We need more circularity
A-Gas Group Commercial Director, Ken Logan, explains why the latest F-Gas proposals in the short term may do more harm than good.
The European Commission has tabled proposals for deep cuts in the current F-Gas phase down schedule with stringent GWP-based sector controls for certain applications. With the UK likely to follow the lead of the European Union, we could see a complete ban on refrigerants with a GWP higher than 150 in new self-contained refrigeration equipment and heat pumps, as soon as 2025.
On top of this, a proposed ban for new split air conditioning systems and heat pumps below 12kW capacity using gases with a GWP of 150 or more could happen in 2027.
To reduce emissions of high GWP refrigerants and to move to better alternatives is not the problem and is not being disputed. There are a lot of well-intentioned environmental objectives, but the mechanics of how to achieve them is being determined with limited consultation and, in the process, often ignoring the extensive knowledge available within the industry.
There is also very little time for the industry to adapt, which doesn’t allow effective planning. Meeting our overall environmental objectives will be better accomplished by working with the support of the industry. We want to help policy makers avoid some of the adverse, unintended consequences which will result from their rigid proposals and unrealistic timescales.
It is estimated that there are around 30,000 different models of self-contained refrigeration equipment, air conditioning systems and heat pumps in the industry, that will need to be redesigned to cope with new refrigerant gas requirements. The proposals will mean a rapid shift to flammable refrigerants.
Compressors, heat exchangers and control systems will all have to be updated. On the proposed timetable, the industry will have very little room – potentially less than a year if the legislation concludes its passage through Parliament in 2024 – to make these changes.
The expected widespread adoption of flammable refrigerants will require different protocols and training, especially for engineers. It will also lead to a lack of available equipment able to meet these new standards which will detrimentally affect the ambitious target of reducing our dependency on fossil fuels through the use of heat pumps.
The draft proposals reveal a complete lack of vision around what to do with the very large installed bank of existing refrigerants, with no new measures stimulating the reclamation and recovery of refrigerants. Reclaimed refrigerants still only account for three per cent of refrigerant supply – so the industry is currently well off the pace.
Further incentivising the reclamation of refrigerants, as well as the recovery and destruction of gases where reuse is not appropriate, should become the basis of any future decisions if policy makers are serious about making a real difference to reducing potential emissions overall.
Recovery for reclamation ensures that gases are not vented or leaked into the atmosphere and also avoids the need to produce the equivalent quantity of virgin refrigerants. The best way to achieve ambitious environmental targets is for policy makers to acknowledge the role reclaimed products have in bridging the gap between ambitious policy and practical reality.
In Australia, Canada and Japan there are schemes where the industry is incentivised to return redundant gases to refrigerant suppliers to be reclaimed or destroyed responsibly. In the USA, used ozone depleting substance refrigerants found in old HVACR equipment can be destroyed and re-purposed into voluntary market carbon offsets, which encourages their containment and greatly reduces the likelihood that they would be vented to atmosphere.
California will only allow the use of reclaimed R410A in new air conditioning units from 2023. There is no reason why these ideas cannot be adapted by policy makers for use in Europe and the UK.
In fact, reclaimed gas is already being used in new air conditioning equipment by some manufacturers in Europe but perversely this equipment would be caught up in these new bans and would be doing the opposite to incentivising the circular economy.
If the importance of recovery for reclamation or destruction is ignored, it begs the question: what will happen to high GWP refrigerant gas in the installed bank, especially if it is going to cost customers and installers money to dispose of the gas when it no longer has a use?
There are unscrupulous operators in the market who will vent gas instead of paying for disposal. This will obviously be environmentally damaging and an unintended consequence if the latest round of F-Gas proposals don’t do more to recognise the clear benefits in adopting lifecycle refrigerant management.