IRHACE, CCCANZ and RLNZ are broadly in agreement with the Ministry’s proposals as set out in the consultation document.
IRHACE, CCCANZ and RLNZ held a meeting with interested parties to determine a common stance towards the phase out of HFCs. The outcome of the meeting was expressed as follows:
A meeting of refrigerant wholesalers was held on 30 March 2017 at the IRHACE centre to consider the best way to manage the phase out of refrigerants with a high GWP in response to the Kigali Agreement.
The meeting looked at previous experience with phase outs of refrigerant and discussed the best mechanism to handle the distribution of carbon credits moving forward.
Attendees agreed that the objective was to achieve a reduction in usage of refrigerants with high GWP in a way that is fair, effective and without unintended consequences. Principles should tie back to achieving the right outcome for improving the environment.
Ideal outcomes include:
Taking all the above into account, the general consensus of the meeting (while not binding on the attendees) is that it would be best to operate a quota system based on existing wholesaler volumes of refrigerant sale.
A percentage of the total approved imports should be kept aside for new entrants into the market.
IRHACE, CCCANZ and RLNZ are supportive of moves to respond to the Kigali Amendment with a move to refrigerants with lower GWP by reducing demand for HFCs, and moving to alternatives. The technology to do this is already well advanced overseas.
We note however that the shift towards refrigerants with lower GWP bring additional risks for practitioners and end users.
Some replacement refrigerants have flammable characteristics and it is important to ensure people working with them and end users are safeguarded.
Who can work with refrigerants is still largely unregulated in New Zealand, and this remains a weakness and may work against better practice and reduction in leakage.
While health and safety falls within the ambit of other government agencies, there are implications that fall across a number of Ministries. IRHACE, CCCANZ and RLNZ would like to see a stronger regulatory response to ensure safe work practices and installation, as well as a minimisation of leakage. This needs to be supported by a greater emphasis on training. RLNZ has already produced a Flammable Safety awareness course in anticipation of this.
RLNZ, IRHACE and CCCANZ have consistently advocated a system for managing refrigerants similar to the F gas regulations in Europe.
Responses to specific questions raised in the Consultation document: