California Air Resources Board

Thank you for the opportunity to contribute to this important policy initiative in California. I am responding to the questions numbered 1-4 in the commercial refrigeration section. Please see below with associated question numbers:

1. What potential technological solutions are available for existing facilities and how can their adoption be accelerated?
- the transcritical co2 refrigeration system design is well known and can apply to almost all applications. The main hurdle to adoption at scale is capital cost. Transcritical co2 system architectures are excellent options for all system types except self-contained (where hydrocarbons offer better efficiencies), some industrial sites (where ammonia is also a good option), or other cooling-dominated applications where large-charge hydrocarbon options exist (residential air-to-water heat pumps for example).
- One unique value of transcritical cycles is their ability to provide useful heat for buildings, both for domestic hot water and for space heating.
- A number of options for expanders for transcritical systems (ejectors, microturbines, etc.) are available but additional research and development would be worthwhile investment for California. Suggest funding research at national labs or local technical universities.
- Hydrocarbon systems (propane and isobutane), both air cooled and water cooled, represent great options for self contained and small load fixtures. Because they cannot be field charged, a replaceable cassette type model is required. The state could support the supply chain for such technology and support standardization of design for the casettes (like the USB standard).
- Glycol secondary systems (while often using more energy than pure direct expansion approaches) can be a good option to reduce refrigerant charge dramatically in larger supermarkets.

2. What incentives are needed to transition existing refrigeration facilities and what GWP limit should be set for technologies supported through incentives?

- Incentives are absolutely needed to drive both ultra-low GWP solutions (we should not incentivize anything above 10GWP) and to make sure that investments going into the transition also further state goals for an energy efficient and flexible electricity grid.
- the current $40m budget set for the FRIP program is vastly insufficient to drive the market adoption/market transformation required. Suggest allowing the energy efficiency program implementers (Investor owned utilities, regional energy networks, and community choice aggregators to leverage public purpose funds to drive down greenhouse gas emissions in refrigeration by assigning total system benefit value through the use of the refrigerants avoided cost calculator. Such an approach would dramatically increase the available budget for retrofits and would ensure that state investments in low-gwp infrastructure would not negatively impact efforts to achieve an efficient and flexible electric grid, and vice-versa.
- Incentives are additionally needed for small business, for independent retailers, for native tribal facilities, for NGO food banks, for other food system installations that the state's population relies on.
- Incentives are needed to get the contractor base and OEM community engaged in the necessary market transformation. These should focus on worker training, ideally tied to certification on ultra-low GWP options for cooling tech.
- Incentives should be used to setup a CA center of excellence for refrigeration transformation and hosted at a CA university. Such a center could provide training for market participants and conduct research into state-of-the-art technology. This would drive CA economic growth.

3. What safety testing and safety standard updates, if any, are needed for the transition to ultra-low GWP or no-GWP alternatives in this sector?
- hydrocarbon refrigerants, specifically propane and isobutane represent some of the best options for cooling technologies. It’ll be important to find every safe application of those technologies to implement an ultra-low GWP solution in the state. In order to do so safely, safety standards for manufacturing, installing, maintaining and disposing of hydrocarbon-based systems need to be fast tracked. The state should lead efforts to test equipment and approaches using hydrocarbon refrigerants with the goal of accelerating market readiness of safe-use approaches to leveraging hydrocarbons as refrigerants.
- Adoption of up-to-date codes and standards needs to be a priority so that outdated standards don’t delay the transition. Local AHJ's may require training and assistance to prepare for a rapid market transition and new technology.
4. What barriers exist in bringing technologies such as ejectors, CO 2 condensing units and others, to the California market, particularly for smaller refrigeration systems such as those found in convenience stores?

- The condensing unit market is primarily driven by cost. The easiest way to move to ultra-low GWP condensing units is to require the use of ultra-low GWP refrigerants in all new condensing units - but the market is not yet ready for such a strategy. In order to prepare for requirements, it would be advisable to provide targeted incentives for energy-efficient co2 (and other market ready ultra-low GWP solution) based condensing units. This could best be done through tying energy efficiency funding and refrigerant funding together (either through providing public purpose funds incentives calculated using the CPUC's refrigerants avoided cost calculator, or through tying specific CARB funding to energy efficiency performance requirements - along the lines of how energy star appliance standards work) to offer a single and simple option to pay people to make the investments. Such a plan should follow the approach of the CA solar initiative with initially very high incentive levels, followed by a gradual ramping down of the incentive levels over time and done so in a transparent and predictable manner. After such a program, the requirement could be effective.