The Environmental Investigation Agency (EIA) and International Institute for Ammonia Refrigeration (IIAR) request your support to urge the California Air Resources Board to enact a regulation ensuring adoption of climate-friendly refrigeration in ice rinks in California and around the world. Full text of the letter appears below. Please sign on by submitting your information by Tuesday, September 8th.
Re: <150 GWP Refrigerants for Ice Rink Refrigeration Systems
Dear Chair Nichols,
The Environmental Investigation Agency (EIA) and International Institute of Ammonia Refrigeration (IIAR) submit this letter, with the support of companies and organizations listed below. Together, we support enacting pragmatic regulations to reduce emissions of hydrofluorocarbons (HFCs) and encourage low-global warming potential (GWP) refrigerants in ice rinks and other stationary refrigeration equipment.
Our organizations share a concern that a 750 GWP threshold for new ice rink refrigeration systems outlined in the current proposed HFC rulemaking would lead to unnecessary displacement of existing ice rinks using refrigerant with zero climate impact by systems using HFC-blend refrigerants with GWPs above 600 and lower energy efficiency. This would result in an emissions increase from ice rinks and lock-in higher GWP refrigerants for the 25-year lifetime of new equipment, making it more difficult to meet the state’s 2030 HFC reduction target and net zero emission goals. We therefore strongly support a revision of the proposed HFC regulation to reduce the GWP prohibition from 750 down to under 150 for new refrigeration systems in new and existing ice rinks. This is consistent with the proposed HFC regulation’s treatment of other types of stationary refrigeration systems where <150 GWP alternatives are already widely in use. California’s policies as a climate leader on reducing HFC emissions hold great importance to setting precedent across the United States and around the world. This proposed regulation marks the first of its kind globally that specifically targets a GWP threshold for refrigerants in ice rink refrigeration systems and as such would send a strong signal on the direction of the global market for ice rinks.
Two existing refrigerants under 150 GWP are widely available and sufficient to meet the needs for new equipment in both new and existing ice rinks: ammonia and CO2. Ammonia, with a zero GWP, has been used in the vast majority of ice rinks in California and around the world. More than 80% of known ice rinks in California use ammonia refrigerant. CO2, with a GWP of 1, is also growing in use. Over the past 10 years, over 75 CO2 ice rink systems have been installed in North America. Ammonia or CO2 systems for ice rinks have a first cost that is often comparable to systems utilizing HFC alternatives, and deliver energy benefits that further reduce the total cost of ownership. Under 150 GWP HFO-based refrigerants have also been identified that could be used in future.
As follows are specific points supporting the technical feasibility, cost-effectiveness, and climate benefits of enacting a 150 GWP threshold for ice rinks:
a. Lower charge systems using up to 80% less refrigerant over traditional systems
b. Water dispersion tanks – neutralize ammonia refrigerant
c. Transfer systems – a system that senses refrigerant leaks and automatically pumps refrigerant to a secure vessel
It must be noted that if arguments are still made about safety as a concern for ammonia, two of three known safety incidents involving fatalities from ice rinks were from systems using synthetic refrigerants with similar properties to R-513a.
Based on the aforementioned points, we strongly urge the California Air Resources Board to limit refrigerants in new ice rink systems to those with GWP less than 150. The overwhelming majority of ice rinks already use refrigerants with GWP of 1 or less. It would, hence, be a major step backwards for California to enact a law that allows replacement of climate-friendly ice rinks with >600 GWP refrigerants. This would increase HFC emissions in California and hold the state back in meeting its ambitious climate goals.
Thank you for considering and we would be happy to discuss any points in this letter in further detail upon request.
Marc Chasserot, CEO, shecco America Inc
Wynand Groenewald, Consultant, Independent
David Schaefer, Chief Engineer, Bassett Mechanical
Michael Helme, Lead Volunteer, New Yorkers for Cool Refrigerant Management
Danielle Wright, Executive Director, North American Sustainable Refrigeration Council (NASRC)
Stefan Jensen, Managing Director, Scantec Refrigeration Technologies Pry. Ltd.
Kent Stuckey, Owner, Kore Mechanical Inc.
Caleb Nelson, VP - Professional Engineer, Azane, Inc.
Andrew Epp, President, A. Epp Engineering Inc.
Tomohisa Hashimoto, President, Mayekawa Canada Inc.
Kurt Liebendorfer, Vice President, Evapco
Mark Reinert, Parks and Facilities Manager, Town of Petawawa, Ontario Canada
Doug Scott, Sales Manager Industrial Products, J&E Hall International
Jeff Claytonj, Supervisor of Facilities, Town of Whitby
Kelly Sasaki, CEO, Mayekawa USA Inc.
Ernest Shongwe, Director, Imphangela Investments
Brad Watson, Manager, Municipality of Centre Hastings
Barry Ouellette, Supervisor of Arenas, City of Windsor (WFCU Centre)
Santhosh Kumar, President, Hansen Technologies
Douglas LaPointe, Supervisor of Operations, Town of St. Marys
Dan Mikel, Facility Maintenance Coordinator, Township of Wellesley
Brad Tuckwell, Facilities Supervisor, Municipality of Chatham- Kent
Randy Watt, Director of Operations, Capital Sports Management Inc. (CSMI)
Brad Goddard, President, Ultimate Fabrication Inc.
Michael Riese, Business Development Manager, Cold Logic Pty Ltd
Peter Yufer, Presidente, Cámara Chilena de Refrigeración y Climatización AG
Giorgio Magnani, Gerente, Intercal S.A.
Thomas Richgels, Director of Sales - USA, RefPlus Inc
Marc Andre Lesmerises, President, Carnot Refrigeration
Jonathan Reuther, Super, Cavanagh Sensplex
Dave Malinauskas, President, CIMCO Refrigeration
Roy Olsen, Refrigeration Engineer, Lee Technologies
Jean-Louis Picouet, Director R&D engineering, Vilter Manufacturing
Oreste Frontaloni, Ingeniero Mecanico, ASEMFI SA
Gillian Henderson, Director, Climate Challenge Network
Miguel Garrido, Executive President, Guentner Group
Francois-Daniel Hébert, Business Development, Bleuets Sauvages du Québec/Usine de congélation de St-Bruno
Pierre Drolet, Corp. eng. manager, Lactalis Canada
Greg Dean, Vice President, Zamboni Company Limited
Jeffrey Gingras, President, Systems LMP
Brian Davis, Senior Director, Danfoss AAIM Controls
David Loverock, Vice President, Jet IceLtd
Bruce Landon, General Manager, Amelia Park Arena
Geoff Crane, Manager, Merritton Centennial Arena
Frank Kruppe, President, Cyrus Shank Company
Jason Lavallee, Recreation supervisor, City of cornwall
Stephen Ruggiero, Director, Essex County Codey Arena
Paul Scarafile, Director, Armstrong Fluid Technology
James Harnett, Owner, EIS RINKS, LLC
Ian Welle, Principal Engineer, Polar Engineering
Kevin Rostkowski, Vice President, Titan Mechanical & Piping Inc.
Omar Morillas, Inside Sales Manager, VJ Pamensky
Jean Despaux, President, Delsle, Despaux and associates inc
Darcy Daymen, President, Dayman Electric
Chris Brown, Manager of Facilities, Town of Greater Napane
Bryan Beitler, Vice President, CoolSys
Greg Klidonas, Senior Vice President, GEA Systems North America LLC
Kenneth Johnson, Senior Engineer, Innovative Refrigeration
David Westphal, US Distribution - Facilities Manager, Gordon Food Service
Nathan Cunningham, Design Engineer, Thermocarb Ltd
Renny Rantucci, President, Thermo Design
Mark Hampel, Industrial Project Manager, Fraser Valley Refrigeration Ltd.
Peter Jordan, Senior Principle Engineer, MBD Risk Management Services, Inc.
Bruce Nelson, President, Colmac Coil Manufacturing Inc.
Jason Mueske, Director of Sales, CTI
Eduardo Alcazar, Electromechanical Engineer, FRIMONT SA
Moisés Ventocilla, General Manager, Inema
Nick Nechay, President, Independent Refrigeration Service
Chris Herzog, Chief Engineer, IREP
Chris Dreher, President, Southern Equipment Sales Co.
Liz Mangelsdorf, Managing Director, Ice Sports Industry
Dean Motes, President, Refrigeration Systems Construction & Service Co
Ronald Strong, President, R.H. Strong Refrigeration Design Inc.
Loney Larson, Owner, Wasatch Refrigeration
Courtney Miller, PSM/RMP Administrator, House of Flavors
Kevin Henry, Facilities Superintendent, Municipality of North Grenville
Art Sutherland, President, Accent Refrigeration Systems
Greg Boyce, Chief Operator, Chapman's Ice Cream
Jeanna Emmons, President/Owner, PSM RMP Solutions
Alexander Taran, VP, Precision Refrigeration
Dennis Bushy, Arena Manager, Moorhead Youth Hockey
Armando Guerra, HVAC Supervisor, Center Operating Company
Chris Savage, VP of Compliance and IT, Carlson & Stewart Refrigeration, Inc.
Jim Patin, Operations Manager, Lou & Gib Reese Ice Arena
Jeff Coulter, Supervisor of Operations, Kitchener Auditorium
Ira Parks, Chief Engineer, St. Margaret's Center, Tantallon, N.S
Alexandre Gobeil, Building Manager & Chief Engineer, True North Sports and Entertainement
Ronald Matwee, President, Normal Limited
Shane Rogers, Manager, GFL- Newport Recreation Centre
Todd Taylor, Principal, Piranha, Inc.
William Bisset, President, Keystone Engineering Solutions, Inc.
Ryan Hagen, Founder, Crowdsourcing Sustainability
Adnan Ayub, President, Isotherm, Inc.
Stuart Poteri, Manager, Centennial arena
Guy Evon, CTC Group Ltd
Risto Ciconkov, Professor, Skopje University, FME
Kevin Bennett, Facility Manager, Town of Kentville
Jesper Olsen, Global Application Expert, Industrial Refrigeration, Alfa Laval Lund AB
Paul Anderson, Senior Project Manager, Cool Air Mechanical
Chris Flanagan, Project Manager, City of New Haven
Jeff Baker, Operations Manager, Cole Harbour Place
Tarlea Gratiela, President, AGFR
Donald Rodner, President, Donald C. Rodner, Inc
Giovanni Dorin, CEO, Officine Mario Dorin Spa
James Shou, Director, JS Refrigeration Engineering Inc.
Ken Jewer, Senior Partner, Jewer Bailey Consultants Limited
Paul Michael, Manager of Recreation Services, Township of Selwyn
Donald Norris, Chief Engineer, Quin Sea Fisheries
Mike Peterson, VP of Sales Engineering, Climate by Design International, Inc.
Robert Warr, Director of Recreation, Town of Marystown
Chris Rooney, GM, Feildian Gardens, Northpoint Sports Ltd.
Ian Flyn, Recreation Director, Town of Bay Roberts
Lester Shantz, Industry Director, Refrigeration, Air, Conditioning, Heating Association (RAHA) - Alberta
Christian Ali Munoz Duran, Direction, ABE
Benoit Beauchamp, CEO, Systèmes Énergie TST inc
Jörgen Rogstam, Managing Director, EKA
Trevor Hegg, Vice President - Product Development, EVAPCO, INC.
Lin Lan, Engineer, Lennox
Paul Hawkins, Founder, In There Apps Pty Ltd