California Air Resources Board

I am writing in support of ALTA Refrigeration, Inc.’s request for a variance from the California Air Resources Board’s (CARB) refrigerant restrictions under Section 95374(c). Prohibiting the continued use of R-513A would severely limit the availability of proven, efficient, and safe refrigeration technologies for cold storage operators in California. Eliminating R-513A would force synthetic refrigerant machinery to use R-1234yf or R-1234ze, both of which have a lower GWP but are considerably more expensive upon initial charge and startup—typically 60% to 120% more costly on a 1,500-pound charge, adding tens of thousands of dollars in upfront cost.

Preserving Equipment Choice
I believe CARB should not further restrict the range of industrial refrigeration technologies available to end users. ALTA’s Expert system represents an innovative alternative to legacy ammonia or CO₂ systems, and eliminating the option to use R-513A would unnecessarily reduce competition and innovation. As a developer, we use all forms of industrial refrigeration equipment (Synthetics, CO2 and Ammonia). We approach each project on a case-by-case basis when refrigerant choice is selected.

Superior Environmental and Operational Performance
The ALTA Expert system has a far lower refrigerant leak rate than traditional light industrial synthetic systems, significantly reducing actual greenhouse gas emissions. Additionally, it consumes less energy compared to central plant ammonia and CO₂ systems—particularly in hot inland California climates, where CO₂ systems face severe energy penalties.

Water Conservation and Safety Benefits
Unlike central ammonia or evaporative-cooled systems, ALTA Expert is air-cooled and requires no water. This is a critical advantage in California, where water is an increasingly scarce resource. Furthermore, the system uses a non-toxic refrigerant, which is inherently safer for people than ammonia.

Lower Long-Term Operating Costs
Over a 15-year life cycle, ALTA Expert offers substantially lower total costs—including energy, water, maintenance, and compliance costs—than comparable ammonia or CO₂ systems. This efficiency directly supports the affordability and resilience of California’s food supply chain.

Reliability and Food Security
The ALTA Expert system requires significantly less maintenance than ammonia or CO₂ systems and has demonstrated higher reliability. Greater uptime means reduced spoilage of perishable foods, enhancing food security and reducing waste.

For these reasons, I respectfully urge CARB to grant ALTA Refrigeration’s variance request. Doing so will preserve a safe, efficient, and environmentally responsible refrigeration technology that aligns with California’s broader goals of sustainability, resource conservation, and food security.