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Davide Sabbadin, Senior policy officer for climate EEB e Marco Mancini, Fgas Legambiente Manager
Davide Sabbadin, Senior policy officer for climate EEB and Marco Mancini, Fgas Legambiente Manager

Target of this article is creating a debate, comparing two different ways of seeing the refrigeration future. Let us start with Davide Sabbadin, Senior policy officer for climate EEB, and Marco Mancini, Fgas Legambiente manager. In the successive page, Carmine Marotta, Managing Director of General Gas, answers

The market of refrigerating gases is under pressure: what is the current situation?
Prices have certainly dropped compared to the peak noticed in 2018 but they remain anyway much higher than in previous years and they are anyway expected to increase owing to the effect of the phase down and of the missing investment in some sectors. An important role in the price control has been certainly played by the gas illegally imported, which has reduced the demand. We will have to understand if, with the worsening of the phase down, the phenomenon will continue or will be hindered more efficaciously by new foreseen measures. However, it is hard to imagine that prices may decrease, especially for refrigerants with medium or high GWP. In the meantime, anyway, natural solutions are currently the market standard, always available at a more affordable cost, net of investments on the transition between the two technologies that see natural gases as applicable for the vast majority of technical solutions, until the complete replacement of the machine fleet installed. Italy, as well-known, is sector leader of technologies and innovations in the field of refrigeration, conditioning and heating, with a strong attention to sustainability according to a full “green” modality.

How well has the combined Regulation 517 + DPR 146 worked and is it working?
I daresay that not everything has gone well. I start from training: professionals able to install heat pumps are missing and most of the existing ones are not trained about natural refrigerants with low GWP. Besides, under certain respects, companies are more advanced than the regulation and many ask that the new FGas regulation is more ambitious, to boost this sector indeed towards the needed transition for the saving of energy and climate-altering emissions. Solutions exist, we need a clear guideline that determines their application. An aspect that has made water on all sides is the illegal market control, but without resources and suitable training for the authorities entrusted with the surveillance (in Italy mainly customs), they risk of remaining good proposals written on water. The fact remains that if natural gases were the standard, the reasons for a black market would largely disappear. A third failure of the legislative combination was mobilizing all RVAC sectors: currently, we know that some sectors are technologically prompter and others less. It seems, we understand, that less prompt ones partly relied on the fact the others would do their homework and that a large volume of shares would anyway remain available for them in the second half of the decade: they did wrong the accounts and now they are running. Never mind, necessity sharpens ingenuity and the brain, even technical, is a resource that never misses in our Country: we are confident. Moreover, a sector like refrigeration, readier than others to the transition to naturals, might free market shares in the use of HFC, which should be restricted and used in very short times by the most backward sectors (conditioning and heating) to lighten the transition, making that effort of research, development and innovation to increase the efficiency and to optimize the most sustainable technologies without using F-gases. Finally, it is unavoidable to notice that F-Gas databank highlights that the market for regenerated in our Country is asphyxiated: we are well aware that large quantities of virgin refrigerant are still sold in bulk, although nowadays banned, for the maintenance of refrigerating benches and probably the regenerated suffers from the competition with the illegal gas, too. The missed take-off of the recovery and regeneration chain was due not only to a guilty absence of the Government but also to a lacking protagonism of the private sector that did not want, or was not able, to do system. We have been for years at the eve of a great novelty in this field, which never comes, like for instance a chain consortium, as many exist in Italy for packages and some categories of special wastes (mineral waste oils for instance), which would allow managing the sector clearly, safely and with well-defined rules, to full benefit of the various chain and environment players, in the full circular economy principle.

The draft of the Regulation 517 review has been just issued: what positive comments?
It seems to us it introduces various positive notes. In the fight to illegality, in particular, with a worsening of administrative penalties foreseen and their homogenization, and a better tracing and register system. The share allocation at a symbolic price as well is a good sign that should prevent purchasing phenomena by straw heads, seen in these years, and create more dynamism in the market. Our judgement is positive also about the phase down alignment with the global context and especially with European climatic targets.

The draft of the Regulation 517 review has just been issued: what negative comments?
In general, we miss a sense of urgence in training, an emergency plan to educate both professionals in activity and to implement higher and university training in the short term, to have technicians ready within 5 years. Deluding also the Enclosure 4 on bans, even if there are important signals, and on the side of resources from shares. We opt for inverting the order of factors and for radically exemplifying the rule: the ban of all HFC, with the exception of the sectors where naturals are not a marketable solution, yet, for which the regulation already provides for possible exemptions. Deluding the threshold values of GWP, partly inherited from the past, which do not take into account the new GWP values recalculated by IPCC. Beyond technicisms, we wonder: what sense does it make to keep, for instance, GWP 2500 in refrigeration, today? The new Regulation should be more farsighted, in view of defining also this sector’s policy and the climatic impacts in next years. Paradoxically, the old Regulation was more ambitious and visionary than this draft. Binding maintenances with the use of gases with lower and lower GWP with a well-defined graduality would seem more reasonable to us than leaving things unchanged. It would be worth adopting a more prudent and precautionary approach about the use of new chemical mixtures and fluids that apparently solve the climatic impact problem (ex. HFO): we have shifted from harmful ozone gases to climate-altering gases of which we do not know the environmental impacts in-depth. Obviously, where solutions with natural fluids are not available, we need to work more on transition and research, but where the latter are sound and functional, we just need to incentive, to promote and to spread them. For these reasons, we believe it is a wasted opportunity not having introduced the DNSH (do not significant harm) criterion in the regulation, regarding the potential chemical damage that some refrigerants might bring to the environment, acting as Pfas. We risk of making room for a new generation of refrigerants that run the risk of disappearing from the market in some years owing to their potential environmental damage, and what will we tell to all those who today buy technologies based on those refrigerants?

How will the rising cost of electric energy influence operational choices?
Certainly, the already existing focus on the energy efficiency will increase. However, I remind that the gas cost has equally risen and the dynamics of the independence from fossils has become a driver as important as climate, or even more, in the short and medium term, for decision makers’ choices. Therefore, the way is traced in favour of heat pumps, especially if at high temperature, so enabling the one to one replacement of gas boilers in the domestic market, to speed up installation times. Heat pumps with natural gas that reach high delivery temperatures might be favoured. Much will depend on how and if the Energy Taxation Directive will be changed.

The ecologic component is clear, as well as the energy one: to what extent are we facing the safety variable?
Considerably in the ambit of technical regulations but scarcely in terms of training, it seems to us. However, we do not believe that shifting from a system, where we have methane gas that circulates in houses and burns in a box where there is a free flame, to a system where we have propane or isobutane confined in a flame-free circuit is on the whole a step backward in the Country’s safety: on the contrary. Besides, in the future installers will be partly the same and they will inherit the culture of the methane market’s safety. On the other hand, some technologies connected with the safety increase are already available for installation and as contour of (civil and industrial) plants and they will be more and more developed if the market decides following this direction. Beware non-technological and regulatory hindrances, where Italy can unfortunately boast some records in many sectors. A work in synergy with competent bodies and firemen might be a driver to boost these processes of regulation insight and review, also looking at what the other European Countries are doing. In the ambit of Standards, we go towards an unavoidable lightening of regulations, due to the technical evolution of products that, through double circuits and other innovations, have drastically increased products’ intrinsic safety. On the other hand, if safety is the topical issue to be debated, we talk about that also for A2L, for which the problem is general. For all products, both natural and A2L, the growth in volumes will probably allow knocking down the extra-costs connected with the extra-protections linked with safety.

A F-Gas Regulation exists: when a N-Gas Regulation?
I do not think it is useful, in the specific case. We would have been favourable to an all-encompassing European register, which included also natural. Then, training is the other theme: both subjects are included and manageable within the f-gas reg.

How much competence is needed to face this transition? Does this competence exist? And if it does not exist, how can we implement it?
This is the key issue. The acceleration given by the Russian invasion of Ukraine has exacerbated the shortage pf professionals trained in alternative technologies to gas. It is not simple to ask for investments to those who do not perceive their usefulness, because they already work full time to deal with an exploding market. In technical higher schools, training is very scarce compared to the market demand and natural gases, which are the absent market basis for certain sectors. On the other hand, what professional, today employed full-time, would give up his job to work as a professor, considering the salaries paid to teachers today? At least a pair would be necessary for each province: can 214 volunteers be found? There are some doubts about that. Here come the knots that concern both the training of active professionals and new recruits. In our opinion, the regulation should contain a sort of emergency plan, which engages member States to a roadmap with precise goals: 50% of plumbers and electricians should be trained by 2025 to install PdC, with all gases available on the market, for instance. And from there upwards, up to 100% in 2030. The training for refrigerator technicians and natural gases should prosecute hand in hand at fast rates, too. Resources? There is always the share issue …

Is the GWP choice as main parameter for the phase-down sufficient to meet sustainability targets?
Currently, the GWP is the most updated tool, as perceived in IPCC reports. Efficiency is certainly central, but with the massive injection of electric renewables foreseen from now to 2030 the climatic impact of the energy used will be likely to tend to zero within 2035, that is to say within the service life of a product sold today.

How can we implement the targets of emission reduction according to TEWI?
Certainly, by ascertaining that the energy efficiency is always an element as important as GWP. There are some cases in which gases with low GWP are not so efficient as those with high GWP, and in that case the choice must obviously opt for efficiency. However, in most cases this does not happen, on the contrary, outputs are inversely proportional to GWP. If anything, it is the costs that rise. The elusive “CO2 equator” is now a thing of the past, technologies are highly optimized in terms of plants’ energy efficiency. However, let us not forget that the GWP should be calculated on 20 years, not on 100 years as the European Commission starts introducing in the new Regulation. And then TEWI changes completely, because GWP values of gases are much higher.

How is the refrigerant market you would like?
We would like a market where natural and non-patented refrigerants and those with GWP<3 that are not chemically harmful are the habit in all sectors and HFC are the exception, regulated and authorized by EU for specific applications. Therefore, we opt for a regulation that bans f-gases for all those applications where it is possible to do that, solving the climatic and environmental problem radically and also aiding the balance of payments, considering that we import most HFC in Europe. And in times of rethinking of strategic dependencies …