Last week the European Commission published its review (COM 2011/581) of the fluorinated gases (F-gas) Regulation (842/2006). It was a depressing confirmation of what we NGOs predicted years ago: the leak-prevention approach doesn’t work nearly as well as intended. The Commission’s new ideas about policy moving forward could have been copied almost verbatim from the position I wrote for CAN Europe in 2000.
In 2005 I reviewed the Dutch ‘STEK’ system[1], the approach upon which the EU regulation was based. Leakage rates based on selective self-reporting seemed unlikely to be accurate, and thus costs of abatement would likely both be much higher than the €18.32/tonne CO2 predicted by the regulation – as high as €50/tonne or more.
Fast forward to last week: the European Commission confirmed that there was ‘low overall compliance’ with containment provisions. Under ‘best case’ assumptions about improved containment and recovery, the cost in 2015 will be about €41/tonne – more than double the predicted cost, assuming everything starts going to plan.
Despite poor implementation, the calculated savings compared to BAU is roughly as hoped for by the regulation. What’s up with that? First, the good news: putting in place a regulation sharpens people’s minds about alternatives. Across the spectrum of equipment, non-F gas equipment is gaining ground on its own merits of efficiency and cost-effectiveness.
Second, the not-so-good news: the calculations assume a dramatic improvement in compliance in the next 5 years, after which emissions will roughly stay where they are through 2050, around 110MT CO2eq. per year. The policy of 80-95% reductions for the whole economy by 2050 would mean total emissions of around 275-1100 Mt/year. In other words, F-gases would represent as much as 40% of total EU emissions. Funnily enough, I did a similar ‘what if’ calculation in 2000, saying they could grow to as much as 25% of emissions, provoking howls of derisive laughter from industry. Looks like I was too conservative!
The report says that to do any better than staying stable, more emphasis should be placed on alternatives to f-gas containing equipment. It mentions a phase-down approach, and expanded use bans, just as CAN did in 2000. These could cut another 70Mt in 2030 at a cost of less than €20/tonne.
All of the information is available at http://ec.europa.eu/clima/policies/f-gas/index_en.htm, and a public consultation is open until 19 December.
[1] Anderson, Jason. ‘Is STEK as good as reported?’ 14 June 2005, Institute for European Environmental Policy.