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Forprojekt til udarbejdelse af handlingsplan for kølebranchen

Summary and conclusions

The phase-out of HFC refrigerants and the transition to natural refrigerants requires extensive reconversion for some of the refrigeration sector. In certain areas, the basis for this reconversion is barely in place: access to components, test of new systems, and common rules with the rest of the world can be mentioned in particular. People and companies have to be provided with requisite knowledge and competence, but not everyone is able to release resources for reconversion. Expedient sector reconversion requires special efforts before the prohibition on use of HFC refrigerants comes into force according to the present draft statutory order. Through the implementation of the pilot project, the needs of the sector have been investigated and the proposals for activities have been drawn up. The proposals constitute a good and well-funded basis for preparation of a detailed action plan for the reconversion process. The task group cannot continue any further on its own. The authorities and the relevant part of the refrigeration sector have to prepare an action plan together, taking this report as their point of departure. There is no doubt that reasonable implementation of the reconversion process depends on considerable economic support to the sector. It should also be mentioned that the sector is not opposed to taking initiatives to improve the environment.

The idea behind preparing an action plan for the refrigeration sector originated in a draft statutory order on industrial greenhouse gases that the Danish Environmental Protection Agency published at the beginning of 2001 suggesting to generally out phase HFCs from 1 January 2006. The purpose of an action plan for the refrigeration sector is to make a serious effort in connection with an industrial reconversion within the refrigeration sector enabling it to project, install and use HFC-free systems for new refrigeration installations following the phase-out requirements set out in a statutory order.

The refrigeration sector reacted forcefully to the draft statutory order, fearing that the refrigeration sector would face even greater reconversion problems in connection with phasing out CFCs. The sector thereby acknowledged the need to establish cross-organisational refrigeration co-operation on co-ordinated and goal-oriented trade efforts in order to enable industries to handle the situation. The reactions were expressed, for example, by means of the co-ordinated initiatives of the refrigeration associations in connection with a public enquiry. In the eyes of the associations, the need for co-operation between the authorities and all "refrigeration actors" was of vital importance regarding whether or not the trade would succeed in achieving their objectives within the suggested time schedule. It should again be mentioned that the sector is not opposed to taking initiatives to improve the environment.

In continuation of this, the idea of a ‘trade action plan’ was discussed with the Danish Environmental Protection Agency, and it was agreed to continue the work on this idea throughout the pilot project. The principal purpose of the pilot project has been to prepare a proposal for an action plan for the refrigeration sector, including financial estimates and proposals for a time schedule as the starting point for expedient reconversion of the refrigeration sector.

The task group has prepared descriptions of the suggested principal activities, for example, close co-operation with the refrigeration sector, detailed proposals for the activities in a final proposal for an action plan, and answers to the questions of who, what, when, etc. The resources and the time schedule available for the task group for the performance of the work have somewhat limited the possibilities. The task group has made great efforts and been very committed during the performance of the work, which in the opinion of the group forms a very good basis for carrying out necessary activities in connection with reconversion from HFCs to natural refrigerants.

The issue of the general election and the change of government in Denmark at the end of 2001 resulted in some uncertainty, and this was reflected in the project, since it was not certain whether or not the new Environment Minister also would be committed to phasing out greenhouse gases. However, time has shown that he does. In this connection, close contact and dialogue between the Minister and the industry has taken place during the spring of 2002.

The project monitoring group has regularly studied the political situation with a view to adjusting the project to the conditions of the framework. The opinion of the monitoring group was that developments will continue towards refrigeration systems applying refrigerants with the lowest possible environmental impact, high energy efficiency and optimal economic life, no matter whether or a Danish law requiring phasing out HFCs is enacted. Developments are also promoted by the environmental authorities in other large countries and major international food processing companies. The EU is also working on an EU Regulation stipulating the minimum levels in this field, and this is expected to be introduced within a few years.

The project monitoring group has also dealt with the fact that the overall background and objective of phasing out greenhouse gases do not alone mean reducing HFC emissions into the atmosphere. A similar environmental effect can also be achieved by reducing CO₂ through reducing the considerable energy consumption by refrigeration plants. Initiatives in respect of include energy efficiency, economic life, energy-saving projections, etc.

Late in the project progress, a new draft statutory order was introduced for public hearing, the phase-out terms for some of the refrigeration systems were changed in relation to the previous publication of the autumn of 2001 due to reactions from the sector. The task group was satisfied that it was heard and that the sector's points of view were considered.

The aim throughout the pilot project has been to involve the entire refrigeration industry, including owners and consumers, to the greatest possible extent. It was intended that not only be the limited group of persons of the task group should account for the views, attitudes and requirements of the entire industry. Most of the information derives from the survey. It is the project group’s opinion that interpretations of conclusions will be changed considerably by a subsequent discussion with the industry. In this way, constructive and useful inputs for the completion of the task group’s proposals for activities will be obtained.

The survey was distributed to 492 entities previously designated as constituting a representative section of all 8 "actor categories" in the refrigeration sector: A-Association, organisation and scheme; B-Educational institution and centre for technology; C-Projecting and advisory entity; D-Enterprise producing refrigeration components or units; E-Enterprise installing and servicing refrigeration plants or units; F-Wholesaler; G-Owner of refrigeration plant and operating staff; and H-Authority. The investigation was made on basis of the draft statutory order from autumn 2001.

The questions were divided into the following 8 categories:

The various detailed results of the survey will not be set out here, since they are discussed in detail in section 5 of the report, but a small number of selected matters are described below:

	The refrigeration sector consists of approx. 500-650 enterprises of various size, excluding the group of owners and consumers.
	In Denmark, approx. 12–15,000 people are directly involved in refrigeration technology

	It is difficult to conclude very much from the answers concerning the applications of natural refrigerants in the future, but some trends are indicated.
	Various refrigerant development and demonstration projects, including HCs and CO2 have already been carried out or are currently in progress.
	The trade is interested in participating in projects on field tests, including knowledge-sharing, and some expect to be able to start up sooner.

	Opinions are divided as to whether it is possible to obtain standard components from Danish or foreign manufacturers.
	In the opinion of the majority, it is to the advantage of Danish exports, competitiveness and employment to reconvert the industry to natural refrigerants, but opinions are divided.
	The courses available at present are not sufficient to meet the requirements.
	The majority of those responding to the survey desire personal competencies connected with requirements stipulated by the authorities and that enterprise competence is similarly connected with authorisation/recognition including current updating through approval by the authorities.

	There is general favour for quality assurance through a voluntary trade scheme.
	Comprehensive knowledge already available is not directly accessible to the public at present.
	Need for customised courses involved staff groups and preferably modular designed courses.
	The industry desires that technical information is made accessible and would prefer it to be electronic.
	Knowledge of existing requirements and sets of rules is insufficient and should be improved.
	Opinions vary in many areas as regards whether requirements and sets of rules are deemed sufficient and operative.
	There is a need to make requirements, sets of rules, and auxiliary tools more user-friendly and that foreign material be translated into Danish.
	There is a desire for more authoritative control by the Danish Working Environment Authority regarding refrigeration plants.

Despite great efforts to obtain as many answers as possible, it was only possible to include 155 answers/questionnaires in the survey: a percentage of 32%. The task group had expected more commitment through a greater percentage of answers.

On the basis of the conclusions of the survey, supplemented with the task group’s own intentions and ideas, 11 proposals for activities were drawn up as a starting point for drafting the contents of an action plan.

All proposals for activities contain "activity description", "actors and organisation", "resources" and "time schedule". Resources have been a difficult point, but we have tried to make our proposal indicative of the level required. Under time schedule, primarily the task group has decided when the activity should be started. The following headings are listed for all of the proposals (cf. section 6 for further details):

Preparation of common training course for what refrigerants suit what types of systems.

Need for development and testing of standard products, in particular for HC and CO₂.

Systems for commercial refrigeration and A/C systems with laboratory and field tests.

Production and storage premises, service vehicles, and "safe" tools.

Qualifying education, certificates according to type of refrigerant and amount, and modernisation of certification scheme.

Development and adjustment of existing and new training courses, increase in capacity, etc.

Preparation of sets of rules and guidelines, ancillary tools such as guidelines and software, and electronic product catalogue.

Efficient organisation and development of available knowledge via the internet, information activities in form of seminars, workshops, newsletters, etc.

Examination of existing sets of rules, expedient, practical and applicable regulatory requirements/optional schemes, safety and control, requirements for Danish-language regulations, requirements for energy efficiency, economic life, requirements for quality level, etc.

Support scheme for owners and training of installation companies, incentive to get started quickly, and collection and dissemination of system experience.

The task group’s proposal and ideas about how to proceed with the implementation of the activities and prepare an action plan.

The task group suggests that the result of the pilot project in the form of this report should be used as the starting point for designing a concrete action plan. The task is that authorities and the sector jointly select and give priority to elements that the parties agree to implement during the period of reconversion in order for the sector to "achieve the desired result" and for which the resources are available. The dialogue should take place between the authorities, a number of representatives from all categories of the relevant refrigeration sector, and some key persons and companies – possibly through a co-ordination and consultation committee. The task group suggests that the preparation of the action plan is carried out with the project group from the pilot project as a secretary function or as a task group in a new (main) project. This will be a natural continuation of the work already started, and it will ensure continuity and reduce the risk of time delay when assigning the project to new people.

The resources in terms of financial funds and time required in order to carry into effect the activities of an action plan probably constitute the greatest problem and the most important barrier.

Financing opportunities for the individual activities should be thoroughly investigated and agreed upon from activity to activity.

Opportunities and places for support should be investigated and in this connection, in the opinion of the task group, it seems obvious to recycle capital from refrigerant taxes to the activities in the action plan. The refrigerant taxes were introduced as a consumption-controlling element to reduce the consumption of HFCs, so what would be more obvious?

In order not to waste valuable time, the task group considers it important to establish a sector committee and that discussion should start immediately in order to prepare a reasonable and realisable action plan for the process of reconversion. It is suggested that most of the proposals for activities are implemented as soon as possible, and therefore there is a need to select the most important activities for rapid implementation.

The total figures for implementation of all proposals for activities amount to DKK 110 million (expenditure) and 35,000 man-hours (calculated at approx. DKK 8.5 million in time consumption). For many of the activities, it has not been possible to prepare reliable estimates.

One of the questions in the survey aimed at the expected consumption of resources for the reconversion process. The sum of the figures from the answers amounted to approx. DKK 94 million (66 answers) and approx. 95,000 man-hours (45 answers). It also clearly appears from the comments on the answers/questionnaires that it is difficult for enterprises to state the considerable resources requires in figures. On this basis, it is reasonable to estimate that the total costs and the total man-hours for the reconversion of the refrigeration sector to natural refrigerants will easily exceed DKK 300 million and 300,000 man-hours. It also appears from the survey that those who have answered the questionnaire have already consumed approx. 69,000 hours.

Not everyone in the sector is able to release resources for the reconversion, and this may lead to unknown consequences. E.g. some of the small refrigeration companies with elderly owners may choose to operate as service companies for some years and not get involved in new risky and costly reconversion, then close the company when retiring.

The task group cannot continue any further on its own. The authorities and the relevant part of the refrigeration sector should prepare a detailed action plan based on the preliminary work carried out. The task group hopes that the report will benefit the reconversion process of the sector when HFC refrigerants are prohibited.

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