California Global Warming Solutions Act (AB 32): Early actions for refrigerant gas management

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How to stay ahead and address the early action requirements for Stationary Equipment Refrigerant Management to be included in updates to AB 32.

The California Global Warming Solutions Act (AB 32), first passed in 2006 with additional early actions taking effect in 2010, is a broad and comprehensive directive with the goal of reducing greenhouse gasses (GHGs) by approximately 25% by the year 2020. This goal is derived from the increase of greenhouse gasses in California since 1990. The objective of these early actions and amendments to AB 32 is to eliminate emission sources of GHGs and reduce overall emissions to 1990 levels.

As part of the California Global Warming Solutions Act (AB 32) the Air Resources Board (ARB) has approved an early action measure to reduce high-global warming potential (GWP) greenhouse gas (GHGs) emissions by establishing new legislation and defining requirements related to improved monitoring of AC/HVAC systems, enforcement of regulations, reporting of refrigerant usage, and recovery, recycling, or destruction of high-GWP refrigerant gases.

The greenhouse gasses (GHGs) as defined by the California's AB 32 are identical to those gasses identified in the Kyoto Protocol. These gases are already being regulated, monitored, and managed by many other countries around the World. In addition to carbon dioxide (CO2), which is the most widely known GHG, the following gasses are also defined as GHGs with high global warming potential (GWP) carbon equivalent emissions by the AB 32 legislation:

* Methane (CH4): a byproduct of waste decomposition, and natural geological phenomena; the majority of methane is derived from natural gas drilling.

* Nitrous Oxide (N2O): a pollutant created by industrial processes, motor vehicle exhaust, and industrial air pollutants reacting with the atmosphere; similar to methane (CH4), nitrous oxide (N2O) is often attributed to agriculture and waste disposal.

* Sulfur Hexafluoride (SF6): a gas used for various electrical applications, including gas insulated switchgear. Sulfur Hexafluoride is also used for experimental applications.

* Perfluorocarbons (PFCs) and Hydrochlorofluorocarbons (HCFCs): a collection of commonly used refrigerant and aerosol gasses with a wide variety of other commercial applications. CFCs and HCFCs are considered Ozone Depleting Substances (ODSs), as defined in title VI of the US Clean Air Act (Section 608).

The Stationary Equipment Refrigerant Management Program developed by California's Air Resources Board (CARB) is a protocol and detailed requirements for the management of new or existing AC/HVAC systems containing refrigerant gases. The refrigerant management programs details requirements for automated monitoring of systems, detailed usage and service book keeping, and the credentials to manage related to service technicians and their recovery equipment.

The proposed Stationary Equipment Refrigerant Management Program, which integrates two AB 32 early action measures, addresses the detailed monitoring and management of the PFCs and HCFCs noted above and includes tracking requirements for new and existing commercial and industrial refrigeration systems. In draft form today with implementation by January 2010, the refrigerant management program will require leak monitoring, tracking, and reporting of warming potential (GWP) refrigerants. First phase, roll-out is expected to target AC/HVAC systems containing 2,000 pounds or more of refrigerant gas.

CARB is charged with the monitoring GHGs and high GWP gasses, as well and the eventual development and enforcement of specific and quantitative new regulations covering carbon related emissions which refrigerant management with the tracking, reporting, cylinder management, and gas recovery for stationary refrigerant and air conditioning (AC) systems all becoming key integral parts.

California's early action protocols may include additional fines or fees related to missing refrigerant usage records, unaccounted refrigerant gas inventory, or non-compliance with refrigerant tracking reports. The California Air Resources Board (CARB) is an extension of the EPA and works to monitor and enforce the US Clean Air Act. Section 608 of the Air Act regulates refrigerant gas usage, leaks, recovery, and annual reporting.

The overall intent of CARB's strategy is to monitor and reduce the introduction of man-made GHGs and high GWP gasses into the atmosphere, as called for in the California Global Warming Solutions ACT (AB 32) in effect since 2006 with tighter controls, monitoring, and overall regulations becoming enforceable by early 2010.

Refrigerant gas monitoring, tracking, and management are important business planning considerations. Just like organizations manage assets, like a delivery truck, the consequences the release of high GWP gases, such as refrigerant gases, must be consider. Refrigerants cost money, harm the ozone and environment, and are subject to mandatory carbon emissions reporting. As organizations with AC/HVAC systems containing refrigerant gas of 50 pounds or more will soon find out, the effective monitoring, management of data, and systematic reporting of refrigerant usage will be key to business success in our emerging carbon economy.

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