Australian Refrigeration Association submission calls for F-Gas-style legislation to reduce emissions and encourage low-GWP replacement, especially naturals
The Australian Refrigeration Association and over 80 signatories have called on its national government to use F-Gas style legislation to bring HFC emissions under control.
Unusually for a national cooling industry, the Australian industry is recommending a more ambitious Australian strategy for HFC phase down than its policymakers have proposed, calling for more speed and more controls, including F-gas style record keeping and leak detection requirements.
In its submission, ARA set out the context for its call for a phase-down and government-led controls, saying: “The HVACR industry in Australia is composed of 20,000 suppliers, 80,000 licensees, tens of thousands of specifiers and consultants and 23 million end users who enjoy the benefits of HVACR but are ill-informed about its energy efficiency and environmental impact.”
ARA said that if HFCs are not phased down rapidly, ‘the world has little chance of achieving the required degree of global warming control’. It said that aligning the country with a global phase down would bring technology benefits, as Australia’s cooling industry already has natural refrigeration technology necessary to replace HFCs.
The body offered three clear reasons for taking a more ambitious approach, namely:
“1. It is commercially warranted and will deliver important economic efficiency in the national interest.
2. By demonstrating Australia’s commitment to rapid HFC phase down we will encourage other countries to adopt a similar level of ambition in the global interest.
3. The only barriers to HFC phase down are the barriers we allow or fail to address. There are no technical or commercial reasons to delay the HFC phase-down.”
ARA said: “We strongly recommend that far more consideration be given to the European Union legislation addressing HFC phase-down. In our view the EU legislation is far more ambitious, concrete and specific than the [Australian Department of Energy’s] options paper. It addresses many of the issues we list below as required sources of emissions reduction such as mandatory end use restrictions, mandatory refrigerant emissions avoidance and the specific methods required to deliver these. The EU legislation will drive change in the industry that Australia can capitalise on. We fail to see why Australia should not emulate Europe. At the very least the Review should be assigned the specific task of assessing the EU legislation and considering the costs and benefits in the Australian context.”
ARA has recommended a range of specific measures, consisting of the following:
· Ban the use of HFCs in new vapour compression systems with a charge >5 kg by 2025
· Compulsory use of low-GWP refrigerants (<150 GWP) in all new vapour compression systems with a charge <150g by 2025
· The introduction of minimum energy performance benchmarking for all single HVACR systems including multiple single systems that may operate in concert to emulate a total system
· The introduction of a voluntary HVACR quality assurance scheme providing consumers with a clear choice between a compliant and a non-compliant solution and a clear definition of the consequences of a decision either way
· A uniform, skills-based, rigorous licensing and licensing renewal scheme for all HVACR practitioners incorporating all refrigerants and licence levels reflecting HVACR system complexities/risks and the technical/design level of the licence holders. This means passing exams both for obtaining licences, but also for retaining them
The Association also sets out a range of conditions which will help achieve an HFC phase-down. It says far greater examination is required by HVACR sector to identify high priority sectors and to recommend the sequence and timing of phase-down by sector. “There are important opportunities for energy efficiency such as split system and commercial/industrial air conditioning, cold storage, commercial refrigeration and motor vehicle air conditioning. District Energy offers high potential for emissions reduction and costs savings by reducing both infrastructure and the operating cost required to deliver heating and cooling in urban and industrial centres.”
It also notes that since low GWP technologies are already available in every sector, “a relatively short notice period of a few years is sufficient to enable the industry to transition in all regards: by sourcing the required technology and preparing their supply chain for its availability.”
Another area in which ARA wants to see change is in the reduction of intentional and unintentional emissions. It wants to usher in mandatory reporting of refrigerant use, noting that contractors already collect this data for their invoicing purposes. ARA says: “They should be required to report this data by automated means enabling low cost emissions measurement and control. At the same time automated refrigerants leak identification should be required for all equipment over a given charge size enabling both the contractor and end user to be made aware of refrigerant losses. The result will be faster leakage reporting, faster and more focused maintenance, increased energy efficiency and reduce refrigerant emissions.”
This would have a greater effect, it notes, in that it would cause both contractors and end users to be made aware of both the cost and environmental impact of their maintenance decisions.
Ultimately, ARA notes, it would enable the introduction of a penalty or licence retention scheme that would further discourages intentional or unnecessary releases of environmentally harmful substances be they of the HFC, HFO or any other category.
The final plank to its strategy is an upgrading of industry standards in order to enable the industry to deliver both safe practices and enable transition to low GWP technology.
It says that the cost of implementing such measures should not be seen merely as a cost to the industry, but as a saving of emissions costs. It propose a levy on refrigerants at the point of sale, based on emission, with natural refrigerants exempt and all collection costs to be borne by the refrigerant distributors.
This, it concludes, all needs to be underpinned by proper regulatory enforcement and improved training; by the government putting its money where its mouth is by embedding it in its procurement strategies; by better benchmarking of HVACR installations with regard to emissions; and by improved end of life management.
The association said, in publishing the submission:
“In making the recommendations, we recognise that the HVACR industry is currently based on technologies that are low energy efficiency and high direct emissions. We recognise that every buyer of HVACR systems faces a choice to reduce their HVACR operating costs or not.
Specifically when an HVACR buyer selects an HVACR system that uses HFC refrigerants he/she is also choosing a system that is less energy efficient than it could be and risks high direct greenhouse gas emissions. There is in fact no need or benefit to using HFC based technology.
However we also recognise that there are hundreds of thousands of individuals in the HVAVCR supply chain which need to be educated about the benefits of using low-GWP technology. We recognise that Australia needs regulations, training and education that encourage the use of this technology.”