IIAR

New York has introduced the Cap-and-Invest Program to help the state achieve the greenhouse gas emission reduction requirements outlined in the State’s Climate Leadership and Community Protection Act.

The program would set an annual cap on greenhouse gas emissions, which declines over time. A portion of the proceeds from the purchase of emissions allowances would fund the Climate Investment Account, which would support the transition to a less carbon-intensive economy.

“By providing funding to support the transition to low global warming potential (GWP) refrigerants, the Cap-and-Invest Program has the potential to accelerate the adoption of natural refrigerants statewide,” said Danielle Wright, executive director of the North American Sustainable Refrigeration Council. “The funds would help New York State businesses get ahead of regulatory pressures and achieve corporate climate commitments by offsetting the cost of transitioning to future-proof natural refrigerants.”

Low-carbon buildings have been identified as a proposed sectoral investment area for the Climate Investment Account. “That sector would include assistance to food retail stores located in disadvantaged communities to transition to low GWP refrigerants,” Wright said. “This would open up opportunities for those funds to also support the transition for industrial and cold storage facilities in the future.”

In a letter supporting the initiative, Gary Schrift, IIAR’s president, wrote that the necessary standards, training and expertise are readily available for a safe and reliable transition to natural refrigerants and away from high global warming HFC refrigerants in both cooling and heat pump systems.

While HFCs were once considered a suitable replacement for ozone-depleting substances, Schrift wrote that they are super-polluting greenhouse gases and one of the most potent drivers of climate change. “Pound for pound, HFCs trap thousands of times more heat in the atmosphere than CO2,” he explained.

Classified as short-lived climate pollutants (SLCPs), HFCs have a disproportionate impact on warming in the near term, making their mitigation significantly more urgent than other GHGs. “In New York State, HFCs make up 14% of all building sector emissions, making HFC emissions reduction one of the most powerful tools to achieve New York’s mandate to reduce greenhouse gas emissions 40% by 2030 and 85% by 2050,” Schrift wrote.

However, transitioning from existing HFC based refrigeration systems requires the full replacement of HFC-based refrigeration equipment with natural refrigerant equipment, representing an enormous cost to owners and operators. This cost burden is particularly challenging for small and independent food retailers and food retailers operating in disadvantaged communities. “These businesses often lack the financial resources to transition their stores, risking increased costs to consumers, store closures, and the emergence of food deserts,” Schrift said in the letter, adding that once businesses have transitioned to natural refrigerants, which are future-proof, systems will be functional for years.

Funding support is a critical solution to unlock the tremendous emissions savings potential of transitioning existing refrigeration facilities to low-GWP refrigerants. However, Wright said lowcarbon buildings are one of many proposed sectoral investment areas for the Climate Investment Account, which means it is competing for funds.

“At this stage, letters of support are one of the most impactful opportunities to underscore the importance of incorporating refrigeration into the Cap-and-Invest Program,” Wright said. “DEC and NYSERDA are still accepting comments on the program. I would encourage all stakeholders from the refrigeration industry to submit a comment of support that highlights the need for investment in the transition to low-GWP refrigerants.”

Comments can be submitted at https:// capandinvest.ny.gov/. Public input will inform the development of a regulatory proposal. Once that proposal is issued, there will be another public comment period before the final regulation is issued.