TITLE 17. CALIFORNIA AIR RESOURCES BOARD 
NOTICE O F PUBLIC HEARING TO CONSIDER PROPOSED AMENDMENTS TO THE 
REGULATION FOR REDUCING SULFUR HEXAFLUORIDE EMISSIONS FROM GAS 
INSULATED SWITCHGEAR 
The California Air Resources Board ( CARB or Board) will conduct a public hearing at 
the date and time noted below to consider the proposed amendments t o the Regulation 
for Reducing Sulfur Hexafluoride Emissions from Gas Insulated Switchgear (SF 6
Regulation or Regulation). 
DATE: 
TIME: September 24, 2020 
12:00 P.M. 
Please see the Public Agenda which will be posted ten days befo re the 
September 24 , 2020 , Board Meetin g for any appropria te direction regarding a possible 
remote-only Board Meeting . If the meeting is to be held in person , it will be held at the 
California Air Resources Boa rd, Byron Sher Auditorium , 1001 I Street, Sacramento, 
California 95814. 
This item will b e considered at a meeting of the Board, which will commence at 
12:00 p.m., September 24, 2020, and may continue at 8:30 a.m., on 
September 25 , 2020 . Please consult the agend a for the hearing , which will be available 
at leas t ten day s befor e September 24 , 2020 , to determine the day on which this item 
will be considered. 
WRITTEN COMMENT PERIOD AND SUBMITTAL OF COMMENTS 
Intereste d members o f the public may presen t commen ts orally or in writing at the hearing 
and may provide commen ts by postal mail or by electronic submittal before th e hearing. 
The public commen t perio d for this regulatory action will beg in on July 24, 2020 . Written 
commen ts no t physically submitted at the hearing must be submitted on or afte r July 24, 
2020 and receive d no la ter than Septembe r 22, 2020 . CAR B reque sts tha t whe n possible, 
written and email statemen ts be filed at least 10 days before the hearing to give CARB staff 
and Board members additional time to consider each comment . The Board also encourages 
members of the public to bring to the attention of staff in advance of the hearing any 
suggestion s for modificatio n of the proposed regulatory action . Commen ts submitted in 
advance of the hearing must be addressed to one of the following: 
Postal mail: Clerk s’ Office , California Air Resources Board 
1001 I Street, Sacramento, California 95814 
Electronic submittal: http://www.arb.ca.gov/lispub/comm/bclist.php 
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 Please note that under the California Public Records Act (Gov. Code, § 6250 et seq.), 
your written and oral comments, attachments, and associated contact information (e.g., 
your address, phone, em ail, etc.) become part of the public record and can be released 
to the public upon request. 
Additionally, the Board requests but does not require that persons who submit written 
comments to the Board reference the title of the proposal in their comments to facilitate 
review. 
AUTHORITY AND REFERENCE 
This regulatory action is proposed under the authority granted in California Health and 
Safety Code, sections 38510, 38560, 38580, 39600, 39601 , 41510, 41511 and 41513 . 
This action is proposed to implement, interpret, and make specific sections 38560, 
38580, 39600, 39601, 41510, 41511 and 41513. 
INFORMATIVE DIGEST OF PROPOSED ACTION AND POLICY STATEMENT 
OVERVIEW (GOV . CODE, § 11346.5 , subd. (a)(3) ) 
Sections Affected : Proposed amendment to California Code of Regulations, title 17, 
section s 95350, 95351, 95352, 95353, 95354, 95355, 95356, 95357, 95358, and 95359 . 
Proposed adoption of California Code of Regulation, title 17, sections 95354.1, 95357.1 
and 95359.1. 
Docume nts Incorporated by Reference ( Cal. Code Regs., tit. 1, § 20, subd. (c)(3)): 
United States Environmental Protection Agency. 2014. Mandatory Reporting of 
Greenhouse Gases; Final Rule. Title 40 Code of Federal Regulations, Part 98, 
Subpart A, Table A -1. December 11, 2014. https://www.govinfo.gov/content/pkg/FR -
2014 -12-11/pdf/2014 -28444.pdf , Section 95351(a). 
Background and Effect of the Proposed Regulator y Action : 
CARB staff is proposing amendments to the Regulation for Reducing Sulfur 
Hexafluoride Emissions from Gas Insulated Switchgear (Regulation, title 17, California 
Code of Regulations, sections 95350 et. seq.).  The Regulation was originally enacted 
as an early action measure pursuant to the California Global Warming Solutions Act of 
2006 (Assembly Bill 32 or AB 32; Chapter 488, Statutes of 2006 ) to reduce SF 6 
emissions from the electricity sector’s transmission and d istribution system .  AB 32 
established an initial goal for California to reduce statewide greenhouse gas (GHG ) 
emissions to 1990 levels by 2020 and to maintain and continue GHG emissions 
reductions beyond 2020 . The current Regulation requires owners of ga s-insulated 
switchgear (GIS) to report the following annually: SF 6 emissions, an inventory of their 
GIS that use SF 6 as an insulating gas, information related to containers that store SF 6 
gas, and transfers of SF 6 into or out of GIS. The proposed amendmen ts would also 
change the term “GIS” to “gas -insulated equipment” (GIE) to clarify that more devices 
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 beyond switchgear are covered by the Regulation. This terminology change would not 
affect the types of devices covered under the Regulation, and the term G IE will be used 
throughout this document. 
SF6 is an extremely powerful and long -lived GHG. The 100 -year global warming 
potential (GWP) of SF6, which indicates its heat-absorbing ability relative to that of 
carbon dioxide (CO 2) over a 100 -year period , is 22,800, making it the most potent of the 
six main GHGs. Because of its extremely high GWP, small reductions in SF 6 emissions 
can have a large impact on reducing GHG emissions , which are the main driver s of 
climate change . The current Regulation requ ires reductions of SF 6 emissions from GIS 
over time , setting an annual emission rate limit that each GI E owner may not exceed. 
The maximum allowable emission rate started at ten percent in 2011, and has 
decreased one percent per year since then. In the a bsence of proposed changes to the 
Regulation, in 2020, the limit would reach one percent and would remain at that level 
going forward . Data reported under the Regulation show that statewide SF 6 capacity is 
growing by one to five percent per year, and proj ections provided by GIE owners 
indicate that this trend will continue into the future. Because , under the current 
Regulation , the emissions limit would remain equivalent to one percent of annual 
capacity, as capacity grows, so too would expected emissions. 
The Legislature reaffirmed California’s commitment to take further action against climate 
change by adopting Senate Bill ( SB) 32 (Chapter 250, Statutes of 2016) , which further 
directs the State to reduce its GHG emissions to at leas t 40 percent below the 1990 
level by 2030. In 2019, CARB initiated a process to explore achievable paths toward 
carbon neutrality and is working to implement direction provided in Board Resolution 
17-46 to evaluate and explore opportunities to achieve add itional significant cuts in 
GHG emissions from all sources. 
Considerable progress has been made in the past decade to develop non -SF6 GIE; 
across the voltage spectrum , manufacturers now either offer market -ready non -SF6 GIE 
or have development plans in the foreseeable future. Despite this progress, inventory 
data reported under the Regulation show that SF6 capacity in the State has been 
growing, meaning that non -SF6 technologies have not yet been widely adopted, and 
staff projects that SF 6 capacity will continue growing well into the future. This indicates 
that a regulatory change is necessary to drive the transition away from the use of SF6 in 
GIE. 
In response to California’s aggressive climate goals and the increasing availability of 
technology that does not use SF 6, CARB staff is proposing to amend the Regulation to 
clarify regulatory coverage, expand the scope to include other GHGs beyond SF 6, drive 
GHG emission s reductions, accelerate the transition to technologies that do not use 
SF6, improve the ability of equipment owners with relatively small amounts of SF 6 to 
comply with the Regulation, specify reporting and accounting procedures to increase 
reporting accuracy and facilitate tracking of GHGs covered under the proposed 
Regulation , and improve CARB staff’s ability to verify reported data. 
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 Due to the expansion in the Regulation’s scope to include other GHGs beyond SF 6, and 
the terminology change from GIS to GIE, CARB staff is proposing to change the name 
of the Regulation to the “Regulation for Reducing Greenhouse Gas Emissions from Gas 
Insulated Equipment.” If enacted, the amendments will go into effect following the 
schedule described in the Proposed Regulation Order. Some changes will become 
effective the day the Regulation i s finalized and will impact each GIE owner’s data year1 
2020 annual report (due June 1, 2021).  Other changes that require new data to be 
collected will become effective January 1, 2021 , or after. 
CARB may also consider other changes to the sections affec ted, as listed on page two 
of this notice, during the course of this rulemaking process. 
Objectives and Benefits of the Proposed Regulatory Action: 
The proposed Regulation would establish a timeline for phasing out acquisition of SF 6 
GIE in California that would take effect in stages between 2025 and 2033 . The 
proposed amendments would reduce total GHG emissions from GIE , improve the abilit y 
of small GIE owners to comply, improve accuracy in reported emissions , and improve 
CARB staff’s ability to verify reported data . The proposed Regulation has been 
developed with the help of a robust informal public process, which included three 
publicly noticed workshops and one publicly noticed working group meeting from 
November 2017 through August 2019. The proposed amendments would: 
 Expand the scope of the Regulation to cover emissions of all insulating gases with a 
global warming potential ( GWP ) greater than one, and clarify terminology related to 
which GIE are covered by the Regulation; 
 Establish a timeline for phasing out acquisition of SF 6 GIE in California and create 
an incentive to encourage GIE owners to acquire non-SF6 GIE prior to the phase -
out; 
 Establish a process through which GIE owners could be granted a pha se-out 
exemption to allow them to acquire SF 6 GIE after the phase -out, but only when 
certain conditions are met ; 
 Establish alternative emissions limit s for small -capacity GIE owners to improve their 
ability to comply with the Regulation, a ssign each GIE ow ner an emission s limit in 
metric tons of CO 2 equivalent ( MTCO 2e) (as opposed to the current SF6-specific 
emission rate limit ), and establish methods to minimize the growth of the emissions 
limit over time; and 
 Revise reporting requirements to improve reporting accuracy, clarify requirements, 
close gaps in accounting for SF 6 and other covered insulated gases, and improve 
CARB staff’s ability to verify reported data. 
1 “Data year” means the calendar year for which a GIE owner must submit an annual GHG emissions 
data report. 
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     Staff analyzed the impacts of the amendments, in particular the installation of non -SF6 
GIE due to the phase -out, through 2036, the year after which all requirements in the 
proposed Regulation would come into effect. Absent th e proposed amendments, staff 
estimates that SF 6 emissions in 2036 would be 364,000 MTCO 2e, a significant increase 
relative to estimated emissions of 286,000 MTCO 2e in 2024, the year before the phase -
out begins. By contrast, t he proposed Regulation will reduce the 2036 emissions level 
to be approximately 283,000 MTCO 2e.  Cumulative emission s reductions for the period 
2020 to 2036 will be approximately 391,000 MTCO 2e. Because GIE lasts 
approximately 40 years, though, emissions reductions from non -SF6 GIE acquired 
between 2025 and 2036 will continue through 2075, resulting in cumulative emissions 
reductions of approxima tely 3,143,000 MTCO 2e. 
Each of these proposed changes to the Regulation are explained here in further detail. 
Expanding Scope and Clarifying Coverage of the Regulation 
The purpose of the proposed Regulation is to further reduce emissions by phasing o ut 
SF6 use so that GIE owners will transition to use of non -SF6 GIE, some of which may 
utilize GHGs other than SF 6 that have substantially lower GWPs than SF 6. The 
introduction of insulating gases that contain a GHG other than SF 6 necessitates 
expanding t he scope of the Regulation to include GHGs with a GWP greater than one . 
Staff proposes only to require the reporting and regulatory coverage of insulating gases 
with a GWP greater than one because the amount of GHGs with GWPs less than or 
equal to one that would be used in GIE would have a relatively small potential impact to 
global warming (in MTCO 2e).  This is because the volume of ins ulating gas with a GWP 
less than or equal to one contained in GIE through the State is anticipated to be very 
low. If all SF 6 in active, non -hermetically sealed GIE in California at present were 
converted to CO 2, the amount of CO 2 in GIE statewide would be about 1,000 MTCO 2e. 
Annual CO 2 emissions in this case would be roughly ten metric tons (assuming a one-
percent leak rate as required by the Regulation), which is roughly equivalent to the 
emissions from driving two passenger vehicles for a year.2 
Throughout the proposed Regulation and this document, the term “SF 6” was in many 
places replaced with “insulating gas with a GWP greater than one” or “covered 
insulating gas,” except in cases where specific references to SF 6 are still needed. 
Coverage of these alternative gases in the Regulation ensures continued tracking of 
GHGs from the operation of GIE in the state. It also facilitates recognition of the 
transition from SF 6 GIE to non -SF6 GIE. 
SF6 Phase -Out and Early Action Credit 
In Table 1 and Table 2 of the proposed Regulation, CARB staff proposes a schedule for 
the phase -out of the acquisition of new SF 6 GIE. The phase -out dates differ according 
2 U.S. EPA Greenhouse Gas Equivalencies Calculator: https:/ /www.epa.gov/energy/greenhouse -gas-
equivalencies -calculator . Last accessed November 20, 2019 . 
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      to voltage capacity, short -circuit current rating, and configuration (i.e., above or below 
ground). Non-SF6 GIE either do not contain a GHG or use insulating gas with a 
significantly lower GWP than SF 6, so the transition from SF 6 GIE to non -SF6 GIE will 
have the benefit of reducing GHG emissions. In developing the phase -out schedule, 
CARB staff consulted with more than ten manufacturers currently developing non -SF6 
GIE to learn when their products are expected be commercially available. Additionally, 
based on stakeholder comments about the amount of time their organizations generally 
require to ensure that new products are safe, reliable, and deployable, CARB staff 
included a three -year period between expected commercial availability and proposed 
phase -out date s. 
Because the phase -out dates would not begin until 2024 , and certain types of non -SF6 
GIE are available now, the proposed regulatory amendments also include an early 
action credit. The early action c redit would encourage GIE owner s to place 72.5 kV or 
greater non-SF6 circuit breakers into active service prior to the applicable phase -out 
date for those devices , which should lead to additional reductions in GHG emissions . 
The proposed credit is roughly equivalent to the amount of SF 6 in a comparable SF 6 
circuit breaker . 
SF6 Phase -Out Exemption Process 
As described above , CARB staff developed the phase -out schedule after discussing 
non-SF6 GIE availability dates with over ten manufacturers for over a year.  CARB staff, 
however, recognizes that , in some specific cases , GIE owners may need to install SF 6 
GIE after the corresponding phase -out date. 
Therefore, t he proposed Regulation adds a new exemption process that allows GIE 
owner s to acquire SF 6 GIE after the applicable phase -out date under the following 
conditions : when the GIE owner submits, and CARB approves, an SF 6 phase -out 
exemption request; when the SF 6 GIE device was present in the State for a prior data 
year; when the SF 6 GIE device was purchased prior to the applicable phase -out date 
(provided the SF 6 GIE device enters California no later than 24 months after the 
purchase date); or when the SF 6 GIE device is a replacement provided by the 
manufacturer under the terms of the manufacturer’ s warranty. 
To obtain a phase -out exemption, t he GIE owner must submit a phase -out exemption 
request to CARB that would explain and justify the need for the exemption. If the 
request is approved, the GIE owner could acquire the SF 6 GIE described in the request 
and install the SF 6 GIE in the location(s) described in the exemption request. 
Revisions to the Emission Rate Limit 
The proposed Regulation contains revisions that would change the allowed emissions 
levels for GIE owners with smaller capaciti es of SF 6 and other covered insulating gases. 
As explained below, this change will enable small -capacity GIE owners to comply with 
the Regulation . Further, the proposed Regulation transition s the basis for evaluating 
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 emissions compliance from an emis sion rate limit to an emissions limit measured in 
MTCO 2e. The emissions limit will be structured to support the phase -out of SF 6, 
incentivize adoption of non -SF6 GIE, and ensure continued emission s reductions 
despite the anticipated growth of GIE capacity in t his sector . 
a. Transition to an Annual Emissions Limit 
The proposed Regulation includes a new method for GIE owners to calculate their 
emissions limit in terms of MTCO 2e rather than percent of average system capacity. 
From 20203 through 2024, GIE owners with average system capacities of 10,000 
MTCO 2e or greater will have an emissions limit equivalent to one per cent of average 
system capacity (considering all insulating gases with a GWP greater than one), 
maintaining equivalency with the current Regulation. 
The proposed Regulation increases the emissions limits for the smallest GIE owners.  
CARB staff’s goal for the proposed Regulation was to set emission limits such that GIE 
owners of all sizes would be held to stringent but reasonable limits on emissions.  Given 
the difficulty in achieving a one -percent emission rate for GIE owners with average 
system capacities below 10,000 MTCO 2e, and the fact that these owners make up less 
than two percent of statewide SF 6 capacity, staff proposes a threshold of 10,000 
MTCO 2e, below which the emissions limit would be set at the equivalent of two percent 
of average system capacity from 2020 to 2034 , or 50 M TCO 2e, whichever is greater. 
While allowing these GIE owners to have higher GHG emissions limits than allowed 
under the current Regulation may seem to run contrary to the goal of reducing GHG 
emissions, setting an emissions limit that is too low for these GIE owners to comply with 
is an ineffective way t o reduce GHG emissions.  Setting a realistic target could help 
incentivize small -capacity GIE owners to reduce their emissions, where possible, to 
ensure compliance, which should be achievable under the revised limits . 
b. Establishing a Baseline to Incen tivize Adoption of Non -SF6 GIE and 
Emissions Limit Stepdown 
Because smaller capacities of SF 6 and other covered insulating gases can make 
compliance with the emissions limit more challenging , staff was concerned that 
establishing an emissions limit that is equivalent to one or two percent of active, non -
hermetically sealed system capacity could actually disincentivize the replacement of SF 6 
GIE with non -SF6 GIE. That is, GIE owners may keep and operate their SF 6 GIE longer 
to maintain a higher capacity level. To address this issue, the proposed Regulation 
includes a baseline approach which would “fix” average system capacity (that is, the 
GIE owner’s capacity against which emissions compliance is assessed) at a point in 
time , after which any re duction in actual SF6 capacity would not result in a 
commensurate reduction in average system capacity . 
3 For data year 2020 only, the emissions limit considers SF 6 only.  See the discussion in section III of this 
ISOR, Rationale for Section 95353(b)(1). 
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  An emissions limit with a fixed baseline would incentivize a GIE owner to replace SF 6 
GIE with non -SF6 GIE after the baseline is set because the implem entation of non-SF6 
GIE would decrease the actual amount of SF 6 in their system, which would reduce the 
risk of SF 6 emissions, without any corresponding decrease in average system capacity 
used to evaluate regulatory compliance . This transition from SF 6 GIE to non -SF6 GIE 
should result in additional reductions in GHG emissions. 
Because average system capacity will not decrease when SF 6 GIE are replaced with 
non-SF6 GIE, the equivalent allowed emission rate will effectively grow over time, 
making it easier to comply with the Regulation. To ensure that the Regulation remains 
equally ambitious over time, CARB staff propose s that, in 2035, each GIE owner’s 
emissions li mit will be reduced by five percent , and remain at that level going forward, to 
maintain an effective emission rate lim it near one or two percent. 
Changes to Required Procedures and Reported Elements 
Finally, the proposed Regulation contains revisions th at would change reporting 
requirements to improve reporting accuracy, clarify requirements, close gaps in 
accounting for SF 6 and other covered insulated gases, and improve CARB staff’s ab ility 
to verify reported data. 
Benefits of Proposed Amendments 
In total, the staff proposal achieves the following outcomes: 
 Establishes an SF6 phase -out schedule with unique dates for nine GIE categories, 
based on GIE voltage capacity, short -circuit current rating , and whether the GIE 
would be used above or below ground . The schedule is consistent with expected 
non-SF6 product availability from at least two manufacturers in each of those 
categories and the phase -out dates are set to be three years after this availability. 
These factors are responsive to stakeholder feedback that non -SF6 GIE must be 
available from more than one manufacturer and that GIE owners need 
approximately three years to familiarize themselves with the new GIE in advance of 
the phase -out dates . For non -SF6 GIE that are available today, CARB sta ff set the 
earliest phase -out date to be 2025 to accommodate the three -to five -year capital 
planning cycle that GIE owners indicated they undertake. 
 Includes an SF 6 phase -out exemption request process that offers GIE owners 
flexibility to acquire SF6 GIE after the phase -out when non-SF6 GIE are unavailable 
from at least two suppliers, and when available non -SF6 GIE either cannot meet the 
size requirements, cannot be used due to incompatibility with existing infrastructure, 
or are not suitable based on saf ety or reliability requirements. In response to 
stakeholder feedback, the exemption request process allow s for expedited approvals 
in the wake of a catastrophic failure affecting the GIE owner’s SF 6 or non -SF6 GIE, 
shortening the review period to 1 4 days instead of the standard 75 days when a 
catastrophic failure has occurred . 
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   In recognition of stakeholder feedback and the fact that non -SF6 GIE are available 
for some applications today, GIE owners that install qualifying non -SF6 GIE in 
advance of the applicable phase -out date will receive an early action credit that can 
be added to the GIE owner’s baseline starting in 2025. By being early adopters of 
non-SF6 GIE, GIE owners will gain more experience with them, smoothing the 
transition to non -SF6 GIE more broadly. 
 Establishes emissions limits that all GIE owners can meet , regardless of their 
average system capacity. The emissions limits for GIE owners with average system 
capacity of less than 10,000 MTCO 2e will have an emission s limit e quivalent to two-
percent of their average system capacity , rather than having to meet the one -percent 
limit specified in the current Regulation . GIE owners of this size have demonstrated 
the difficulties they face in achiev ing a one -percent emiss ion rate on an annual 
basis , and this adjustment allows them to maintain their 2019 allowed emission rate. 
 Promotes accurate accounting of GHG emissions from GIE throughout the State by 
expanding the current Regulation to cover additional GHGs expected to be used as 
insulating gases in GIE in the coming years.  The GWP of some emerging insulating 
gases is less than one. As a result of stakeholder feedback and the relatively small 
potential impact to global warming (in MTCO 2e) of GIE equipment u sing GHGs with 
GWPs less than or e qual to one , staff proposes only to require the reporting and 
regulatory coverage of insulating gases with a GWP greater than one.  Other 
revisions to the reporting requirements will improve CARB staff’s ability to verify the 
reported values . 
Comparable Federal Regulations: 
In 2017, ten of the GIE owners subject to the Regulation also filed an emissions report 
to United States . Environmental Protection Agency (U.S. EPA) under 40 CFR Part 98 
(Greenhouse Gas Reporting Progr am or GHGRP) Subpart DD .4 U.S. EPA’s GHGRP 
requires reporting of GHG emissions data and other relevant information from GIE 
owners whose aggregate nameplate capacity of non -hermetically sealed GIE exceed 
17,820 pounds of SF6 or perfluorinated compounds .5 U.S. EPA states that these data 
can be used by businesses and others to track and compare facilities' GHG emissions 
and identify opportunities to reduce pollution, minimize wasted energy, and save 
money.6 U.S. EPA’s GHGRP does not require that emissions be reduced ; it only 
requires that they be reported. This stands in contrast to CARB ’s Regulation, which 
was enacted as an early action measure under AB 32 for the purpose of achieving GHG 
emissions reductions. As such, more granular data are required to be reported under 
CARB’s Regulation, which requires that all GIE owners in California report emissions 
and ensure that they do not exceed the applicable emissions limit . 
4 U.S. EPA Greenhouse Gas Reporting Program data, accessed through FLIGHT: 
https://go.usa.gov/xpX98 . 
5 Subpart DD, G reenhouse Gas Reporting Program -Electric Transmission and Distribution Equipment 
Use: https://www.epa.gov/sites/production/files/2018 -02/documents/dd_infosheet_2018.pdf 
6 Greenhouse Gas Reporting Program (GHGRP): https://www.epa.gov/ghgreporting/learn -about -
greenhouse -gas-reporting -program -ghgrp 
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              U.S. EPA’s GHGRP is not a comparable federal regulation because it has a high 
reporting threshold and lacks any emissions limit.  CARB’s Regulation is needed to 
support mandated GHG emissions reductions, as set by SB 32, and follow the direction 
provided in Board Resolution 17 -46 to evaluate and explore opportunities to achieve 
additional significant cuts in GHG emissions from all sources . 
An Evaluation of Inconsistency or Incompatibility with Existing State Regulations 
(Gov. Code , § 11346.5 , subd. (a)(3)(D) ): 
During the process of developing the proposed regulatory action, CARB conducted a 
search of any similar regulations on this topic and concluded the proposed reg ulation is 
neither inconsistent nor incompatible with existing State regulations. 
DISCLOSURE REGARDING THE PROPOSED REGULATION 
Fiscal Impact/Local Mandate Determination Regarding the Proposed Action 
(Gov. Code, § 11346.5 , subds. (a)(5)&(6)): 
The determinations of the Board's Executive Officer concerning the costs or savings 
incurred by public agencies and private persons and businesses in reasonable 
compliance with the proposed regulatory action are presented below. 
Under Government Code sect ions 11346.5 , subdivision (a)(5) and 11346.5 , subdivision 
(a)(6), the Executive Officer has determined that the proposed regulatory action would 
create costs or savings to any State agency , would not create costs or savings in 
federal funding to the State, would not create costs or mandate to any local agency or 
school district, whether or not reimbursable by the State under Government Code, title 
2, division 4, part 7 (commencing with section 17500), or other nondiscretionary cost or 
savings to State or local agencies. 
Cost to any Local Agency or School District Requiring Reimbursement under 
section 17500 et seq .: 
The pr oposed regulatory action would not impose a mandate on local agencies, and the 
costs to local agencies would not be reimbursable by the State because the proposed 
Regulation does not mandate local agencies to provide a service to the public.  Further, 
the requirements are of general applicability because they apply to all GIE owners 
regardless of whether the owners are local agencies or private businesses . 
Because some regulatory provisions begin in 2020, all mentions of cumulative cost will 
cover the entire analysis period (2020 –2036). However, since there are no incremental 
costs or cost savings between 2020 and 2024, all average costs and cost savings 
discussed below are averages over the 12-year period (2025 –2036) with non-zero 
costs. 
Because the phase -out requirement will not be implemented until 2025, there will be no 
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 costs to local government in the fiscal year that the proposed Regulation will be 
effective (2020 –2021) and the two subsequent fiscal years. However, there will be 
costs and cost savings to 49 local agencies that are mainly publicly owned utilities 
across California. Local government agencies would incur the higher capital cost for 
non-SF6 GIE upfront but would benefit from maintenance and reporting cost savings in 
subs equent years. Staff estimated the cumulative cost to local government to be 
$37 million over the period 2020 –2036, or approximately $3.1 million per year on 
average over the 12 years with non-zero costs. There is also a cumulative cost savings 
of $17 million over the period of 2020 –2036, or approximately $1.4 million per year on 
average over the 12 years with non-zero costs. The tax revenue to local governments 
from 2025 through 2036 totals to $10.5 million with an average of $875,000 per year 
during the 12 years of non-zero costs. 
The proposed Regulation would not impose a mandate on any school district . 
Cost or Savings for State Agencies: 
Because the phase -out requirement will not be implemented until 2025, there will be no 
cost to State government in the fiscal year that the proposed Regulation will be effective 
(2020 –2021) and the two subsequent fiscal years.  However , there will be costs and 
cost savings to ten State government agencies across California. All ten State 
government agencies considered in this analysis are public universities. Staff estimates 
the cumulative cost to State government to be $ 2.1 million over the period 2020 –2036, 
or approximately $ 176,000 per year on average over the 12 years wi th non -zero costs. 
There is also a cumulative cost savings of $ 1.7 million over the period 2020 –2036, or 
approximately $ 138,000 per year on average over the 12 years with non -zero costs. 
The sales tax revenue to State government f rom 2025 through 2036 to tals to 
~$8.8 million with an average of $737,000 per year during the 12 years of non -zero 
costs. 
The implementation and enforcement of the proposed Regulation would not have an 
impact on staff resources at CARB. The workload will be absorbed by current staff 
using similar processes. 
Other Non -Discretionary Costs or Savings on Local Agencies: 
No additional costs or savings to local agencies beyond those addressed above under 
“Cost to any Local Agency or School District Requiring Reimbursement under sec tion 
17500 et seq.” are expected. 
Cost or Savings in Federal Funding to the State : 
No costs or savings in federal funding are anticipated. 
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      Housing Costs ( Gov. Code , § 11346.5 , subd. (a)(12) ): 
The Executive Officer has also made the initial determination that the proposed 
regulatory action will not have a significant effect on housing costs. 
Significant Statewide Adverse Economic Impact Directly Affecting Business, 
Including Ability to Compete ( Gov. Code , §§ 11346.3 , subd. (a), 11346 .5, subd. 
(a)(7), 11346.5, subd. (a)(8)): 
The Executive Officer has made an initial determination that the proposed regulatory 
action would not have a significant statewide adverse economic impact directly affecting 
businesses, including the ability of Califo rnia businesses to compete with businesses in 
other states, or on representative private persons. 
Results of The Economic Impact Analysis/Assessment (Gov. Code , § 11346.5 , 
subd. (a)(10) ): 
NON -MAJOR REGULATION: Statement of the Results of the Economic Impact 
Assessment (EIA) : 
(A) The creation or elimination of jobs within the State of California. 
The operation and maintenance requirements of alternative -gas GIE are designed to be 
similar to those for conventional SF6 GIE. Technicians familiar with handling SF6 GIE 
may need to receive additional training to operate and maintain non-SF6 GIE, and they 
are expected to be able to perform the job as they have with SF6 GIE. Therefore, staff 
does not expect there to be a significant increase or decrease in jobs due to workers’ 
ability to perform the job. However, vacuum GIE are expected to require significantly 
less maintenance. Staff expects a decrease in jobs related to maintenance crews at 
sites that use vacuum technolo gy, though it is anticipated that this decrease will be 
relatively small. 
(B) The creation of new business or the elimination of existing businesses within the 
State of California. 
Because all existing GIE manufacturers are located outside of California, the proposed 
Regulation is not expected to result in considerable business creation or elimination in 
California. 
Non-SF6 GIE are generally more expensive upfront than SF6 GIE; however, the cost 
savings from less maintenance and reporting are expected to compensate for the higher 
purchase cost and potentially lower the lifetime ownership cost. Most of the GIE owners 
in the State are electric power generation, transmission, and distribution and large 
industrial companies . CARB staff expects that these entities will be able to cover the 
higher upfront cost with little financial impact, especially when they can anticipate cost 
savings over the long term. 
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    (C) The expansion of businesses currently doing business within the State of 
California. 
No significant impacts to the expansion of businesses due to the proposed Regulation 
are anticipated. While the proposed Regulation is intended to increase demand for non-
SF6 GIE, this will be in place of SF6 GIE that would have been acquired in the absen ce 
of the proposed Regulation. The proposed Regulation is therefore not expected to drive 
an overall increase in demand for GIE and expansion of businesses for GIE owners. 
There may be some expansion of business to manufacturers of non-SF6 GIE, but all 
currently known GIE manufacturers are located outside of California. 
(D) The benefits of the regulation to the health and welfare of California residents, 
worker safety, and the state’s environment. 
Benefits such as reduced GHG emissions and reduced ope rating costs could result 
from implementation of non -SF6 GIE. The proposed Regulation is expected to reduce 
approximately 38,000 pounds of SF 6, or 391,000 MTCO 2e of GHG emissions during the 
analysis years 2020 –2036. Because GIE lasts approxima tely 40 years, emissions 
reductions from non -SF6 GIE acquired between 2025 and 2036 will continue through 
2075, resulting in cumulative emissions reductions of approximately 3,143,000 
MTCO 2e. Because GHGs are global pollutants, both California’s residents and the 
world’s population would benefit from the reduction in these emissions and the 
associated mitigation of global climate change. Therefore , these amendments may also 
directly improve the health and welfare of California residents, worker safety, an d the 
State’s environment. 
Effect on Jobs/Businesses: 
The Executive Officer has determined that the proposed regulatory action would have 
minimal impact on the creation or elimination of jobs within the State of California, the 
creation of new businesses or elimination of existing businesses within the State of 
California, or the expansion of businesses currently doing business within the State of 
California .  A detailed assessment of the economic impacts of the proposed regulatory 
action can be found in the Economic Impact Analysis in the Initial Statement of Reasons 
(ISOR ). 
Benefits of the Proposed Regulation: 
The objective of the proposed regulatory action is to reduce GHG emissions, improve the 
ability of small GIE owners to comply, improve accuracy in reported emissions, and 
improve CARB staff’s ability to verify reported data. 
A summary of these benefits is provided ; please refer to “Objectives and Benefits” under 
the Informative Digest of Proposed Action and Policy Statement Overview Pursuant to 
Government Code 11346.5(a)(3) discussion that starts on page three . 
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  Business Report ( Gov. Code, § § 11346.5, subd . (a)(11); 11346.3, subd. (d)): 
In accordance with Go vernment Code sections 11346.5 , subdivisions (a)(11) and 
11346.3, subdivision (d) , the Executive Officer finds the reporting requirements of the 
proposed regulatory action which apply to businesses are necessary for the health, 
safety, and welfare of the people of the State of California. 
Cost Impacts on Representative Private Persons or Businesses ( Gov. Code , § 
11346.5, subd. (a)(9)): 
In developing this regulatory propos al, CARB staff evaluated the potential economic 
impacts on representative private persons or businesses. The proposed regulatory 
action would impose additional costs to private businesses acquiring non -SF6 GIE 
instead of SF 6 GIE or filing for an SF 6 phase -out exemption . Some of these costs are 
expected to be offset by savings in the long run due to lower maintenance costs and 
exemption from reporting requirements for some non -SF6 GIE. 
CARB is not aware of any cost impacts that a representative pr ivate person would 
necessarily incur in reasonable compliance with the proposed action. 
Effect on Small Business ( Cal. Code Regs., tit. 1, § 4, subds. (a) and (b)): 
The Executive Officer has also determined under California Code of Regulations, title 1, 
section 4, that the proposed regulatory action would affect small businesses . However, 
there are significant maintenance cost savings that will offset some of the costs to small 
businesses. 
Consideration of Alternatives (Gov. Code , § 11346.5, subd. (a)(13)): 
Before taking final action on the proposed regulatory action, the Board must determine 
that no reasonable alternative considered by the Board, or that has otherwise been 
identified and brought to the attention of the Board , would be mor e effecti ve in carrying out 
the purpose for which the action is proposed, would be as effective and less burdensome 
to affected private persons than the proposed action, or would be more cost -effective to 
affected private persons and equally effective in implementi ng the statutory policy or other 
provisions of law. 
The Executive Officer analyzed three alternatives to the proposed amendments and 
determined that none were less burdensome and equally effective in achieving the 
purposes of the R egulation in a manner than ensures full compliance with the 
authorizing law. 
Retain One -Percent Emission Rate Limit. This alternative would maintain the 
Regulation’s one -percent emission rate limit rather than replacing it with an emissions 
limit measured in MTCO 2e. The impa ct of this alternative would be that SF 6 emissions 
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    from this source would continue to grow with system GIE capacity.  The data reported to 
CARB under the Regulation demonstrate that the amount of SF 6 in active GIE —that is, 
the GIE capacities used to determ ine emission rate limits —has grown in the last several 
years at an annual rate between one and five percent.  In meetings with GIE owners 
during the public process to amend the Regulation, GIE owners have noted that the rate 
at which SF 6 capacity is expect ed to grow statewide in the coming years may be greater 
than the historical rate and, for certain GIE owners, the rate of growth could be 
significantly greater than for the sector overall.  Reasons for the expected increase 
include replacement of old oil c ircuit breakers with SF 6 breakers, growth in demand for 
electricity due to population growth and the State’s goal to increase electrification of 
vehicles and other infrastructure, and the changing nature of the electric grid to include 
the growth in renewa bles. 
Because SF 6 capacity is expected to grow after 2020, and the maximum emissions 
allowed are proportional to SF 6 capacity, under the Regulation, emissions from this 
source category would be expected to increase after 2020. The one -percent rate limi t 
also fails to encourage adoption of new GIE that do not contain SF 6, and would not 
capture GIE devices that use a GHG other than SF 6 as an insulating gas.  The non -SF6 
GIE alternatives present an opportunity to reduce GHG emissions from this source 
categ ory, consistent with the State’s aggressive GHG emissions reduction targets 
described earlier in this document. 
Under this alternative, the goal of accelerating the transition to non-SF6 technologies 
and reducing GHG emissions would be more difficult to achieve. With an emission rate 
limit, any decrease in a GIE owner’s capacity also decreases the amount of SF6 the GIE 
owner is allowed to emit on an annual basis. This creates somewhat of a disincentive 
to replace SF6 GIE with non-SF6 GIE. Though this could mean delayed purchases of 
(currently more expensive) non-SF6 GIE, or increased maintenance costs from 
operating older SF6 GIE devices, these are indirect rather than direct outcomes of this 
option. Therefore, this alternative could increase SF6 emissions with neither a cost 
increase nor decrease. For these reasons, staff has rejected the “Retain One-Percent 
Emission Rate Limit” alternative. 
Do Not Phase out SF 6 GIE. This alternativ e would consist of removing the phase -out 
requirements and corresponding SF 6 phase -out exemption process. This alternative 
would not achieve the goals of accelerating the transition to non -SF6 technologies and 
realizing the corresponding GHG emissions red uctions.  Through conversations with 
GIE owners and GIE manufacturers as part of the public process, it became clear that 
non-SF6 GIE are being developed and these emerging technologies over time have the 
ability to replace SF 6 GIE in many, if not all, app lications. Though some non -SF6 
alternatives are in use today, their adoption is somewhat limited and supply varies by 
company.  As with many emerging or alternative technologies, the cost of non -SF6 GIE 
is expected to be higher than SF 6 GIE in the near -term, though over the long -term costs 
are expected to come down as production volumes increase. GIE owners are also 
extremely comfortable with their long -standing practice of using SF 6 GIE.  These factors 
could make it difficult for the non -SF6 to get a foo thold without further incentives. 
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 By establishing a phase -out schedule, CARB is establishing a market and driving 
demand for these products, particularly for the higher -voltage options that are 
anticipated to be developed at a later point in time.  CARB has been told by 
manufacturers and GIE owners that the proposed SF 6 phase -out would be a key factor 
driving near -term development work to commercialize additional non -SF6 GIE. If these 
technologies are not adopted, it is conceivable that SF 6 use and emis sions will continue 
to grow.  Also, with no phase -out of SF 6 GIE, these emerging technologies will likely 
become commercially available at a later point in time, if they are developed at all, due 
to lack of demand. This could have impacts both in California and globally, and further 
GHG emissions reductions from t his source category beyond those mandated by the 
Regulation would be very difficult to achieve without use of these alternative GIE. 
Implementing this alternative would yield significant cost savings relative to the 
proposed Regulation, but it would also result in SF 6 emissions growth over time, an 
option that is untenable from a climate impacts and a policy perspective given 
California’s GHG emissions reduction goals.  For these reasons, staff has rejected the 
“Do Not Phase out SF 6 GIE” alternative. 
Do Not Implement Differing Emissions Limits for Small -Capacity GIE Owners. This 
alternative would keep the emissions limit for s mall-capacity GIE owners (that is, GIE 
owners with capacity of less than 10,000MTCO 2e) at one percent.  S mall-capacity GIE 
owners have explained to CARB staff the challenge in complying with a one -percent 
emission rate limit on an annual basis. GIE owners of this size may have a small 
number of SF 6 GIE devices. Typically, a pressurized SF 6 GIE device will notify the 
owner of a drop in pressure (leak) only when the pressure drops below a certain 
threshold. Because that threshold may be several percent of the device’s capacity, by 
the time the GIE owner is made aware that a leak has occurred, more SF 6 may have 
been lost than allowabl e under the one -percent emission rate limit. While leaks are an 
issue for larger GIE owners as well, because these events occur relatively infrequently 
for individual GIE devices, larger GIE owners have sufficient capacity to allow for 
several of these ev ents per year while maintaining an overall emission rate below one 
percent. 
Under the proposed Regulation, CARB staff proposed increasing the allowable 
emission rate for these small-capacity GIE owners.  Under this alternative where the 
emission rate rem ains at one percent for all GIE owners, small-capacity GIE owners 
may be unable to comply on a regular basis.  This could result in additional costs to the 
small-capacity GIE owners due to possible enforcement penalties. This could also 
result in signific ant program and enforcement staff time to address emissions 
exceedances, many of which may be dismissed if deemed beyond the control of the 
GIE owner.  Because of these physical limits, small -capacity GIE owners could incur 
these additional costs without a ny corresponding GHG emissions reductions.  For these 
reasons, staff has rejected the “ Do Not Implement Differing Emissions Limits for Small -
Capacity GIE Owners ” alternative. 
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 ENVIRONMENTAL ANALYSIS 
When the Regulation for Reducing Sulfur Hexafluoride Emissions from Gas Insulated 
Switchgear (“Regulation;” Title 17, California Code of Regulations, sections 95350 et. 
seq.) was proposed in 2010, CARB adopted a no impact environmental analysis (NIEA), 
which is the equivalent of a negative declaration, under its certified regulatory program 
(California Code of Regulations, title 17, sections 60000 through 60008) to comply with 
the requirements of the California Environmental Quality Act (CEQA; Public Resources 
Code section 21080.5). The NIEA, included as Sec tion V. of the ISOR for that 2010 
item, dated January 7, 2010, determined that, based upon available information, no 
significant adverse environmental impacts should occur as a result of adopting the 
Regulation. Staff has determined that no additional env ironmental review is required for 
the current proposed amendments to the Regulation because there are no changes 
proposed to the originally approved project that involve new significant environmental 
effects or a substantial increase in severity of previou sly identified significant effects 
than previously identified in the prior 2010 NIEA. The basis for reaching this conclusion 
is provided in Section VI. of the ISOR report. 
SPECIAL ACCOMMODATION REQUEST 
Consistent with California Government Code Section 7296.2, special accommodation or 
language needs may be provided for any of the following: 
 An interpreter to be available at the hearing; 
 Documents made available in an alternate format or another language; and 
 A disability -related reasonable accommodation . 
To request these special accommodations or language needs, please contact the Clerk 
of the Board at (916) 322 -5594 or by facsimile at (916) 322 -3928 as soon as possible, 
but no later than 10 business days before the scheduled Board hearing. 
TTY/TDD/Spe ech to Speech users may dial 711 for the California Relay Service. 
Consecuente con la sección 7296.2 del Código de Gobierno de California, una 
acomodación especial o necesidades lingüísticas pueden ser suministradas para 
cualquiera de los siguientes: 
 Un intérprete que esté disponible en la audiencia; 
 Documentos disponibles en un formato alterno u otro idioma; y 
 Una acomodación razonable relacionados con una incapacidad. 
Para solicitar estas comodidades especiales o necesidades de otro idioma, por favor 
llame a la oficina del Consejo al (916) 322 -5594 o envié un fax a (916) 322 -3928 lo más 
pronto posible, pero no menos de 10 días de trabajo antes del día programado para la 
audiencia del Consejo. TTY/TDD/Personas que necesiten este servicio pueden marcar 
el 711 para el Servicio de Retransmisión de Mensajes de California. 
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 AGENCY CONTACT PERSONS 
Inquiries concerning the substance of the proposed regulatory action ma y be directed to 
the agency representative Carey Bylin, Manger, Energy Section, at (916) 445 -1952 or 
(designated back -up contact) Mary Jane Coombs, Branch Chief, at (916) 322 -7554. 
AVAILABILITY OF DOCUMENTS 
CARB staff has prepared a Staff Report: Initial Statement of Reasons (ISOR) for the 
proposed regulatory action, which includes a summary of the economic and 
environmental impacts of the proposal.  The report is entitled : Staff Report: Initial 
Statement of Reasons for Rulemaking -Proposed Amendments to the Regulation for 
Reducing Sulfur Hexafluoride Emissions from Gas Insulated Switchgear . 
Copies of the ISOR and the full text of the proposed regulatory language, in underline 
and strik eout format to allow for comparison with the existing regulations, may be 
accessed on CARB’s website listed below, or may be obtained from the Public 
Information O ffice, California Air Resources Board, 1001 I Street, Visitors and 
Environmental Services Center, First Floor, Sacramento, California, 95814 , on July 21, 
2020 . Because of current travel, facility, and staffing restrictions, the California Air 
Resources Boa rd’s offices may have limited public access. Please contact Bradley 
Bechold , Regulations Coordinator, at bradley.bechtold @arb.ca.gov  or (916) 322-6533 if 
you need physical copies of the documents. 
Further, the agency representative to whom nonsubstantive inquiries concerning the 
proposed administrative action may be directed is Bradley Bechtold , Regulations 
Coordinator, (916) 322 -6533 . The Board staff has compiled a record for this rulemaking 
actio n, which includes all the information upon which the proposal is based. This 
material is available for inspection upon request to the contact persons. 
HEARING PROCEDURES 
The public hearing will be conducted in accordance with the California Administrative 
Procedure Act, Government Code, title 2, division 3, part 1, chapter 3.5 (commencing 
with section 11340). 
Following the public hearing, the Board may take action to approve for adopt ion the 
regulatory language as originally proposed, or wit h non -substantial or grammatical 
modifications. The Board may also approve for adopt ion the proposed regulatory 
language with other modifications if the text as modified is sufficiently related to the 
originally proposed text that the public was adequatel y placed on notice and that the 
regulatory language as modified could result from the proposed regulatory action . If this 
occurs, the full regulatory text, with the modifications clearly indicated, will be made 
available to the public, for written comment , at least 15 -days before final adopt ion. 
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\ The public may request a copy of the modified regulatory text from the contact 
information listed above . 
FINAL STATEMENT OF REASONS AVAILABILITY 
Upon its completion, the Final Statement of Reasons (FSOR) will be available and 
copies may be requested from the agency contact persons in this notice, or may be 
accessed on CARB ’s website listed below. 
INTERNET ACCESS 
This notice, the ISOR and all subs equent regulatory documents, including the FSOR, 
when completed, are available on CARB ’s website for this rulemaking at 
https://ww2.arb.ca.gov/rulemaking/20 20/sf6 
CALIFORNIA AIR RESOURCES BOARD 
_________________________________ 
Richard W. Corey 
Executive Officer 
Date : July 7, 2020 
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumptio n. 
For a list of simple ways you can reduce demand and cut your energy costs, see our websi te at www.arb.ca.gov . 
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