Comment Log Display

November 25, 2008

To the Members of the California Air Resources Board: 

The employees of Interdynamics, Inc., a U.S. manufacturer of
products for consumer Do-It-Yourself maintenance and repair of
automobile air-conditioning systems respectfully submit the
following comments relating to the Revised Draft AB 32 Scoping
Plan.

Interdynamics is a leading member of the Automotive Refrigeration
Products Institute (ARPI) and a driving force in the mobile
refrigeration industry, with a track record of environmental and
social responsibility.  Since 1992, we have supported reduced use
and replacement of ozone depleting refrigerants such as R-12.  ARPI
members designed the unique can and fittings for R-134a and other
SNAP approved, non-CFC refrigerants.  We have also leveraged
innovation to mitigate the environmental impact of our products by
improving our packaging and inventing self-sealing dispensing
valves.  

Our company and trade groups have been working cooperatively for
the past two years with the ARB’s Research Division to craft
proactive, effective and affordable solutions to mitigate climate
change impacts associated with our consumer products.  Our work
with staff will directly yield a workable AB32 regulation,
providing real emissions reductions and, at the same time, not
disadvantaging low income Californians.     

We are proud to have set a cooperative example for other industry
groups to follow and look forward to further supporting Alberto
Ayala, Richard Corey and Tao Huai’s Research Division team at our
upcoming January 22, 2009 Early Action Board hearing.

But our work has not been easy and will not have been achieved
without significant cost.  Our alternative measures plan includes:

•	An industry-first, self-administered small-container
return/recovery/recycling program with economic incentives for
consumers to return used containers for processing.

•	Development and commercialization of an industry-first
self-sealing valve to mitigate accidental and installation
emissions of refrigerant from small containers. 

•	A California-specific consumer education campaign, including
print and website.

We ask you to consider the costs and efforts expended by our
company and industry in being amongst the first AB32 “cooperators”.
 Consider the potential punitive effects the Scoping Plan’s
proposed “upstream fees” could layer on top of the already
significant costs borne by the first industry to voluntarily
participate in a self-regulating exercise.  

In early 2008, Interdynamics and ARPI had discussed with CARB
staff the possibility of a fee in lieu of the regulation but were
told that emissions reductions were the primary objective of AB32
measures. Now, on the eve of adoption of the regulation the
prospect of a fee is raised, noting that an upstream fee would
ensure that the climate impact of these substances is reflected in
the total cost of the product.  Since the fee will follow the
regulation, the “total cost” of the products will have already
increased exponentially.

We disagree with the fee on top of our newly-promulgated
cooperative regulation and have grave concerns that such a fee
penalizes us for our proactive approach.  

Additionally, the Board and we recognize that incremental
regulatory costs and fees are ultimately passed to consumers
through higher product prices.  This may precipitate a tipping
point to render these products uneconomic, constituting a de facto
product ban, thus ensuring an adverse impact on minorities and
those on fixed incomes.  This is contrary to the original
objectives we and CARB staff had set out in the development of
alternative regulations on the servicing of vehicle air
conditioners by non-professionals.  

In conclusion, please know that we support a balanced,
cost-effective plan to reduce greenhouse gas emissions. 
Interdynamics and ARPI are already playing a meaningful role in
helping the state meet its policy goals for reducing green house
gas emissions in California through participation in the early
action rulemaking on Reduction of Refrigerant Emissions from
Non-Professional Servicing and will continue its work with CARB
staff on the rulemaking.  We continue to stand ready, with the
Board, to implement a regulatory scheme aimed at reducing
greenhouse gas emissions while not devastating our industry.  We
want to be part of the solution, but not if the price is our
businesses.  

Thank you in advance for your attention, consideration and
support.  We welcome further discussing this issue with you and
invite you to contact me for further information about this issue.

Sincerely,

Mitchell Bolinsky
Director of Marketing
Interdynamics, Inc.
560 White Plains Road
Tarrytown, NY  10591
mbolinsky@id-usa.com
office:  914/798-7932
fax:     914/798-7971