Our response to the Climate Change Commission

Representing the country’s HVAC&R Industry, HVAC&R Centre has submitted its response to the second emissions reduction plan (ERP) to assist New Zealand contribute positively to the world’s climate change problem

New Zealand’s second emissions reduction plan (2026–30) discussion document outlines sector proposals for the second emissions reduction plan, as well as how these policies might affect different groups of people and how communities can respond to the effects of climate change.

In this submission, we have responded to seven key questions detailed in the discussion document.

• What, if any, other sectors or areas do you think have significant opportunities for cost-effective emissions reduction?

• What additional opportunities do you think the Government should consider?

• What, if any, other impacts or consequences of the Government’s approach to meeting the first emissions budget should the Government be aware of?

• What, if any, are the long-term impacts from the changes to the first emissions reduction plan on meeting future emissions budgets that should be considered through the development of the second emissions reduction plan?

• What are some examples of how businesses and industries are already managing climate risks?

• How can these kinds of activities be further supported?

• Please provide any additional feedback on the pathway the Government has set out for managing climate risks from emissions reduction activities.

Overall, we believe that this discussion document and the first ERP roadmap give insufficient attention to the impact of HVAC&R systems on global warming.

By extension, this significantly diminishes the opportunity to mitigate HVAC&R GHG emissions through improved management of refrigerants.

Under the current policy settings, HVAC&R GHG emissions emission reductions will be severely constrained. Conversely, with the right policy settings, far better HVAC&R GHG emissions reduction outcomes will be delivered at minimal cost to the Government.

The current policy setting assumes a singular focus on the high GWP synthetic refrigerants, being the fluorinated (F-gas) refrigerants that cause direct Scope 1 fugitive GHG emissions. The policy settings ignore the fact that all refrigerant types cause indirect Scope 2 and 3 GHG emissions.

We have pointed out in a number of submissions that the management of refrigerants is arguably the world’s leading opportunity to mitigate global warming.

• It is widely accepted that improved management and phase-down of F-gases offers an opportunity to mitigate the impact of global warming by as much as 0.5°C by the year 2100 – this is quoted extensively in government reporting and information releases.

• The Project Drawdown 2020 Review ranked refrigerant management and alternativerefrigerants as respectively the number 4 and number 7 opportunities to mitigate global warming between 2020 and 2050, ‘alternative refrigerants’ being a proxy for the Kigali phase-down of HFCs. The first publication of the Project Drawdown Review in 2017 aggregated refrigerant management and alternative refrigerants ranking them as the number one opportunity to mitigate global warming.