Political interference is in the air again, this time in Brussels with the usual half thought out policy with little or no understanding of consequence of actions.
The EcoDesign Directive is aimed at improving energy efficiency of energy related products, including split air conditioning and heat pump systems. This is all very laudable and I don't think anybody would object to this move. However, in the process of working out the details of the Directive, the stakeholder meeting was presented with a consultant's working document which appears to be straying worryingly towards the F Gas Regulation review.
The F Gas review process has been on-going for about two years now and the Commission seem too have taken on board much of what the various stakeholders have been saying - particularly with regard to technical limitations on some of the alternatives being suggested: energy efficiency drops, lack of skills and/or equipment, safety issues, etc. The problem is that F Gas is dealt with by DG Climate, whereas EcoDesign is in the domain of DG Enterprise and DG Energy. The EcoDesign study is now looking at potential bonuses for "low GWP gases", whatever that's supposed to mean, and bans as soon as 2015 for some products using gases with GWP above 675. Most discussions on "low GWP" tend towards less than 150, as with auto AC for example, so why does this study mention a GWP level of 675 or below? 675 is conveniently the GWP level of R32 (see previous blogs for my thoughts on that!) Maybe I'm just being cynical but could a certain AC manufacturer have had a hand in drafting the working document?
The worrying thing about all this is that any thoughts on specific refrigerant types should not be written into any Directive that is about energy efficiency. Concerns about fluorinated gases should be restricted to the F Gas Regulation review - in other words, in the domain of those who understand the issues. If EcoDesign does go down this route there is a real possibility that people will be drawn down a route whereby the equipment actually becomes less energy efficient!
I've said before that if we can improve F Gas to make it more effective then the emission levels are minimised, and gases that are safely contained in sealed leak free systems do not have any effect on the environment. Far too much attention is paid to GWP levels - they've become the be all and end all to many lobbyists and politicians, partly because numerical figures tend to be influential even if at times they are misleading.
Even more concerning about this move within the framework of EcoDesign is that the UK alone seems concerned about it. Speaking with Defra representatives last week in Brussels at an industry conference it transpired that they are concerned about this move too - which is heartening from a UK industry perspective - but the UK alone is sadly just one voice. European institutaions like AREA are now asking members across the EU to highlight this potentially ludicrous move in the hope that, when the decisions are made, the UK is no longer alone in seeing the potential conflict between two pieces of legislation.