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MIPIGGS Newsletter ** UPDATE ON EURO F-GASES ** * GREENPEACE, FoE, CAN Europe CONDEMN F GAS REGULATION * * CONTAINMENT FAILS - HFCs As Escape-prone As CFCs - REPORT * plus * SANYO GUILTY OF GREEN-HFC CLAIMS IN AUSTRALIA * Editor’s note: due to unusually rapid developments in the f-gas field we have decided to put out this additional newsletter. Apologies if this is clogging your mailboxes. BAN HFCS in CARS: DRAFT F GAS REGULATION "FALLS FAR SHORT" SAY GREEN GROUPS Plans to allow their wholesale use in car airconditioning means these gases, over a thousand times stronger heaters of the atmosphere than CO2, will become the CFCs of climate change they say. Instead governments should require the use of alternative technologies pioneered by BMW, Toyota and others, The call comes as analysts Atlantic Consulting report [below] that as much HFC is getting into the air from fridges, car systems and fire extinguishers as the notorious CFCs did in the past. This demolishes the official UK case for not using alternatives and relying on "containment". The NGO comments [detail below] are made in response to a UK Government consultation on the draft ‘f-gas’ regulation drawn up by the European Commission, which closes on Thursday 26 February. The proposed regulation is ‘fundamentally flawed’ and ‘falls far short of what is required given the seriousness of the climate threat’ say the NGOs. They point to the fact that HFCs have grown over 20% in the Arctic atmosphere in twelve months (2001-2) and are rising almost exponentially the world-over, as reported in the last newsletter. The UK is particularly criticised for putting forward figures about containment in mobile (car, van etc) air conditioning with no detail, just ‘plucked from the air’. The groups call for HFCs only to be used transitionally as replacements for ODS and not for new uses such as car air conditioning; warning labels on any car containing HFCs; official public awareness campaigns to alert the public to the environmental dangers posed by HFCs and other f-gases; and public procurement policies of utilising alternative technologies to f gases. A vote on the f-gas regulation in the European Parliament, expected in the last week, has been delayed pending translation of the hundreds of amendments put down. [full text of NGO letter below] * * * * * ATLANTIC CONSULTING REPORT – "HFC CONTAINMENT HAS FAILED" A report by environmental-impact expert Eric Johnson, uses the f-gas industry’s own data to show the containment’ hopes for HFCs are false, suggesting a bad case of ‘cognitive dissonance’ among officials and politicians who want to base policy on such hopes. For HFCs in fire extinguishers, Johnson says the UK Government assumed rates too low for the systems to be used to put out fires – and only amended their estimates, after more than six years of argument. Instead of being neatly contained in equipment and safely recovered for re-use or destruction, the report draws directly on industry studies to find HFCs are as escape-prone as CFCs were 30 years ago. They are building up rapidly in the atmosphere and the refill market and leak studies demonstrate that any policy based on ‘containment’ – the current European Commission and UK position, and promoted by the car industry – is, in the words of Roger Higman at Friends of the Earth "pie in the sky". The report tests observed market data for HFC 134a against leak models and concludes that for mobile air conditioning, the best fit is given for high leak rates of 25 – 30% a year, rather than the optimistic 10 – 15% assumed by the car industry and UK government. The report, submitted to the UK f-gas consultation, cites multiple sources to show that * Leak rates for HFC 134a are as bad as for the notorious CFC 12 The report says: * Since the late 1980s the refrigeration and air-conditioning (RAC) industry has instituted a policy of containment in response to concerns over ozone depletion and global warming. Its main aim was to prevent leakage of hydrofluorocarbons (HFCs) from RAC systems; this was to be achieved through both design and operational measures. The author states that extraordinarily, his ‘experience is that many regulators routinely accept containment estimates, even though "real measurements actually proving the lowered refrigerant emission rates are not available", while at the same time simply dismissing criticisms. For instance in 1999 the UK government stated: "New [fire extinguishing] systems can be expected to have average annual emission rates in the range of 1% to 3% of system charge." Even after it was pointed out in consultation that this range goes below that required to extinguish fires, the estimate was not changed’. For more information contact – Australian Court Finds Sanyo ‘Green HFC’ Claims to be Misleading Australia’s Federal Court, has found that Sanyo Airconditioners Manufacturing Singapore Pte* Ltd, trading as Sanyo Airconditioning Australia, engaged in false, misleading and deceptive conduct over advertising of air-conditioning units it supplied. At fault was Sanyo Airconditioning Australia's promotional brochure for the Eco Multi Series air conditioners, which was distributed to businesses and consumers, from about May 2002 to July 2003, contained environmental marketing claims, such as "environmentally-friendly HFC ‘R407C’ Added" and "for a new ozone era – keeping the world green". The ACCC [Australian Competition and Consumer Commission] instituted proceedings against Sanyo Airconditioners Manufacturing Singapore Pte Ltd alleging it had contravened the Trade Practices Act 1974 by making false, misleading and deceptive representations about the environmental benefits of the gases used in its air conditioning units, namely the hydroflurocarbon (HFC) refrigerant R407C and the hyrdochloroflurocarbon (HCFC) refrigerant R22. The court declared that Sanyo Airconditioning Australia’s brochure was misleading and deceptive in breach of section 52 of the Trade Practices Act 1974, and contained false and misleading representations in breach of 53(c) of the Act, in representing that its air conditioning units were environmentally-friendly when in fact: - R-407C employed in its air conditioning units is a powerful greenhouse gas which contributes to global warming, and does not benefit the environment; and - R-22 employed in its air conditioning units is a powerful greenhouse gas which contributes to global warming, is an ozone depleting substance, and does not benefit the environment. The court also ordered that Sanyo Airconditioning Australia: - be restrained from engaging in similar misleading conduct in its future promotional activities; - write to businesses and consumers who were supplied the brochure and also members of the Airconditioning Refrigeration Equipment Manufacturing Association enclosing the Federal Court's orders and the agreed Statement of Facts; - implement a trade practices compliance program; and - pay the ACCC's costs. The court orders were made by consent of the parties. "This outcome sends a warning to businesses attempting to promote their products or services using misleading environmental claims", ACCC Chairman, Mr Graeme Samuel, said after the hearing ended. "Environmental claims, including those in the form of statements, logos and images, must be accurate, clearly identify the environmental benefit to which the claim refers, and must be verifiable. "Environmental marketing claims are an important marketing tool in the air conditioning industry, as well as in other industries. In light of the court’s orders, extra care should be taken by businesses intending to promote the environmental aspects of their products or services to accurately specify the environmental benefits claimed. "During the course of its investigation the ACCC was informed of similar environmental claims being made by other air conditioner manufacturers both domestically and internationally. Accordingly, the ACCC would call on other air conditioning manufacturers to review their advertising to ensure that their environmental claims are accurate and verifiable", Mr Samuel said. Note Sanyo Airconditioners Manufacturing Singapore Pte (correct) Ltd manufactures and distributes air conditioning units, and is a separate legal entity to Sanyo Australia Pty Ltd. (The decision came in November 2003 – sorry we didn’t report this earlier !) For more information contact – Brent Hoare, Executive Officer, Greenchill Technology Association Inc. * * * * * * * * * * * * TEXT OF NGO LETTER TO UK GOVERNMENT RE F GAS CONSULTATION Stephanie Godliman, Dear Stephanie Response to Consultation on EC Commission Proposal for a Regulation on Certain Fluorinated Greenhouse Gases The below are the comments on the above draft regulation, by the following organisations: Friends of the Earth Ltd, Greenpeace UK, Climate Action Network Europe, and the Multi-sectoral Initiative on Potent Industrial Greenhouse Gases (MIPIGGs www.mipiggs.org). We believe the Fluorinated Gas Regulation, as proposed by the Commission, is fundamentally flawed. It falls far short of what is required given the seriousness of the climate threat, recently described by the Prime Minister as the greatest threat facing humankind in the longer term, and by the Government Chief Scientific Adviser as a greater threat than terrorism. The recent report in Nature forecasting mass extinctions of life, only reinforces the gravity of the position. HFCs in particular are on course to become the new CFCs: an entirely avoidable problem of human-made polluting gases, growing almost exponentially in the atmosphere, and have increased 20% in 2001-2002 over the Arctic. Yet this draft, and the UK’s response to it so far, is in no way commensurate. It fails to tackle the growing emissions of these extremely potent greenhouse gases and, subsequently, does not further EU policy on climate change mitigation. It does not recognise the existence and the availability of climate-friendly alternatives and hinders Member States from implementing more effective measures. The only exception is in the section on Mobile Air Conditioning, which the rapporteur (Mr Robert Goodwill) has attempted to weaken considerably. We urge you to strengthen this Regulation and as a bare minimum to support: * A change in Legal Basis (Amendment 30 Flemming): it is important that the basis is Article 175, and not Article 95, in order not to prohibit or discourage action stronger than any regulation, by any Member State; * An inclusion of the Refrigeration and Stationary Air Conditioning sector (Amendment 269 Lucas and Béguin); * An inclusion of the Foam sector (a combination of Amendments 272 El Khadraoui and 271 Sandberg-Fries); * An improvement of the Commission proposal on Mobile Air Conditioning (Amendments 177, 217, 219, 222, 224, 228, 230, 233, 238, and 250 Lucas and Béguin:) * Issue Legal Basis Scope of the Regulation Recovery SF6 Phase-out must start in 2007 and be completed by 2012 at the latest and should cover all new vehicles. ANNEX II (as amended - the changes proposed are in bold) Fluorinated gas Application (AM 269 Lucas Béguin and 270 Flemming) (AM 269, Lucas, Béguin and 272 El Khadraoui) (AM 269, 272) (AM 269 Lucas, Béguin) (AM 269, Lucas, Béguin) (AM 269, Lucas, Béguin) (AM 269, Lucas, Béguin) (AM 272 El Khadraoui) (AM 272 El Khadraoui) (AM 272 El Khadraoui) (AM 271 Sandberg-Fries) (AM 269, Lucas, Beguin) (AM 269, Lucas, Béguin) (AM 269, Lucas, Beguin) (AM 270, Flemming) Footwear (AM 271 Sandberg-Fries) (AM 271 Sandberg-Fries) (AM 271 Sandberg-Fries) (AM 271 Sandberg-Fries) (AM 271 Sandberg-Fries) (AM 272 El Khadraoui) (AM 272 El Khadraoui) (AM 267, Davies) (AM 270, Flemming) Additionally we believe that the regulation should require that: * HFCs should only be used transitionally as replacements for ODS and not for new uses such as car air conditioning We note that there is cross-party support for moves to strengthen the draft in both the UK and European Parliaments, and that UK and other European manufacturers and retailers of alternative technologies include European manufacturers that already produce Greenfreeze are AEG (Germany), Bosch/Siemens (Germany), Calor (UK), Candy Group (Italy, UK), Earthcare (UK), Electrolux (Sweden), Liebherr (Germany), Miele (Germany), Pitsos (Greece), Thompson (France), Vestfrost (Denmark) and Whirlpool (Italy). We urge you therefore to also ensure that the regulation specifies that: * Member States should adopt public procurement policies of utilising alternative technologies to f gases wherever these are available, and undertake technology development and commercialisation programmes with industry to further develop such alternatives Finally, we believe the UK Government stance in favour of containment of HFCs from MACs (Mobile Air Conditioning) rather than their replacement needs scrutiny. Experience from CFC containment and the recent 'fridge mountain' strongly suggests that there will be high levels of leakage and that codes of practice are difficult to make work in a sector made up of SMEs. The appropriate level of detail on the assumptions used to derive the figures is not present and they appear to be 'plucked from the air'. If poor or unrealistic assumptions have been used then the danger is that UK policy is being environmentally irresponsible whilst PRIA [Partial Regulatory Impact Assessment] is giving a veneer of undeserved credibility. The assumptions used in deriving the figures leading to this conclusion should be made public. Yours truly Jason Anderson, Climate Action Network * * * * * * * * * * * * MIPIGGs, the Multisectoral Initiative on Potent Industrial Greenhouse Gases was launched at the Sixth Conference of the Parties of the Climate Convention in 2000. Its website is at www.mipiggs.org (and will be shortly reconstructed). What Is The Multisectoral Initiative on PIGGs ? The MI on PIGGs is an informal multisectoral initiative on potent industrial greenhouse gases. It aims to draw together knowledge and expertise from the sectors of: research and the sciences, from business, voluntary Non Governmental Organisations and from agencies governments, in order to further develop,pursue and implement alternatives, and speed the phase out of such gases. What Are PIGGs ? PIGGs are potent industrial greenhouse gases defined as those which are wholly or principally industrial in origin and are not part of natural biogeochemical cycles and processes. (This distinguishes them from other important greenhouse gases such as CO2, N20 and CH4). The US EPA identifies HFCs as the most significant. SF5CF3 has been identified as the most potent greenhouse gas measured. Who Can Join PIGGs Any individual or organisation which is actively committed to and engaged in one or more of: * Taking practical steps to adopt and promote more environmentally friendly alternatives in order to eliminate use and emission of PIGGs Membership will not be open to any organisation which campaigns, advocates or lobbies for the use or production of any PIGG. The primary activities of MIPIGGs have so far been exchange of information on all aspects of PIGGs aims and objectives; publication and promotion of the newsletter and reports on aspects of PIGGs; education and awareness regarding the threat posed by PIGGs for example with the media; and contributions to the work of relevant national and international regulatory and policy making bodies, for example developing the EU regulation on f gases. To register to receive the newsletter, or to be removed from the list, please contact secretary@mipiggs.org |
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