Operators of Stationary Refrigeration Systems are Subject to New California Air Regulations

As of January 1, 2011, owners and operators of stationary refrigeration systems (other than air conditioners) in California may be subject to a new California Air Resources Board ("CARB") regulation in addition to EPA's regulation. Businesses in the Los Angeles Area may be subject to new rule for air conditioners and a revised rule for stationary refrigeration systems adopted by the South Coast Air Quality Management District ("SCAQMD"). The CARB and SCAQMD regulations apply to systems with 50 or more pounds of "high global warming" ("high-GWP") refrigerants – defined as a chlorofluorocarbon, a hydrochlorofluorocarbon, a hydrofluorocarbon, a perfluorocarbon, a blend with a global warming potential of 150 (as designated by the Intergovernmental Panel on Climate Change), or any ozone depletion substance designated by EPA.

Some of the requirements of the CARB regulations are phased in over time for systems of various sizes. Here is a summary of the key requirements of the CARB regulation. EPA regulations, which apply only to ozone depletion substances, and the two SCAQMD rules, which apply to same high GWP refrigerants as the CARB regulation, have additional requirements which are not discussed in this legal alert.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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