Navigating California’s Gas Insulated Equipment Regulations

Overview of California’s Gas Insulated Equipment Regulation

The purpose of California’s provisions for Gas Insulated Equipment (GIE), located at Title 17 of the California Code of Regulations (17 CCR) §95350, is to achieve greenhouse gas (GHG) emission reductions from the operation of electrical equipment that uses a GHG, such as Sulfur Hexafluoride (SF₆), as an insulating medium. The provisions contain multiple requirements such as annual reporting, timeline for phasing out SF₆ GIE, assignment of emission limits, etc. Such equipment is located at power plants, electrical substations associated with data centers, electrical substations associated with commercial or residential operations, etc. Any GIE owner subject to these provisions (e.g., data center) must meet the requirements notwithstanding any contractual arrangement that the GIE owner may have with any third parties, such as the local utility.

Gas Insulated Equipment Compliance Requirements

As introduced above, 17 CCR §95350 establishes several compliance obligations for owners and operators of GIE that use insulating gases, including SF₆. The primary regulatory provisions include the following:

1. SF₆ Phase-Out Requirements

The regulation establishes a phased-out prohibition on the acquisition of SF₆ GIE for use in California. Beginning on the dates specified in Tables 1 and 2 of the regulation, no person may acquire SF₆ GIE unless a qualifying exemption applies. Several exemptions to the phase-out requirement are provided, including:

• Facilities that have received a CARB-approved SF₆ phase-out exemption; or
• Acquisition of SF₆ GIE in response to an equipment failure, where replacement is necessary to maintain operations; or
• SF₆ GIE that was present in California and reported to CARB for a data year prior to the applicable phase-out, provided the GIE was purchased prior to the phase-out dates and enters California no later than 24 months after purchase date; or
• Replacement of defective SF₆ GIE by the manufacturer under the terms of the manufacturer’s warranty.

If any of the above exemptions apply to a facility, appropriate documentation must be maintained to demonstrate eligibility.

2. Annual Emission Limits

In addition to the phase-out requirements, 17 CCR §95353 establishes annual emission limits for SF₆ and other covered insulating gases used in GIE. It is required that carbon dioxide equivalent (CO₂e) emissions from a GIE do not exceed the applicable annual emissions limit. To demonstrate compliance, facilities must:

• Calculate the average system capacity for each covered insulating gas for the data year;
• Calculate the average CO₂e capacity for each covered insulating gas on an annual basis; and
• Apply the emissions limit formula specified in the regulation

For data years 2025 and beyond, the regulation requires that emission limits for GIE be determined using the specific calculation methodology outlined in §95353, which becomes increasingly stringent over time.

3. Inventory and Recordkeeping Requirements

The regulation also requires detailed inventory and recordkeeping obligations for GIE owners. Facilities must maintain a complete and accurate GIE inventory for each data year, that includes equipment-specific information for all covered devices. Additionally, owners must retain records for a minimum of five calendar years, including documentation supporting all emission calculations, copies of any notifications or communications submitted to CARB, supporting documentation for submitted or revised annual reports, and records to support compliance with emission limits and any exemptions.

4. Annual Reporting Requirements

Lastly, the regulation requires the submittal of an annual report to CARB by June 1^st of each year. The annual report must cover the prior calendar year and include GHG and equipment information, such as:

• Annual GHG emissions data;
• Administrative and ownership information for the GIE;
• Average system capacity and average CO₂e capacity;
• Any calculated early action credits;
• Baseline CO₂e capacity;
• The calculated GIE emission limit for the data year;
• Annual emissions and Global Warming Potentials (GWPs) for each covered insulating gas;
• Total CO₂e emissions, emergency event emissions, if applicable, and CO₂e emissions excluding emergency events.

Lessons Learned from Managing Gas Insulated Equipment in California

The California GIE provisions have been effective since January 2011 (with significant amendments in 2021 effective January 2022) and are usually assigned to staff supporting transmission operations, often with limited support from environmental health and safety (EHS) staff or consultants/experts. Trinity has been involved with these provisions and their implementation since 2021 and has developed a list of lessons learned from our engagements. These lessons learned include items such as:

• Understanding that the California GIE program is more nuanced than the similar federal program under 40 CFR Part 98 Subpart DD and complying with the federal program does not guarantee compliance with the California requirements;
• The California GIE program sets annual GHG emission limits, whereas the federal program only requires reporting of annual emissions;
• The federal Subpart DD program applies to facilities where the total nameplate capacity of SF₆ and perfluorocarbon (PFC) containing equipment exceeds 17,820 pounds, whereas the California program has no minimum reporting threshold and applicability is based on equipment ownership; and
• The California program implements a mandatory phase-out of SF₆ for new GIE beginning January 1, 2025, and extending through 2033 depending on GIE voltage class and configuration.

Our experience has also shown that historic recordkeeping spreadsheets or other tracking systems may not have been updated to address the 2021 amendments to the California program, thereby requiring improvements to the site or vendor procedures and recordkeeping processes. For example, an optional nameplate capacity adjustment procedure was added in 2021 that can be used to limit calculated SF₆ losses when a GIE is removed from regular use or opened for maintenance activities. This nameplate capacity adjustment procedure requires CARB notification and additional weighing and pressure measurements to complete the process.

Trinity’s California staff and GIE subject matter experts can support with reviewing the existing programs of affected GIE owners, identifying and closing any gaps, and ensuring compliance with these California specific requirements. If you are an affected GIE owner and have any questions regarding compliance of your facility, please reach out to Eddie Al-Rayes, Tanya Garcia, or your local Trinity office for assistance.