Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by Calor Gas Ltd (U14)


  F-gas emissions (mainly hydrofluorocarbons—HFCs) are growing faster than other greenhouse gases (GHGs), with far more powerful global warming potential (GWP). They are manufactured, mostly for use in refrigeration and air conditioning, even though there are better alternative technologies on the market. Between 1992, when Greenpeace demonstrated the viability of alternative hydrocarbon (HC) refrigeration, and 2002, global HFC production increased more than 20-fold. Government allowed F-gases to replace ozone-damaging CFCs; while HFCs do not damage the ozone layer, they have a powerful GWP: the most common, HFC-134a, is 1,300 times worse than CO2. EU Member States are now deliberating how far and how fast HFCs should be phased out. This is a rare opportunity for action on an EU-wide basis and, if it is missed, the damage done will take years to remedy. The UK's contribution to this effort and these negotiations should be more ambitious than is currently apparent.


    —  The UK should use its influence with the US Administration, building on recognition of global risks from climate change, to secure support for the Kyoto approach, especially regarding HFCs (para 4).

    —  Action on HFCs is imperative, otherwise there will have to be more drastic reductions in transport and energy emissions (both currently growing fast), measures which may carry economic costs and distortions and test the political will of governments (para 13).

    —  A clear alternative to even more costly investment either to recover or contain HFCs is not to use HFCs in the first place (para 14).

    —  The Government should be more rigorous in implementing its commitments over HFCs in the procurement decisions made by Departments and Agencies (paras 18-20).

    —  Most importantly, in the negotiations and discussions on the EU F-gas Regulation, the Government should put its weight on the side of certain Member States which otherwise face the prospect of the EU over-riding their "greener" domestic legislation; in so doing, the UK will help to achieve more towards phasing out HFCs and encourage the acceptance and use of alternatives (para 23).


  1.  Calor Gas Ltd has since 1994 marketed the CARE range of hydrocarbon (HC) refrigerants; it accounts for less than 0.5% of the company turnover, which mainly consists of the distribution and retailing of liquefied petroleum gas (LPG). HCs are one of several environmentally friendly so-called "Not-in-Kind" (NIK) alternatives to HFCs—energy efficient, safe and with negligible global warming effects. NIKs include water, air, CO2, and ammonia. For public policy rather more than commercial reasons Calor has for several years worked alongside environmental organisations, including Globe UK All Party Parliamentary Group and NGOs such as Climate Action Network (CAN) Europe, Greenpeace, Friends of the Earth, and WWF UK in advancing the case of NIKs over hydrofluorocarbons (HFCs).

  2.  This submission will discuss the role of HFCs in climate change, and pertinent Government policy; the wider elements of the climate change programme will be referred to only in so far as they are relevant to the HFC issue.


  3.  The UK Government's Chief Scientific Adviser, Professor Sir David King, recently stated, "In my view, climate change is the most severe problem that we are facing today, more serious even than the threat of terrorism." (Science, 9 January 2004).

  4.  The study "Abrupt Climate Change" (2003), produced by Global Business Network for the US Defense Department, states that climate change "should be elevated beyond a scientific debate to a US national security concern", with catastrophic climate change—involving flooding, drought, famine, civil disorder and international conflict—as being "plausible" and challenging "US national security in ways that should be considered immediately". This would suggest that representations made by the UK Government to the US Administration on the Kyoto Protocol generally and HFCs in particular might not entirely fall on stony ground.

  5.  The UK Climate Change Programme 2000 stated: "HFCs are not sustainable in the long term". The Deputy Prime Minister confirmed "a clear signal to industry that HFCs have no long-term future" (9 March 2000). Caroline Spelman MP, then Shadow Environment Secretary, said, "The decision to replace CFCs with HFCs was a dirty deal . . . HFCs are a major contributor to the greenhouse effect" (EU Standing Committee A, 14 January 2004, col 16). Sue Doughty MP, Liberal-Democrat Environment spokesperson said: "The Government seem to have watered down their proposals . . . We need much greater ambition . . . in the end, we just say `we will make it less bad'. I would like fluorines to be phased out much faster" (loc cit, cols 7 and 18).

  6.  The Prime Minister stated on 14 September 2004: "What is now plain is that the emission of greenhouse gases, associated with industrialisation and strong economic growth . . . is causing global warming at a rate that began as significant, has become alarming and is simply unsustainable in the long-term . . . By unsustainable . . . I mean a challenge so far-reaching in its impact and irreversible in its destructive power, that it alters radically human existence. . . . Its likely effect will not be felt to its full extent until after the time for the political decisions that need to be taken has passed" Among several pieces of evidence, Mr Blair cited: "Swiss Re, the world's second largest insurer, has estimated that the economic costs of global warming could double to $150 billion each year in the next 10 years, hitting insurers with $30-$40 billion in claims." As a clear indication of further ambition on this issue, he added: "We have to recognise that the commitments reflected in the Kyoto protocol and current EU policies are insufficient, uncomfortable as that may be."

  7.  While Mr Blair did not refer to HFCs as such, the Leader of the Opposition, Rt Hon Michael Howard MP, was very specific: "We must be more active in removing the causes of harmful emissions where we are able to. I can announce today that the Conservatives are committed to phasing out the use of hydrofluorocarbons, or HFCs, between 2008 and 2014 . . . HFCs currently account for 2% of the UK's greenhouse gas emissions and that will have doubled by the end of the first decade of the 21st century. Unless . . . the Government gives a clear lead, then the situation will only worsen." (13 September 2004)


  8.  Fluorinated GHGs, including HFCs, are used in refrigeration and air-conditioning, including vehicle air-conditioning, foam blowing, solvents, aerosols and other products. These largely replaced chlorofluorocarbons (CFCs), banned under the 1987 Montreal Protocol because of their potential to damage the ozone layer. While HFCs do not damage the ozone layer, they have a powerful GWP. The most common, HFC-134a, is 1,300 times worse than CO2. HFCs are among the gases which the Kyoto Protocol commits the EU to reducing by 8% overall by 2008-12 compared to 1990. While CO2, methane and N20 levels are steady or rising slightly in Europe, HFC emissions are growing very fast—between 2000 and 2010 these may at least double, to represent a third of the UK's commitment under Kyoto.

  9.  In Germany, over 95% of domestic refrigerators use HCs: these do not damage the ozone layer, have an almost negligible GWP, are a safe and proven technology and are also cost-effective. Sweden, Austria and Denmark have all proposed both bans and taxes on HFCs; Switzerland has also proposed bans; the Netherlands have developed a tough voluntary system known as STEK.

  10.  An EU regulation on F-gases is being considered in 2004-05 by EU Member States and the European Parliament. The issue is how far and how fast HFCs should be phased out; it is a rare opportunity for action on an EU-wide basis and, if it is missed, the damage done will take years to remedy.

  11.  The Regulation relies for its expectations of HFC containment on using a version of the apparently rigorous Dutch containment scheme known as STEK. Not only is the version envisaged in the Regulation weaker than STEK, but there are doubts as to whether this—perhaps effective in a small, well-organised country like the Netherlands—can be rolled out across the whole EU. The information on which it is claimed that STEK has achieved a 4.8% leakage rate comes from voluntary (importantly, not random) responses to a survey in which only 334 of 2,140 registered companies replied!

  12.  At a conference on climate-friendly refrigeration technologies on 22 June 2004, supported by Greenpeace and the UN Environment Programme, Coca Cola announced it will switch out of HFC foam and that it expects to use natural refrigerants in new equipment from around 2006; Unilever Ice Cream will from 2005 buy only HFC-free freezers; McDonalds is understood to have undertaken to convert 30,000 of its restaurants to alternative refrigeration. However, companies and public authorities will only be incentivised to adopt alternatives if it is clear that, for example, the EU, is committed to a firm programme of HFC phase-out ie one that will impact upon their direct competitors and not leave these companies isolated.


  13.  HFCs currently account for 2% of EU's greenhouse gas emissions, compared with CO2's 80%, but their usage is rising rapidly—particularly with the increased demand for air-conditioning of vehicles and buildings. The HFC industry itself forecasts that HFC production in 2007 will be three times greater than it was in 2001. The 2004 Budget Report stated (para 7.8 and chart 7.1) that UK CO2 emissions are down only by 8.7% since 1990, and running level or slightly increasing since 1997, well above the Kyoto target for 2010. The International Energy Agency warned on 2 March that, "Energy savings rates across all sectors and in almost all countries have slowed since the late 1980s, as has the decline in CO2 emissions relative to GDP". Without action on HFCs there will have to be further reductions in transport and energy emissions (both currently growing fast). Such measures may carry economic costs and distortions and, in view of their unpopularity, will test the political will of EU Governments.


  14.  Most HFC emissions come from leakage during use or disposal. The HFC lobby claims that pollution can be minimised by reducing leakage, and this view is favoured both by the EU Commission and the UK Government. However:

  (a)  Atlantic Consulting's study ("HFC Containment has already failed", first produced in February 2004, and published in Atmospheric Environment, a peer-reviewed journal, in August 2004) shows that "leak rates of HFC-134a over the period 1990-2000 are the same as they were for its predecessor, CFC-12, in the mid-1980s." Atlantic concludes: "Clearly, HFC containment has failed . . . This paper calls into question the use of containment as a policy tool for controlling HFC emissions.

  (b)  The CFC recycling programme for redundant refrigerators is a costly failure: more than half of all CFCs supposed to be recovered escape to the atmosphere (RAL Quality Assurance Association for the De-Manufacture of Refrigeration Equipment, reported in RAC Magazine, March 2004).

  (c)  The HFC industry has campaigned against the controls proposed on HFC uses in vehicle air-conditioning (MAC). In 1997, only 9% of new cars sold in Europe had MAC: by 2003 it was fitted in 80% of new cars sold in Germany. A 31-fold increase between 1995 and 2010 in MAC-related GHG emissions is predicted. Yet these HFCs were not in replacement of CFCs, but an entirely new use (totally at variance with HMG's commitment). In addition to leakage during usage, there will be the costly problem of preventing leakage when vehicles are abandoned or disposed of.

  (d)  After a stakeholder consultation by the EU in 2003, industry estimates of leak-rates from MAC were corrected upwards by 40% (Proposed F-gas Regulation, p 4 COM (2003) final).

  (e)  Every year the UK reports GHG emissions to the United Nations Framework Convention on Climate Change (UNFCCC), with apparently a 2-year lag, ie 1998 emissions reported first in 2000. Furthermore, the UK reports revisions for preceding years: in 2004 the UK revised year 2000 emissions of HFCs, first reported in 2002, upwards by, it seems, 25.6%.

  It is thus not surprising that in 2002 atmospheric levels of HFCs measured over Spitsbergen were 20% higher than in 2001 (ENDS Daily 6 February 2004). A clear alternative to even more investment either to recover or contain HFCs is not to use HFCs in the first place.


  15.  The German Environmental Protection Agency produced in February 2004 a 240 page report identifying, in detail, existing alternative technologies or processes for every use of F-gases in over 20 sectors ("Fluorinated Greenhouse Gases in Products and Processes:—Technical Climate Protection Measures"—Report of the Federal Environmental Agency, Germany 20 February 2004 Federal Environmental Agency

  16.  The report shows that F-gases are not necessary for the following uses: refrigerants in domestic refrigerators and freezers, commercial or industrial refrigeration, stationary air conditioning of buildings or transport, stationary or mobile air-conditioning units (domestic, commercial, industrial); in domestic heat pumps; as blowing agents to make rigid foams for thermal insulation, flexible polyurethane foams, integral skin polyurethane foams or one component foam; as propellant in technical sprays, medical aerosols, aerosols in households and cosmetic aerosols, in aerosols intended for decorative purposes, party supplies and claxons, fire extinguishing, etching semi conductors circuit board production, extinguishing and electrical insulating gas (switch-gear) cover gas for magnesium processing, degasser for secondary aluminium casting and, filling gas for car tyres. (The exceptions are HFCs in pepper sprays and non-domestic insecticides.) It also identifies many new alternatives currently in testing, and measures to reduce emissions.

  17.  The authors state that future emissions will "increase enormously" owing to replacement of CFCs and that systems which use CO2 as refrigerant (not HFCs) "are now ready to go into production". Forecasts predict a continued sharp rise in the use of F-gases. In 2020, fluorinated GHGs are anticipated to have a global annual market volume of up to 500,000 t, Europe accounting for up to 100,000 t of this. In Germany HFC emissions and related emissions will have increased between 1995 and 2010 by approximately 270%. Many German cars are being scrapped in countries without adequate CFC or HFC recovery systems. "Taking all aspects into account, it can be concluded that CO2 is the best refrigerant" for car air conditioning.


  18.  Evidence of the UK Government's disappointing implementation of its environmental commitments is manifested by various recent procurement decisions which, despite specific commitments, use HFCs. Beverley Hughes MP, as Parliamentary Under-Secretary of State for DETR, stated, "Our policy is to switch, where possible, from hydrofluorocarbons (HFCs) . . . to environmentally-preferable substitutes"(WA 9 March 2001), thus reiterating the statement in "Climate Change-The UK Programme" (November 2000) that "HFCs should only be used where other safe, technically feasible, cost effective and more environmentally acceptable alternatives do not exist".

  19.  HFCs have been used in the following: refurbishment of No 10 Downing Street, the new GCHQ at Cheltenham, the MOD Whitehall complex and RAF High Wycombe, Great George Street Treasury Building, the Home Office at 50 Queen Anne's Gate, a building leased by DEFRA in Temple Quay Bristol, and the DFID office, 20 Victoria Street. More recent failings include: the HSE new building in Bootle; MOD Admiralty Arch, London; Romford Hospital PFI project; British Cattle Market Service, Workington (part of DEFRA); Windsor Library, Imperial College; University of London Tanaka & HQ buildings; and Liverpool University Surface Science Building. The Observer reported the Meteorological Office's new £150 million headquarters in Exeter has installed an HFC air-conditioning system (26 September 2004).

  20.  A Government backbench MP, Jane Griffiths, spoke as follows in 2002: "The Foreign and Commonwealth Office . . . asked about the coolant for the new Government communications headquarters building . . . said that the building will use the refrigerant HFC134A . . . HFC 134A was responsible for 2.61 million tonnes of greenhouse gas emissions in 2000. That is not quite the Government climate change policy of not using HFC unless there is no choice . . . The Secretary of State for Health provided me with a list of 77 building projects currently under way . . . The Department did say that [the] NHS Model Engineering Specification . . . advises that HFC 134A or 407C and its associate blends are used. That is even further from the climate change policy . . . The Lord Chancellor's Department . . . has a number [of building projects] in the planning stage and . . . [takes] no consideration of climate change impact. Disappointingly, the Government are not doing very well in implementing their own climate change policies," (Hansard, 24 May 2002, cols 570-71).


  21.  The draft Regulation aims to limit emissions of three F-gases controlled by Kyoto: it sets maximum leakage rates and equipment monitoring rules, and phases out HFC-134a. It has been weakened from its original drive against HFCs by heavy lobbying by the well-funded body, EPEE, established by largely US HFC manufacturers and their allies. Now, it requires no use of alternative technologies; it does not restrict HFCs to "essential uses" nor does it impose concrete bans.

  22.  The Commission proposed to proceed by way of the internal market clause (Article 95) of the Treaty, preventing individual Member States introducing tougher national measures. Several, like Denmark, Austria and Sweden, already possess or are planning tougher legislation, which they might be obliged to roll back. To avoid this, some Member States are arguing for the Regulation to be related to Article 175, the basis of environmental regulation, so that the Regulation would set a minimum environmental target which individual countries might exceed. The UK Government has opposed this.

  23.  With the expectation that the Regulation would proceed on a single market basis apparent in the autumn of 2004, Calor, supported by environmental NGOs, has proposed the following modest amendments:

  (a)  To use the Article 175 (environment) legal base for everything apart from mobile air conditioning, which would understandably, as vehicles are traded across the EU, come under the single market clause. Calor understands that the UK Government opposes this option and that even if this option were taken, because of the legal pre-eminence of the single market, Member States would be forced under legal challenge to withdraw tougher measures. (The irony is that this does not prevent individual states—like France—from having restrictive legislation that effectively rules out the use of non-HFC equipment).

  (b)  To aim to be more ambitious within an Article 95 legal base (ie extending the use restrictions or bans into other areas, with the UK supporting Denmark, Austria, Sweden and Belgium in their possible amendments). Calor understands that the UK Government would oppose any extension of the boundaries of bans or phase-outs because no cost or environmental benefit analysis has been carried out and that it would not be possible to do this before further decisions had to be made at the Council of Ministers meeting in October 2004. Specifically, Calor proposed a restriction on the use of HFCs in domestic refrigerators (as the market was now mainly non-HFC). One advantage would be that this would put an end date to the need to recover HFCs from fridges (under the WEEE Directive). While domestic fridges have low leakage during use, by the time they come to disposal all the gas has usually leaked. (The Government is understood to take the view that as this market is mostly non-HFC, a ban would have little effect—ignoring the symbolic aspect, the WEEEaspect and the fact that the proposed F-Gas regulation will ban HFC applications which have never even been put on the market!)

  (c)  Calor also proposed HFC restrictions in the field of commercial refrigeration, arguing that without some lead from Government (through regulation), the industry would stay with HFCs; this would act as a disincentive to those companies who had shown that they were prepared to take the initiative (see para 12 above).

  24.  The UK Government is understood to be opposed to all these proposals. This is a tribute to the strength of the F-gas lobby, which in stakeholder consultation usually musters a very large majority over Calor, perhaps one or two other NIK users (but most HC users are also, and on a larger scale, HFC users) and green NGOs. It also indicates that, at European Commission level, DG Environment's aspirations have been firmly blocked by DG Enterprise. The same occurred in the UK, where DEFRA is the "lead" department, but has been firmly blocked by the DTI. This, indeed, raises an important political point. The F-gas lobby has a greater share of voice because it represents the majority vested interest "status quo". If Governments had paid attention in the past to share of voice rather than quality of argument, CFCs would never have been banned.

  25.  Unless the UK Government changes its policy on the Regulation, or other Member States, or the European Parliament, defeat this position, those wishing to encourage alternatives to HFCs will have to wait until the Commission reviews the Regulation some four years after it comes into force—probably in 2010. Allowing then for phasing of any new measures, as one HC producer has commented to Calor "I would say HFCs have got a free run in until at least 2015 and beyond."

30 September 2004

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