Canadian Council of
Ministers of Environment
Le Conseil canadien des
ministres de l´environnement
Canada’s Strategy to Accelerate the Phase-Out of CFC and Halon Uses and to Dispose of the Surplus Stocks
Federal-Provincial Working Group on Ozone-Depleting Substances and Their Halocarbon AlternativesPN 1316
The Canadian Council of Ministers of the Environment (CCME) is the major intergovernmental forum in Canada for discussion and joint action on environmental issues of national, international and global concern. The 14 member governments work as partners in developing nationally consistent environmental standards, practices and legislation.
The CCME Secretariat may be contacted at: Canadian Council of Ministers of the Environment 123 Main Street, Suite 360 Winnipeg, Manitoba, R3C 1A3 Tel: (204) 948-2090 Fax: (204) 948-2125 Comments regarding the content of this National Action Plan should be addressed to: Chair, Federal-Provincial Working Group on Ozone Depleting Substances and Halocarbon Alternatives c/o Commercial Chemicals Evaluation Branch Environmental Protection Service Environment Canada Ottawa, Ontario K1A 0H3
Ce document est également disponible en français.
The Federal-Provincial Working Group on Ozone-Depleting Substances and Halocarbon Alternatives has developed a Strategy to achieve an orderly and affordable phase-out of CFCs and Halons in Canada. The Strategy takes into account the input received during extensive consultations with stakeholders. Initiatives have been identified to provide the infrastructure needed to encourage an orderly transition from CFCs and Halons to alternative substances and technology, and to ensure safe disposal of surplus stocks. Phase-out objectives and approaches specific to individual industry sectors are presented. The costs and benefits associated with implementation of the Strategy are also presented.
Table of Contents
LIST OF FIGURES v
LIST OF TABLES v
EXECUTIVE SUMMARY vii
Section 1.................................................................. 1
1.1 Background 2
1.1.1 Impact of Ozone Depletion 2
1.1.2 Canadian Ozone Layer Protection Program 2
1.2 Inventory of CFCs and Halons 4
Section 2................................................................... 6
2.1 General Issues 7
2.1.1 Extended Producer Responsibility 7
2.1.2 Market Force Instruments 8
2.1.3 Disposal of Surplus Stocks 9
2.1.4 Control Measures 10
2.2 Sectors 10
2.2.1 Mobile Air Conditioning 10
2.2.2 Mobile Refrigeration 11
2.2.3 Household Appliances 12
2.2.5 Chillers 12
2.2.6 Halons 13
Section 3 .................................................................. 14
IMPLEMENTATION ACTIVITIES 14
Section 4 ...................................................................15
COSTS AND BENEFITS............................................................. 15
List of Figures
1. Canadian 1998 CFC Inventory 5
2. Canadian 1998 Halon Inventory 5
List of Tables
1. Net Present Value for Options Investigated 16
Canada is committed to protecting the earth’s ozone layer. In the last decade, the federal and provincial governments have taken action to ensure that Canada’s national objectives and all obligations under the Montreal Protocol on Substances that Deplete the Ozone Layer are met or exceeded.
However, a comprehensive review in 1994-95 of Canada’s Ozone Layer Protection Program determined that unless new initiatives are put in place to take CFCs and Halons out of service and dispose of them, most of the Canadian inventory of these substances will ultimately be released to the
The Federal-Provincial Working Group on Ozone-Depleting Substances and Halocarbon Alternatives (FPWG) has developed this Phase-out Strategy in response to that observation. The objective of the Strategy is to minimize and avoid the ultimate release of designated substances to the environment.
Extensive consultations with stakeholders have been a key part of the Strategy development. The FPWG expects that implementation of the Strategy will achieve an orderly and affordable phase-out of CFCs and Halons in Canada.
The Strategy consists of specific approaches to phase out uses of CFCs and Halons and dispose of surplus substances. There are two separate components to the Strategy. The first component consists of initiatives that are general in nature. They will provide the “infrastructure” needed to encourage an orderly transition from CFCs and Halons to alternative substances and technology, and to assure safe disposal of the surplus stocks of CFCs and Halons. The second component consists of phase-out objectives and approaches that are specific to individual industry sectors. A sector-bysector approach is needed because each sector is unique (not “one size fits all”) and the Strategy will reflect what can be achieved in each sector.
The “general” component of the Strategy addresses four separate areas:
extended producer responsibility (EPR); market force instruments; disposal of surplus stocks; and control measures. The second component of the Strategy addresses six specific use sectors: mobile air conditioning; mobile refrigeration; household appliances; commercial refrigeration and air conditioning; chillers; and Halons.
The cost-benefit analysis conducted as part of this work has concluded that the overall health and environmental benefits to Canadians upon implementing the Strategy will exceed the implementation costs for each ofviii the sectors. The total net present value of the Strategy is in the order of a positive $2 billion to Canadian society.
This report describes the Strategy that the Federal Provincial Working Group on Ozone Depleting Substances and Halocarbon Alternatives (FPWG) has developed to achieve an orderly and affordable phase-out of remaining CFC and Halon uses in Canada. The objective of the Strategy is to minimize and avoid the ultimate release of CFCs and Halons to the environment. The Strategy will accomplish this by accelerating the use of alternatives and rendering surplus stocks of CFCs and Halons harmless.
This Strategy is part of the ongoing process of fulfilling Canada’s commitment to protect the earth’s ozone layer. Development of the Strategy came about as a result of a comprehensive review, started in 1994, of the Canadian ozone layer protection program. That review helped to point out that unless new initiatives are put in place to take CFCs and Halons out of service and dispose of them, most of the Canadian inventory of these substances will ultimately be released to the environment. The Auditor General of Canada reinforced this point in the 1997 audit of the national ozone layer protection program and called for action to address it.
Extensive consultations with stakeholders have been a key part of the development of this Strategy. Consultation sessions focusing on a proposed Strategy prepared by the FPWG were held during February in Vancouver, Winnipeg, Halifax, Montreal, and Toronto. In all, approximately 200 people participated in these sessions. Reports summarizing the consultations and the responses of the FPWG to the recommendations from the consultations are available under separate cover.1,2
Canada is not alone in developing approaches to accelerate the phase-out of uses of ozone-depleting substances (ODS). Other countries are taking similar steps. For example, the European Union is planning to ban the refill in commercial refrigeration and air conditioning equipment with CFCs by the end of 2000. Sweden, Denmark, Norway, and Finland prohibited the use of CFCs in new equipment in the early ‘90s. Sweden prohibited recharging of existing equipment with CFCs in 1998, and plans to prohibit the use of CFC refrigerants in existing commercially used equipment in 2000.
1Synthesis Report – Public Consultations on Canada’s Proposed Strategy to Accelerate the Phase-out of Ozone-depleting Substances, CANTOX ENVIRONMENTAL INC., March 31, 2000
2Canada’s Proposed Strategy to Accelerate the Phase-out of CFC and Halon Uses and to Dispose of the Surplus Stocks: Response to Recommendations from Stakeholder Consultations held during February, 2000, Federal-Provincial Working Group on Ozone-Depleting Substances and Halocarbon Alternatives, July, 2000
Action to accelerate the phase-out of uses of CFCs and Halons is also being taken under the Montreal Protocol. The Canadian Strategy will meet Canada’s new obligations in these areas:
•At the 10th Meeting of the Parties to the Montreal Protocol, the Parties requested signatories to develop national and regional strategies for the management of Halons, including emissions reduction and ultimate elimination of their use, to be submitted by July 2000;
•At the 11th Meeting of the Parties to the Montreal Protocol, a decision was adopted on the management of CFCs. All non-Article 5 countries (i.e. all developed countries) are to prepare strategies for the management of CFCs, including options for recovery, recycling, disposal, and eventual elimination of their use. These management strategies are to be prepared by July 2001.
1.1.1Impact of Ozone Depletion
The science of ozone depletion is well established and accepted as a result of many years of collaborative research by scientists around the world.
Anthropogenic releases of certain halogenated compounds, in particular CFCs and Halons, take part in reactions in the stratosphere that destroy the stratospheric ozone. Since the stratospheric ozone layer functions to reduce the amount of UV-B radiation that reaches the earth, the reduction in ozone layer results in increased levels of UV-B radiation reaching the earth’s surface.
Human exposure to the increased UV-B radiation has led to an increase in sunburn, skin cancer and weakening of the immune system. Ecosystem health has also been adversely affected as well. Plankton populations in the oceans (one of the main building blocks of the food chain) have been reduced, and damage to vegetation and crops also occurs.
A study prepared for Environment Canada for the 1997 Meeting of the Parties to the Montreal Protocol estimated the global costs of ozone depletion to be in the range of $235 billion per year.3
1.1.2Canadian Ozone Layer Protection Program
In Canada, the federal and provincial governments share regulatory responsibility for ozone layer protection. The federal government is responsible for implementing controls needed to meet Canada’s obligations
3The Right Choice at the Right Time, Highlights of the Global Benefits and Costs of the Montreal Protocol on Substances that Deplete the Ozone Layer, Environment Canada, 1997
under the Montreal Protocol, and for regulating federal facilities which are not covered by provincial regulations. The provincial governments control recovery, recycling and the releases of ozone-depleting substances. Currently, the federal government has prohibited new uses of CFCs and Halons and has restrictions on the import and export of bulk shipments, and on certain uses. There are also federal ODS regulations (covering releases, recovery, etc.) that apply to federal facilities and undertakings. The provinces restrict emissions of CFCs and Halons, and mandate recovery. Some provinces have banned the refilling of automotive air conditioning systems with CFCs. In all jurisdictions, it is prohibited to vent CFCs or Halons (except to extinguish a fire).
The Federal-Provincial Working Group was established in 1989 by the Canadian Council of Ministers of the Environment. The goal of the Working Group was to establish a coordinated national Strategy to eliminate CFCs and Halons in Canada. Over the years, the Group’s mandate has remained essentially unchanged, although its scope has broadened in concert with changes to the Montreal Protocol and other environmental issues. The Working Group reports to the National Air Issues Coordinating Committee.
The 1995 review of the Canadian ozone layer protection program and the resulting report entitledStrengthening Canada’s Ozone Layer Protection Program established the current direction for the Canadian program. The review’s main recommendations to minimize releases of CFCs and Halons were:
•Zero-release target dates should be set and met by a combination of total containment and elimination of uses;
•The destruction or transformation (to other chemicals) of unnecessary ODS should be required as soon as feasible;
•The development of new disposal technology should be supported;
•Governments should work in partnership with industry and other stakeholders to facilitate disposal; and
•Market force instruments to promote removal from service and proper disposal should be investigated.
In addition, the Office of the Auditor General of Canada issued a report in 1997 on Canada’s Ozone Layer Protection Program, with one of the key recommendations being that the federal government should clearly articulate its position on the destruction of ODS and related equipment.
The Working Group incorporated the results of the “strengthening” exercise into a revised National Action Plan (NAP) in 1998.4 The revised NAP is the framework for the continued coordination of federal and provincial and territorial efforts to control and manage ODS in Canada. The following specific objective in the NAP deals with phase-out of uses and disposal of CFCs and Halons:
“To improve the environmental management of all ODS and halocarbon alternatives and to reduce their emission from all industry sectors by:
•Identifying, where feasible, appropriate dates for the phase-out of specific uses of CFCs and Halons, or as an alternative, mandate total containment; and
•Developing a Strategy for the disposal of surplus CFCs and Halons.”
As a first step in achieving this NAP objective, Environment Canada commissioned a review of the options available to manage surplus CFCs and Halons.5 This review formed the basis for the proposed Strategy document6 prepared by the Working Group in January 2000 and used as the focus for the public consultations carried out in February.
1.2Inventory of CFCs and Halons
The estimated amounts of available CFCs and Halons, based on 1998 information7, are shown in Figures 1 and 2, respectively.
4National Action Plan for the Environmental Control of Ozone-Depleting Substances and their Halocarbon Alternatives, Canadian Council of Ministers of the Environment, Report No. CCME PN 1291, January 1998
5Options for the Management of Surplus Ozone-Depleting Substances in Canada, Shapiro & Associates, June 1998
6Canada’s Proposed Strategy to Accelerate the Phasing-Out of CFC and Halon Uses and to Dispose of the Surplus Stocks, Federal-Provincial Working Group on Controls Harmonization-ODS, January 14, 2000
* Quantities are not ODP weighted
**This total does not include imports of Halons in finished products.
Figure 2: Canadian 1998 Halon
Total: 3,130 tonnes*
* Quantities are not ODP weighted
** This total does not include imports of Halons in finished products
The Strategy consists of specific approaches for the phase out of uses of CFCs and Halons and disposal of surplus substances. There are two separate components to the Strategy. The first component consists of initiatives that are general in nature. They will provide the “infrastructure” needed to encourage an orderly transition from CFCs and Halons to alternative substances and technology, and to assure safe disposal of the surplus stocks of CFCs and Halons. The second component consists of phase-out objectives and approaches that are specific to individual industry sectors. A sector-by-sector approach is needed because each sector is unique (not “one size fits all”) and the Strategy will reflect what can be achieved in each sector.
The “general” component of the Strategy addresses four separate areas:
•extended producer responsibility (EPR);
•market force instruments;
•disposal of surplus stocks; and
The EPR initiatives will underwrite disposal costs, thereby ensuring that disposal costs do not contribute to illegal releases or unsafe disposal practices. Economic incentives (e.g. accelerated capital cost allowances) and other market force instruments are being examined, as a way of encouraging transition to alternatives in an orderly manner. Work under the third area will be aimed at actively supporting the development of disposal programs. The last general area of initiatives (Control Measures) will ensure that there is a clear, comprehensive and consistent regulatory framework in place, to ensure there is a “level playing field” for industry to work under.
The second component of the Strategy sets a phase-out approach for six specific use sectors:
•mobile air conditioning;
•commercial refrigeration and air conditioning;
2.1.1 Extended Producer Responsibility
(i) Industry will play a key role in the development of management strategies to phase-out, collect and dispose of surplus ODS in Canada, including:
•Development of management plans for retrofitting, converting or replacement of existing systems using CFCs and Halons;
•Research and Development of alternative products and technologies; and
•Partnering with government and other stakeholders to develop management plans for collection and disposal of surplus stocks.
•The Heating, Refrigeration and Air Conditioning Institute (HRAI) has proposed a plan for the collection and disposal of surplus refrigerants in the stationary refrigeration and air conditioning and chillers sectors, funded by a voluntary industry levy on replacement refrigerants. Other groups are also considering making similar proposals.
•HRAI will take the lead in developing the program they have proposed. The FPWG and interested stakeholders will participate as appropriate.
•Other sectors (e.g. mobile air-conditioning and refrigeration, Halons) will be encouraged to participate in such initiative or develop their own EPR program.
(ii) Government, industry and training institutes will cooperate on: education and communication activities on available alternative technologies and products; communicating the objectives and timelines of the Strategy; and training of technical personnel.
•The environmental awareness and training program for refrigeration and air conditioning service technicians will continue. This program is well established and involves participation of HRAI, the Refrigeration Service Engineers Society (RSES), community colleges, and the
federal and provincial governments. Over 95,000 technicians have taken the training program since its inception in 1992.
•Environment Canada is preparing an ODS Disposal Guide to compliment the Disposal Guidance Document8 in order to assist owners of ODS in their disposal decisions.
•The Multistakeholder Working Group for ODS and Alternatives will be asked to examine the need to undertake development of education/communication materials dealing with available alternative technologies and products.
•Environment Canada, the Provinces and Territories will develop awareness programs to inform stakeholders of the Strategy’s objectives and timelines.
2.1.2 Market Force Instruments
(i) Environment Canada to examine what economic incentives would be appropriate to achieve the objectives of the Strategy, and how to implement these incentives.
•Environment Canada is studying potential economic incentives, as described in the recommendation above.
•The FPWG will undertake consultations with other government departments, both federal and provincial, and with stakeholders on the findings and recommendations of the study, with a view to having appropriate market force instruments implemented in Canada.
8Guidance Document on Disposal Technologies for Ozone-Depleting Substances (ODS) in Canada, CANTOX ENVIRONMENTAL INC., March 2000
(ii) Industry-funded programs to be considered for inclusion in management plans for collection and disposal of surplus stocks.
•The HRAI initiative, described above, should achieve essentially the same results.
•Further development and implementation of the HRAI-led initiative.
•Expansion to other sectors, e.g. Halons.
(iii) Manufacturers and distributors of alternatives to consider providing incentives such as rebates on new equipment being sold or installed.
•The FPWG will encourage manufacturers and distributors of alternatives to provide incentives or take other actions to accelerate the transition to alternatives.
•The FPWG will periodically monitor the rate of equipment retrofits and replacements, and reasons for them.
2.1.3 Disposal of Surplus Stocks
•Governments will partner with private-sector organizations to support initiatives leading to the development of environmental and cost effective disposal program(s).
•The HRAI is leading an initiative to dispose of surplus CFCs from the stationary refrigeration and air conditioning and chillers sectors, as described earlier.
•An ODS Disposal Guide is being prepared by Environment Canada.
•Further development and implementation of the HRAI and other industry level initiatives.
•Expansion of the program to other sectors.
2.1.4 Control Measures
•Governments to work together to provide clear and comprehensive control measures that are consistent from jurisdiction to jurisdiction in implementing the Strategy.
•The export of surplus CFCs and Halons will be prohibited except for destruction and critical uses using the evaluation criteria of the Montreal Protocol.
•FPWG continually examines and recommends adjustments to control measures in Canada to improve consistency.
•The Sector approaches in Section 2.2, below, identify the necessary control measures.
•Two jurisdictions, B.C. and Yukon, currently have “seller take back” provisions in their regulations.
•Governments to develop the necessary control measures to implement the Phase-out Strategy.
2.2.1 Mobile Air Conditioning
•Prohibit refill of mobile air conditioning equipment with CFCs as soon as possible.
•Alberta, British Columbia, New Brunswick, the Yukon territory, and the federal government have developed control measures that prohibit refilling of mobile air conditioning equipment with CFCs.
•The Canadian Environment Protection Act (CEPA) Code of Practice9 contains guidelines for recovering CFCs from mobile air conditioning equipment.
•Remaining provinces and territories to develop control measures to prohibit the refill as per the CCME National Action Plan on ODS and their Halocarbon Alternatives.
2.2.2 Mobile Refrigeration
•Prohibit refilling in the Mobile Refrigeration Sector with CFCs effective 2003.
•CEPA Code of Practice contains guidelines for recovering CFCs from this sector.
•Companies in this sector are actively converting from CFCs to alternatives.
•Governments to develop the appropriate control measures.
•Management programs for disposal of surplus CFCs to be developed and integrated with the stationary equipment program.
9Environmental Code of Practice for Elimination of Fluorocarbon Emissions from Refrigeration and Air Conditioning Systems, Environmental Protection Series, Environment Canada, March 1996
2.2.3 Household Appliances
•Add a ban on converting equipment to use CFCs (R-12) to existing regulatory approach.
•Enhance implementation of recovery programs.
•An ODS disposal guide is being developed by Environment Canada.
•The FPWG to monitor / report on success of recovery programs.
•The FPWG to consider how to improve existing recovery programs.
A staged refill ban effective by year:
•Small commercial units (< 5 HP): 2004
•Medium units (5 – 30 HP): 2005
•Large industrial units (> 30 HP): 2006
•The HRAI led initiative for disposal of surplus CFCs applies to this sector.
•Development and implementation of HRAI initiative.
•Development of appropriate control measures.
•Beginning in 2005, require conversion or replacement of CFCcontaining chillers at next overhaul.
•Beginning in 2003, limit the releases of CFCs from low pressure chiller purges to less than 0.1 kg/kg or air.
•The HRAI led initiative for disposal of surplus CFCs applies to this sector.
•Purge limits are already in place in eight jurisdictions, with Alberta, British Columbia, Yukon, and the federal government already mandating 0.1 kg/kg air.
•Development and implementation of the HRAI initiative.
•Development of appropriate control measures.
•Prohibit refilling of portable equipment by 2003, except for critical uses.
•For fixed systems, provide for one refill between 2005 and 2010. The refill would be allowed on the condition that the system is replaced by an alternative within a year of the refill. This would also be subject to critical use exemptions. Starting in 2010, refills will be prohibited.
•British Columbia, Alberta, Manitoba, Ontario, New Brunswick, the Yukon Territory, and the federal government have, or are developing, control measures to prohibit the refilling of portable extinguishers.
•New Brunswick prohibits refilling of fixed systems, similar to the approach above.
•Remaining jurisdictions to develop and implement the necessary control measures.
In order to clarify the actions needed by each level of government, the FPWG has updated the current NAP and has identified the tasks required to implement the Strategy.
To ensure consistent implementation of the Strategy, the FPWG will prepare an Implementation Report on the status of the tasks associated with the Strategy. The report will be submitted to CCME on a regular basis.
A cost-benefit analysis was conducted by Environment Canada to support the development of this Strategy.10 The analysis investigates the economic implications of accelerating the phase-out of CFCs and Halons and the disposal of surplus stocks. Equipment targeted by the disposal Strategy includes:
•Large Building Air Conditioning (Chillers);
•Halon 1211 Portable Fire Extinguishers; and
•Halon 1301 Total Flooding Systems.
A detailed discussion of the assumptions, options investigated and results are included in the Environment Canada Cost-Benefit report. Detailed results for the options investigated are shown in Table 1. The date presented in the option column of Table 1 is the year that the phase-out starts. The low and high values in Table 1 reflect uncertainty in the cost and benefit estimates and bounds where the mean value, or expected Net Present Values (NPV), falls within. The expected value was estimated using Monte Carlo sampling (statistical risk and uncertainty testing) which reflects uncertainty in key input variables in the NPV estimate. The expected NPV, therefore, provides an indication of the most likely outcome in terms of costs versus benefits of each of the options.
The NPV for the options analyzed for each of the sectors are positive. Overall, the expected net present value for the approaches selected for this Strategy is approximately $2 billion.
10Cost-Benefit Analysis for a Ban on CFCs and Halons, Regulatory and Economic Analysis Branch, Environment Canada, July 2000
Table 1*: Net Present Value for Options Investigated @ 5% discount rate ($millions - 2000)
Option Low NPV Expected NPV High NPV
SOURCE: Web Site CANADIAN COUNCIL OF MINISTERS OF ENVIRONMENT, Publications.