EFCTC Position

Coverage

• HFCs have been developed as safe substitutes for Ozone Depleting Substances (ODSs) covered by the Montreal Protocol.
  
  
  • ODS, which are not taken into consideration by the Kyoto Protocol, are equally or even more powerful Greenhouse Gases than HFCs
    
  • Taken together global CO₂ equivalent emissions of HFCs and ODSs have been declining over time.
    HFCs can be used safely in a wide range of energy efficient applications such as insulation, refrigeration and air conditioning. Their indirect contribution to CO₂-emission reduction (by lowering energy consumption) is important.
    
  • Contrary to other Greenhouse Gases, HFCs are produced to meet a demand. They are not byproducts. They can be recovered and re-used. Consequently, emissions of HFCs can be prevented and minimized.
    
  • The most widely used HFCs have a much shorter atmospheric lifetime than CO₂ and are removed from the atmosphere relatively quickly.
    
    
• EFCTC fully supports an ambitious global agreement on the reduction of Greenhouse Gas emissions.
  We therefore accept that a “Business as Usual” scenario for HFCs is not an option.
  
  
  • What is needed is legal certainty as the equipment relying on HFCs has a use cycle of 10 years or more.
  • Preference should be given to a market based approach, where an ambitious consumption reduction target is set and the implementation is left to the maximum extent possible to the operators in the market.
  • In view of the extremely broad use of HFCs, these substances should remain separate from an emissions trading scheme.

We support the proposal to delegate the implementation of a market based approach to the Montreal Protocol mechanism cf paragraph 57 (page 110) of  http://unfccc.int/resource/docs/2009/awglca7/eng/14.pdf , while keeping HFCs emissions under the UNFCCC and related agreements.

• In this context it must be noted that concrete proposals for such a “phase down” schedule have been made to the Montreal Protocol, notably draft decision XXI[J] by Micronesia and Mauritius.
  http://ozone.unep.org/Meeting_Documents/mop/21mop/MOP-21-3E.pdf and a proposal by Canada, Mexico and USA http://ozone.unep.org/Meeting_Documents/mop/21mop/MOP-21-3-Add-1E.pdf
  
  • These proposals were discussed at the 21st Meeting of the Montreal Protocol held in Port Ghalib, Egypt, November, 4th-8th, 2009 with a resulting Declaration signed by a number of governments. EFCTC supports the concept of the proposals from USA/Canada/Mexico however there is considerable detail that requires further analysis to further develop the proposal so that it could form the basis of an international agreement. The production/consumption allows an "upper limit" which sets the level of ambition.
    
  • In order to achieve an international agreement around this proposal, EFCTC considers that it is important to focus on a consumption cap, which determines use leading to reduced emissions. A production cap determines where the substance is produced. On this basis a production cap is not necessary, but if a production cap is to be considered then it is better to include HCFCs alongside HFCs in any baseline.

LINKS

• EFCTC views on international principles for a regime to control HFCs emissions
• Projection of global demand for HFCs
• EFCTC position on North American proposal to phase down fluorocarbons under the Montreal Protocol
• Overview of Production, Sales, and Atmospheric Release of Fluorocarbons through 2006