ACRIB commentary on F Gas Review - 14/12/2011

ACRIB has submitted this commentary as part of its response to the Commission Consultation on Effectiveness of the F Gas Regulations which closed on 19th December 2011.

"ACRIB encourages 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 member states

·    Acknowledge the evidence that demonstrates containment is working, and the Regulation needs only technical adjustment and inclusion of certain 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 taken to maximise compliance with the F Gas Regulation and achieve emissions reductions now.

 

The key policy options necessary to achieve this are:

1.The introduction of single national databases for verification of individual and company certificates.

2.That suppliers be responsible for ensuring that only appropriately certified companies are supplied.

3.An awareness campaign aimed at equipment operators covering enforcement in combination with a ‘non-compliant’ operator reporting service.

4.More active enforcement and increased policing of operators’ legal obligations under the Regulation to take place.

5.Member states to report to the Commission on compliance levels and to ensure more robust auditing of all company and individual certification authorities.  

 

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 greater reductions in emissions and is an affront to environmentally 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 restrictions on sale of F gas refrigerant or equipment designed to contain F gases and improved technical and training specifications to prevent leakage from new equipment and associated components.

 

Technical experts should be able to select the widest possible choice of refrigerants taking into account energy efficiency, safety, technical feasibility and containment issues. Legislation which forces the use of certain refrigerant options could compromise any of these criteria with serious consequences.