Eco ambition is good but not at any cost
The European Union wants to lead the world in the transition to low global warming potential (GWP) substances, but it cannot ignore other factors – not least safety, according to Graeme Fox of the Building Engineering Services Association (BESA).
It is good to be ambitious. Defined as ‘an earnest desire for some type of achievement or distinction’, ambition drives progress. However, it should not override every other aspect of a proposal, particularly if the unintended consequences could be damaging to the planet or even downright dangerous.
So, how ambitious should we be about technology? If we can achieve our goals technologically, shouldn’t we just get on, and do it?
Take artificial intelligence (AI), for example. It is all around us in the modern world and, in the main, it is seen as a positive development that speeds up access to useful services and problem solving. An AI programme could probably have written this article…maybe it did. Would that be a good thing? There are opinions expressed here, so could AI be telling us how to think? What about the dark side to AI?
As with all such debates, all the pros and cons need to be considered.
So, it is with the ‘ambitious’ new targets proposed by the European Parliament in its revision of the F-Gas Regulation to reduce the global warming impact of the refrigeration and air conditioning industry. It is keen to dramatically speed up the removal of f-gases from use in stationary refrigeration, air conditioning and heat pump systems because it is now technically feasible.
However, member states are already pushing back, and other countries are looking on with some scepticism – not least in Africa and the UK.
While applauding the ambition of European administrators to show global leadership on tackling climate change, they must be careful as the new phase down timetable being proposed could have potentially lethal consequences, particularly in the developing world.
It would require a dramatic acceleration in the adoption of alternative refrigerants, which will increase the amount of flammable gas in use. This would create serious safety concerns because the industry’s workforce is not yet fully trained in the use of flammable refrigerants.
Also, if the UK decides to adopt the new restrictions it could undermine its programme for increasing heat pump installations and lead to the premature removal of thousands of installed systems with a useful operating life of at least 15 years. That would make no sense environmentally and could be financially ruinous for many end users.
The Parliament is proposing a ban on single split systems using less than 3kg of HFCs with a GWP of 750 or more from January 1st, 2025. Any stationary self-contained refrigeration equipment that contains F-gases with a GWP of 150 or more will also be banned from that date.
From the start of 2027, it proposes a ban on plug-in room and other self-contained air-conditioning and heat pumps (including monobloc systems) with capacities up to 50kW containing F-gases as well as a ban on air-to-water split systems with a rated capacity of up to and including 12 kW – if they are using HFCs with a GWP of 150 and above.
It then envisages removing all plug-in AC and heat pump equipment operating on F-gas with a GWP greater than 150 from January 1st, 2030.
A ban on air-to-air split systems with a capacity of up to and including 12kW and operating on HFCs with GWP of 150 or more would come into force from 1 January 2029 along with the removal of split systems with capacities of more than 12kW, operating on HFCs with GWP over 750.
Then from the start of 2033, there would be a ban on split systems over 12kW operating on HFCs with a GWP over 150.
There are some exceptions for installations with specific safety considerations, but the overall impact would be a major upsurge in the use of flammable alternatives.
The UK has continued to mirror the F-Gas Regulation despite its departure from the European Union, but this is definitely one occasion when we should be making up our own mind about which rules to adopt. We need to consider the full picture.
However, whichever way we go, decisions made in Europe have international significance. The rest of the world looks to it for leadership and manufacturers will have to adjust their global strategies to reflect major changes in one of its largest markets – so this will be significant for worldwide product development.
The African industry is not happy about being used as a ‘guinea pig’ for the introduction of alternative refrigerants and has already recorded several deaths linked to flammable substances. The U-3ARC, which represents companies in all 54 African states, has called for a halt to their introduction until technicians are properly trained – for their own safety and that of the public.
“This preliminary training must be accompanied by a vast awareness campaign among end users of these technologies which can cause disasters for humans, in terms of fires, even if they are beneficial for the environment,” the organisation said in an open letter.
It said the risks were “enormous” and that “the protection of the environment only makes sense if the human being, who is at its centre benefits from it” and is not put in danger.
In July, the United Nations Environment Programme (UNEP) will launch its long-awaited Refrigerant Drivers’ Licence (RDL) scheme. It is designed to raise professional standards internationally giving the developing nations access to the same technical progress and training on safe refrigerant handling that we take for granted in Europe and other developed markets.
This is a major development for the industry worldwide and will save a lot of lives. However, it cannot transform the sector overnight. It will take considerable time to get technicians up-skilled, certified, and able to work safely with the new generation of refrigerant gases, so it is vital that we do not jump the gun and start flooding the market with alternative systems before the workforce is competent to work with them.
And this does not just apply to Africa. Many of the developed nations are struggling to keep up with the existing HFC phase down programme and most of us do not have fully trained workforces ready to work with flammable gases.
There are major skills gaps in every sector and, while the training is in place, there is still a lot of work to be done to get everyone trained up and ready – and that is without any sudden acceleration like the one proposed for the F-Gas Regulation.
The European Commission, the European Parliament and the Council of the European Union have still to agree on the final wording of the proposed revisions and industry groups representing manufacturers, contractors, and end users, rightly said they would continue to lobby for “a more realistic phase down timetable”.
Of course, we should continue leading the way in transitioning the world towards more environmentally benign refrigerants, but just because something is technically feasible does not mean it is morally or professionally applicable in the real world.
Transitioning too quickly could put a lot of lives at risk and is not necessarily the right thing to do for the environment either. Just because you can, technically, do something does not always mean you should.