Submitted Comment Name Heather MacLeod Affiliation Youthpower Climate Action Subject Variance for LG on R32 for humidifiers Message Hello CARB, I am the adult advisor for a youth climate group, My students have been studying refrigerants, and are working with a local natural foods store on switching their refrigerants to natural refrigerants. Having close relationships people who will be living on this planet in another 50 years makes me more keenly aware of the importance of cutting our emissions in half in the next 6 years. When I look at this variance request, I'm not convinced that LG understands the importance of cutting emissions in half quickly. I'm not an expert on refrigerant regulations, and maybe regulations in the US don't allow the use of truly low gwp refrigerants, like R123yf. But if LG needs extra time to develop a humidifier that has a lower GWP, then it seem to me that they might as well take that time to develop a system that runs on a really low gwp, like R123yf. (or any other extremely low gwp refrigerant) Otherwise, they will have take the extra time of using a high gwp refrigerant.(410A) only to be attached to a slightly better gwp of 677 (R32). And then they'll be committed to that mediocre level of gwp for a long time. It doesn't make sense to take extra time to develop a system that works with a gwp that is 677 times that of CO2 (R32 has a gwp of 677), if you could develop a system that works with an extremely low gwp refrigerant . If they want extra time, then they should do something really good with that extra time, like developing a system to work with R123yf. And according to this website, you can use R123yf for dehumidifiers. https://www.coolingpost.com/world-news/lower-gwp-a2l-refrigerants-in-snap-list-proposals/ So if you DO decide to give them the variance with the extra time, I would request that you require that they use that extra time to do something more helpful to our climate than simply shifting to R32. From what I hear, Europe has significantly cut their use of HFCs - we can do the same if we set a high standard. Here is one article about what Europe is doing: https://eia-international.org/news/adoption-of-new-air-conditioning-safety-standard-a-milestone-for-climate-friendly-cooling/ Thank you for your work. I am regularly grateful that I live in California, and you are one of the reasons that I am grateful. Heather MacLeod File Upload (i.e., Attachments): N/A
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