of PFAS chemical and then TFA acid form a risk that is to high for anyone to warrant the continued use of these gases.  In the EU and USA you are all passing laws to ban the PFAS chemicals within 2yrs.  ( I have included the original article pfas- rmoa)

This is not just about HFC - you need to include HFO as well and the risk of the unknown could make the Ozone hole a pinprick looking back down on a planet contaminated by PFAS chemicals.    

22. How can end-of-life refrigerant recovery from existing systems be increased?

Make it law - that all units must be recovered prior to removal from the truck or trailer etc. and ensure traceability of the removal and reuse of the gas via documented controls. 

I would also advise you to consider - forcing companies that supply transport refrigeration equipment to give there customers a fixed gas price cost for the duration of the life of the unit. This will put the onus back on the companies to ensure no leaks are left unrepaired as they will be paying the costs - it will also mean that the high the GWP gases the high the chance the gas will be banned under the Kigali agreements and thus the prices will rise. Traditionally the cost would be borne by the customer, this was the cost will be borne by the provider of the equipment. Again making them responsilble for using higher GWP gases etc.      

23. How can high-GWP refrigerant leakage be decreased in existing systems?

In the UK and EU with have a annual leak check which is a legal requirement -but we don't test on units fitted to trucks under 3.5t Gross weight - you must test all trucks - vans or trailers annually. Any losses are then reported and you can then estimate gas loss in the sector etc. 

Put the onus on the transport refrigeration companies to provide the documentation and then cross ref to your list of all registered unit in the state to ensure 100% compliance. Also if the unit has a leak in the year then that also needs to be reported and the unit retested to ensure no leaks and again submitted to your data base. 

Make sure that the engineers who are working in the sector also know about the changes and make it a responsility for them to act to become part for the solution and not the problem. 

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On the others questions is the other sectors - most of my comments apply the same to them.  There is no need today to be using HFC- HFO refrigerants in any part of the Cold Chain or AirCon sectors. unless specilsed machines.

The use of Propane and Co2 is more and more common with the UN even training technicians in Turkey to work on equipoement being used in there cold chains. 

The barriers you face are the same as when you took on diesel emissons. The companies providing the products do not want to change, the chemical companies do not want to change. 

But the planet is saying we need to change and so we must. 

I can find you lots of innovation in the sector from PCM's to magnetic refrigeration to wind and water refrigeration systems etc. Its time for you all to embrace a term that I use called #eDonkeyfication and its about the need to park up these old donkey's of units that you are using now and bring on the new donkey in the block that uses natural refrigerants and non diesel powered and that is only after all the companies that use cold chain equipment justify the use. ( See think of the box)  

I have attached a few more articles that you will also find interested on the subject. 

Any questions for me then let me know.

Regards,

Norman 

Norman Highnam MinstR

+44 7443430195