ACRIB is seeking feedback from the industry as part of the f-gas review, to make the most of the UK's experience of the implimentation of the regulations from organising training courses to applying for company certificates.
The European Commission's consultation as part of their review of the effectiveness of the f-gas regulations is focused on what additional new policies should be introduced to achieve radical reductions in emissions rather than on extending what has worked well with existing regulations, which needs to be more thoroughly applied across Europe.
Early indications suggest that f-gas emissions in the UK have decreased in the last 2-3 years according to a review from ACRIB. Whilst this is good news for British industry, the consultation is largely focusing on the European picture. As such ACRIB's draft response to the Commission on behalf of the UK industry tries to redress the balance, prepared with input from key trade associations and professional institutes to highlight the most effective policy measures based on evidence of effectiveness in the UK to date.
Before a final answer is delivered to the Commission ACRIB is calling on the wider industry to participate so that comments can be fed back directly to the commission.
The full ACRIB document is available here: www.acrib.org.uk/fgasreview with detailed comment being requested by 1 December.
The document sets out the following main points for comment:
ACRIB would like to encourage the Commission to focus future much needed policy measures on those which support the progress already achieved by industry in reducing emissions ie:
· Improve legislation, compliance and enforcement in all countries
· Acknowledge the evidence that demonstrates containment is working, and that regulations need only technical adjustment and inclusion of additional requirements to make further savings.
· Reassure businesses that they should continue to invest in compliance and containment. This consultation is sending out a message that an F Gas phase down is imminent and is therefore undermining actions to maximise compliance with f gas and achieve emissions reductions.
The key policy options necessary to achieve this are:.
1. The introduction of single national mandatory individual registration and company certification scheme members
2. That refrigerant suppliers be responsible for ensuring that only appropriately certified individuals can be supplied with F Gas refrigerants.
3. An awareness campaign aimed at equipment operators covering enforcement in combination with a 'non-compliant' operator reporting service.
4. Member states to report to the Commission on compliance levels and to ensure more robust auditing of all company and individual certification authorities.
5. More active enforcement and increased policing of operators' legal obligations under the Regulation to take place
The UK industry is concerned that in many member states a failure to introduce national legislation within the required timescales and low levels of enforcement where national regulations exist have undermined the potential of these Regulations to achieve reductions in emissions and is an affront to environmental responsible companies and individuals that have invested in compliance.
The Commission needs to be more vigilant in ensuring full compliance by all member states. In addition, minor adjustments at national level on enforcement mechanisms would have a major impact on effectiveness ie restricting the sale of F gas refrigerant or equipment designed to contain F gases to those suitably qualified, harmonisation with relevant industry standards including EN 378 and EN 16084 and improved technical specifications to prevent leakage from new equipment and associated components.
Finally in order not to compromise indirect emissions (which make up the vast majority of this sector's contribution to global warming), industry experts should be able to select the widest possible choice of refrigerants taking into account efficiency, safety, technical feasibility and containment issues. Legislation which forces the use of certain, as yet unproven, refrigerant options could compromise any of these criteria with serious consequences.
Final comments must be submitted to the Commission by 19 December 2011. Draft proposals are expected to be issued in early 2012 and will take into accounts the results of the consultation.