The ongoing review of Australia’s synthetic greenhouse gas laws is being undertaken for a “whole lot of wrong reasons”, according to managing director of Scantec Stefan Jensen.
Mr Jensen was at this month’s ministerial roundtable for the refrigeration and airconditioning industry on the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 review, chaired by former parliamentary secretary to the minister for the environment Bob Baldwin.
He said Mr Baldwin “made all the right noises”, and stated to the group, “We are not here to pick winners; we are here to pick outcomes.”
The government has committed to an 85 per cent phase down in emissions from hydrofluorocarbon refrigerants by 2036. This commitment is based on Australia’s Montreal Protocol and Kyoto Protocol commitments, as HFCs have both high global warming potential and contain ozone depleting substances.
Mr Jensen said the 85 per cent was a “fairly mild target”, and showed how far behind Australia was compared with European countries like Denmark, which imposed a total ban on HFCs in 1996 with a 10-year adjustment period for industry.
He said Australia should take the same approach, as the industry would then adjust. He also thinks the focus needs to shift from simply looking at exchanging HFCs for natural refrigerants to reviewing the entire HVACR industry, including licensing, compliance, technology and training.
When the OPSGG MA was introduced in 1989 there was a different set of problems, Mr Jensen said.
“[The review] is asking the wrong question a little bit; it is stuck in the same groove. It needs to look at HVACR as a whole – at the moment it is only in isolation looking at HFCs,” he said.
“The whole business needs to be reviewed. Then we can take advantage of the energy-efficiency gains to be made.”
Mr Jensen said systems needed to not just swap gases, but be redesigned for better energy efficiency. One of the challenges for the HVAC sector, however, is that the refrigerant element is often a “black box” technology that just “shows up on the truck”, and there are no tertiary courses in Australia for HVAC engineers in natural refrigerant system design. He is completing his own tertiary study in the field in Europe.
In the trade sector, he said, while TAFEs have been equipped with the training to upskill apprentices and tradesmen in natural refrigerants, it is offered as an elective, not as core curriculum.
And for existing tradesmen and contractors in the industry, there is no access to subsidised funding for training in natural refrigerants because the government scrapped the workplace development fund, according to Australian Refrigeration Association president Tim Edwards.
Mr Jensen said that if HVAC systems were replaced in their entirety, there was a 30 per cent saving in energy use and the technical life of the system was twice as long.
“It delivers a nice return.”
His company has only been installing HVACR systems that utilise ammonia or CO2 refrigerants for the past five years.
Where the naturals are simply swapped in an existing system, however, he said the energy saving was only around six per cent.
The skill base question is crucial, though, because if natural refrigerant systems are not installed correctly, they can use two to three times the energy of the system with HFCs, he said.
There is also a need to bring the industry up to speed on the “technical discipline” of risk management, where flammable agents such as ammonia are being used. This is something others sectors that use ammonia have been managing for over a century.
“One has to understand how far behind Australia is,” he said.
The COP21 talks in Paris would have an influence on how Australia progresses in reducing synthetic greenhouse gas emissions, Mr Jensen said, however industry preparedness was “very low”.
“I think the politicians are blissfully unaware of how big the problem is.”
He said the industry in Europe was “changing rapidly”, which means there are better technologies available now than there were 20 years ago when Denmark started down the phase down path. And while the supply of natural refrigerants available in Australia is not currently enough should there be a sudden wide-spread uptake, it would quickly adjust to demand, especially if industry were given a deadline like in Denmark.
Mr Jensen said he was proposing a six point plan in his submission to the current round of the review. One of the points is that there should be benchmarking for energy use by HVACR systems in commercial properties and in high-rise buildings, and that these benchmarks should then be set as mandatory maximums for HVACR energy use per square metre in the Building Code of Australia.
He has also proposed to environment minister Greg Hunt a ban on HFCs in all new HVACR systems with a charge larger than 5kg, such as commercial and industrial systems by 2025, and to make the use of hydrocarbon refrigerants compulsory in all new systems with a charge less than 0.150kg [for example, domestic systems] by 2025.
“It really is that simple. If the government does that then industry has direction,” Mr Jensen said.
Dropping the HFC levy in 2014, which happened as part of the Abbott government’s Repeal Day bill, sent the wrong signal, he said, as the industry had started to change but then got the message it was back to business as usual.
“There will be no expense to the government [for the phase down of HFCs] except for training that in other countries is financed by a levy,” Mr Jensen said.
Mr Edwards added that another issue with the current OPSGG MA review was that there were too many related inquiries underway, such that it was difficult for industry players to make “well considered” comment within a short timeframe.
These include new proposed standards, the ACCC review of the authorisation for Refrigerant Reclaim Australia, the Queensland government’s review of legislation relating to hydrocarbon refrigerant use and COAG’s mooted review into the compliance of building products.
“There is no way everyone can make considered submissions to them all,” Mr Edwards said.
He thinks the whole OPSGG MA review should be reframed, and include issues such as work health and safety, and training.
“We need to get it right – we don’t need to do it quickly,” he said. “Paris will be reasonably indicative of what Australia ought to do.”
He said the act also needed to include regulation, which it currently doesn’t due to the government’s fixation on “regulation reduction”.
“You’re not going to get people to stop intentional emissions until you prosecute,” Mr Edwards said.
“What this industry needs is a licensing system that pertains to refrigeration, not refrigerants – we need nationally consistent licensing.”
Meanwhile, the Environmental Investigation Agency has launched a handbook to guide the European HVACR industry through the HFC phase down mandated by the EU F-Gas Regulation legislation, which will compel a large-scale conversion to climate-friendly refrigeration and airconditioning technologies in Europe by 2030. This is expected to result in cumulative emission savings are 1.5 billion tonnes of CO2-equivalent by 2030 and five billion tonnes by 2050, according to the EIA.
The EU F-Gas Regulation Handbook: Keeping Ahead of the Curve as Europe Phases Down HFCs outlines the main impacts and details why producers, importers, exporters, operators, manufacturers, contractors and national authorities should take early proactive measures to ensure swift implementation.
“What [the EIA] is saying is that if you are going to phase down HFCs, you need regulations and you need to enforce those regulations,” Mr Edwards said.