HVAC&R Centre's submission to the Climate Change Commission’s Draft advice

Represent the bulk of New Zealand’s HVAC&R industry, HVAC&R Centre’s submission is specific to the global warming impact of refrigerant GHG emissions, including but not limited to synthetic refrigerants (F-gases), as they relate to the Commission’s Draft advice on Aotearoa New Zealand’s fourth emissions budget

In summary

We have not submitted to the Commission’s 2024 review of the 2050 emissions target because we believe that any estimate of refrigerant GHG emissions in 2050 is highly sensitive to policy choices made in this decade. To quote the Commission’s consultation document for the 2024 review of the 2050 emissions target:

For any target to be effective, it needs to be relevant, achievable and timely. Over time, circumstances can change which affect a target’s impact and influence.

However, the Commission when considering the 2050 emissions target should consider the matters we have raised in this submission.

Unfortunately, the policy approach that has been taken by MfE with respect to managing the global warming impact of refrigerants, and by extension certain assumptions made by the Climate Change Commission, fail to address reality, this being despite the previous submissions our organisations have made.

Accordingly, we do not consider that the Commission’s target for annual F-gas emissions of 0.6 MtCO2e in the fourth emission budget period is unachievable unless there is a major policy rethink relating to how refrigerant GHG emissions are managed.

In our opinion the Emission Reduction Plan’s (ERP) Baseline projected emissions estimate of circa 1.2 MtCO2e (refer ERP Chapter 12 Fig 16.2 below) by the end of the fourth emission budget period would likely be a best-case outcome.

The previous government’s Priority Waste Product policy had the unintended consequence of continuing the historical focus on end-of-life F-gas recovery and destruction, the following realities either being ignored or not being given due consideration:

F-gases (direct fugitive Scope 1 GHG emissions)

1. The impact of F-gases on global warming and the opportunity to mitigate their impact is greater than is generally understood!

2. The inclusion of F-gases as a priority waste product under the previous government’s Priority Waste Product policy was poorly conceived and managed. In particular, the co-design for the regulated Product Stewardship Scheme (PSS) had a predetermined outcome whereby the existing voluntary Refrigerant Recovery (Recovery) PSS for synthetic refrigerants, now calling itself Cool-Safe, would morph into the regulated PSS to continue with its sole focus on F-gas recovery and destruction.

3. Historically very little F-gas has been recovered at end-of-life, the bulk of F-gases end up being vented to the atmosphere from operating systems, principally due to ongoing leakage over the system’s life.

4. The fact that the bulk of hydrofluorocarbons (HFCs) are vented to the atmosphere, have high GWPs and relatively short atmospheric lives, means the critical need is to mitigate their impact on global warming during the current decade when the world most needs to respond to global warming.

5. There is a disconnect between what the Kigali Amendment’s (Kigali) phase-down of bulk HFC imports will achieve in terms of the mitigation of F-gas GHG emissions and the overhanging emissions risk of the F-gas refrigerant bank.

F-gases (indirect Scope 2 & 3 GHG emissions)

6. All refrigerant types cause GHG emissions, not just the F-gases, the historical focus on end-of-life recovery and destruction of F-gases has ignored the opportunity to mitigate the indirect Scope 2 and 3 refrigerant GHG emissions. In particular, energy efficiency should be a primary focus for any scheme seeking to mitigate Scope 3 refrigerant GHG emissions.

The lack of supply chain visibility

7. The fundamental problem facing refrigerant management is the lack of visibility through the supply chain, there being no visibility at the operating system level, you can’t effectively manage what you can’t measure! The lack of quality data is reflected in estimates of refrigerant GHG emissions having high degrees of uncertainty.

Each of the above matters are addressed in detail in the full submission. Read online here.