F Gas ReviewThe contractors’ view

Graeme Fox F.Inst.R

President, AREAAir Conditioning & Refrigeration European contractors’ Association

(www.area-eur.be)

XV European Conference, Milano, 7th/8th June 2013

Air Conditioning & Refrigeration

European Contractors’ Association

20 Members from 17 Countries• > 9,000 companies

• > 125,000 employees• Combined turnover approx. 20 billion Euros

• But almost all SMEs of less than 20 people each• Direct employment of European workers

• Design, installation, maintenance and repair of RACHP systems of all types and using all refrigerants

AREA Position Papers

All available from http://area-eur.be

AREA position on review proposals: December 2012AREA position paper: October 2010

Pre-charged non-monoblock position: October 2010Joint AREA/EPEE position on certification: March 2011

& more

Contractors’ main concerns:

•Training & certification

•The service ban

•The pre-charge ban

Training & certification

Mandatory competence assessment not mandatory training!

Competence can be assessed by examination and testing.

Modular tests for alternative gases.

Knowledge is the important thing and that can be proved by testing.

Training should only be for those who cannot demonstrate the required level of technical knowledge.

Training & certification

Mandatory competence assessment not mandatory training!

Competence can be assessed by examination and testing.

Modular tests for alternative gases.

Knowledge is the important thing and that can be proved by testing.

Training should only be for those who cannot demonstrate the required level of technical knowledge.

Renewal of certificates every 5 years

Service ban

•Threshold limits too low:2500 GWP CO2 equivalent equates to only 1.28 kgs of R404a

meaning small end users would be hard hit by the bans with few alternatives available in reality

•Some drop-in gases replacing HCFCs are above the 2500 limit

•Entry date of 2020 doesn’t leave enough time to plan

•Need to allow use of recycled gases – not provided for in proposal

What is the purpose of F Gas Regulation?

Minimising emissions of fluorinated greenhouse gases

What is the purpose of F Gas Regulation?

Minimising emissions of fluorinated greenhouse gases

Competence assessment is essential

What is the purpose of F Gas Regulation?

Minimising emissions of fluorinated greenhouse gases

Competence assessment is essential

But so is ensuring professional installation & servicing!

What is the purpose of F Gas Regulation?

Minimising emissions of fluorinated greenhouse gases

Competence assessment is essential

But so is ensuring professional installation & servicing!

Restricting sales of gas bottles is not enough

What are the consequences?

Unprofessionally installed systems are not properly leak tested which leads to high rates of leakage – often total loss of refrigerant

What are the consequences?

Unprofessionally installed systems are not properly leak tested which leads to high rates of leakage – often total loss of refrigerant

Restricting supply of gas bottles does not affect the unregulated sector because they tend to install small splits with all the necessary

refrigerant already charged at the factory

Market size for small splits

Market for small split air conditioning / heat pump units is estimated at 7 million units sold in EU every year 10,500 tonnes of HFCs

Market for domestic heat pumps alone is estimated at 20 million installed by 2020

1 million small splits were sold in Italy alone in 2010:Under current situation there is no way of verifying that the installations were carried out by certified professional and no way of tracing where the gas has

gone.

Market size for small splits

Market for small split air conditioning / heat pump units is estimated at 7 million units sold in EU every year 10,500 tonnes of HFCs

Market for domestic heat pumps alone is estimated at 20 million installed by 2020

1 million small splits were sold in Italy alone in 2010:Under current situation there is no way of verifying that the installations were carried out by certified professional and no way of tracing where the gas has

gone.

21.9 million tonnes CO2 equivalent every yearSo 10% leakage means 2.2 million tonnes equivalent leaked every year!

A missed opportunity?

Failing to stop pre-charging non-monoblock systems would:

• Ensure installation by non-certified professionals continues in breach of the regulations

• Increase F-gas use because gas will continue to leak unabated• Make controls on refrigerant use harder for authorities

• Harm responsible European SME contractors