UK pushes for pragmatic approach to F-gas
May 30, 2023
Leading UK experts have accused the EU of being “blinkered” by ambition in their F-gas revision proposals, pushing for the UK to take a more pragmatic approach.
Speaking at Tuesday’s RAC magazine F-Gas Question Time, Graeme Fox, current IoR president, director of technical at BESA and head of F-gas certification body REFCOM, accused the European Commission of a lack of joined up thinking and the European Parliament of being blinkered by ambition and having an unwillingness to actually discuss the practical implications of their proposals.
Based upon modelling of the EU market, co-speaker Ray Gluckman admitted that the European phase down proposals were going to be incredibly challenging.”I’m quite concerned about the first eight to 10 years,” he said.
Echoing the concerns of their counterparts in Europe, the speakers concerns encompassed many aspects of the F-gas proposals. In addition to the proposed phase down timetables, concerns were expressed over the drive for an early ban on all HFCs and HFOs, the lack of training on flammable refrigerants, future servicing of existing equipment, the potential detrimental effects of the proposals on energy efficiency and the possibility that the proposals will prevent Europe achieving its heat pump installation targets.
Between them, Gluckman and Fox have a knowledge of all things F-gas that is probably unmatched anywhere else in Europe. Ray Gluckman is a highly experienced consultant who has worked on F-gas related projects for 30 years, advising the UK Government, the European Commission, the United Nations and the World Bank. In addition to his current roles, Graeme Fox has spent 18 years as a director of European contractors’ group AREA, four of them as president, liaising with UK and European authorities dating back to the very first F-gas negotiations 20 years ago.
While the current European F-gas regulation (517/2014) was transferred into UK law post brexit. Great Britain now has the opportunity to diverge from the European regulations. The UK industry is pressing ministers to take a more pragmatic approach to its own F-gas revision proposals.
By the same token, there are benefits to some degree of harmonisation between the UK and European regulations, particularly with regard to the position of Northern Ireland, and the UK does have its own ambitious climate change targets.
Divergence
Referring to the UK government’s revision of the regulation, Fox said: “We’re now looking at effectively a new regulation and it does give us that that opportunity to diverge where it actually suits the UK.
“I’ve been pretty vocal over the years since F-gas came in that there are certain aspects of the regulation which have, frankly, never worked for the UK,” he said, referring to, as a for instance, the lack of a register of operatives.
Accepting that from an the point of view of the industry, manufacturers and gas suppliers, divergence from the European regulation was not the preferred option, he said: “However, when we know a regulation just simply isn’t working, then actually diverging from that regulation and those elements obviously clearly makes sense.”
Ray Gluckman agreed that there were benefits in harmonisation, but noted that DEFRA, the UK department responsible, had recognised important differences between the UK markets and the overall EU market. “So, it’s possible that there will be different rules,” he said.
“It’s been actually quite heartening to have a more pragmatic approach by the UK government and DEFRA are actually listening and they’re having proper grown up conversations about it,” Fox added.
Of particular concern is the perceived rush to flammable A3 refrigerants. “Technically we can change over to hydrocarbons on all these systems in many, many cases, but just because something is technically feasible from a manufacturing point of view, doesn’t mean that you can actually apply that in practice in many places in the real world,” Fox said.
Recalling to his days as a contractor, Fox added: “We had massive problems with some of the sites I worked on. I did a lot of MoD work. I did a lot of airport work and train stations. All of these places have very strict bans on the use of anything flammable so that you have massive problems with actually applying flow refrigerants in some of these locations.”
Assumptions
Ray Gluckman questioned the Commission’s analysis report on which the proposals are based. “They haven’t analysed energy properly,” he claimed. “They’ve made sweeping assumptions that propane can be equally efficient to an HFC.”
In the case of the proposed bans on air conditioning and heat pump units in the under 12kW category, Gluckman maintained that they had only analysed R410A, R32 and propane. “They didn’t analyse any other gases. They didn’t analyse an HFO blend with GWP under 150 for example. And the assumptions in the analysis report imply that over half the market from January of next year in the under 12kW, air to air split market – which is massive market – that half of it is going to be on propane by next January and 90% of it by January 2025.”
With less than 1% of that market on propane this year, Gluckman described the assumption that the switch could be made in such a short time frame as “unreal”.
“The likelihood is that manufacturers will rush to put things on the market. They won’t have time to optimise and the efficiency will drop. As soon as the efficiency drops, you’re going to get more greenhouse gas emissions from the extra energy consumption than you’re saving from a little bit of HFC. And that is particularly true about heat pumps. If we do anything to slow the rollout of heat pumps we will massively increase the amount of fossil fuel emissions over the next say five to 10 years.”
Training
Training, or a lack of it, was another worry, particularly when it came to handling flammable A3 refrigerants like propane which are currently unregulated under F-gas.
“Don’t forget that the massive rollout of propane systems is a roll out of millions of heat pumps and split systems that are completely unregulated because they are out of scope of the regulations, which means technically, you don’t have to have any qualifications,” Fox said. “You don’t have to have any registration. Any Tom Dick or Harry can install a propane split system under law. And that’s just crazy!”
Fox also insisted that while hydrocarbon training and flammable training courses are available and being taken up in the UK, this was not the case in much of Europe. “A lot of the countries across Europe haven’t even created their flammable training courses yet, let alone set up training centres to deliver them. So there are literally hundreds of thousands of technicians and AC and fridge engineers right across Europe, who are already handling, or will be handling, flammable refrigerants in the very near future who have had zero training in the implications of refrigerants and that’s clearly not a safe prospect.”
Graeme Fox revealed that in talks with DEFRA over the Great Britain regulations he has been pushing for the inclusion of all refrigerants in the regulation. Insisting that they all have global warming implications, he said: “Just by taking the word fluorinated out of the regulations, we actually include every single refrigerant, except ammonia. And it’s a really simple process, because everything, even CO2, is a greenhouse gas. It just becomes a greenhouse gas emissions regulation. It’s a really simple process.”
A UK government response is due towards the end of this year but new F-gas regulations for Great Britain are not likely to come in until 2025.