Detailed submission - Shape the emissions reduction plan

In terms of F gas phase down, attached is a table that compares various high GWP refrigerants , some of their alternatives and how they compare in terms of operation

The single biggest impact will be in bans on pre charged finished equipment and the ability to service Legacy "Low Temperature" commercial and Transport Systems <50Kw. These need a <2000GWP as there are no A1 class refrigerants that could do the job.

Presently as an importer and wholesaler of Refrigerant my concerns would be the impact to current inventories of materials if demand fell away and current inventories of HFC became unwanted and unsalable. Would the government provide compensation of the ETS paid and cost of materials ? One way to provide some form of buffer is to extend the implementation of servicing bans out to 2025.

Our business is no longer importing high GWP refrigerants like R507 or R404A but I still have inventory to service legacy plant....I estimate I will run out in mid 2022 however other Gasses like R410A and R452 are still being imported as we have no viable alternative

Generally I am supportive of this for Domestic Fridges & Heatpumps as well as Automotive AC. The issue is with Commercial equipment and we are already seeing this to an extent where A/C Chiller units manufactured in Europe previously operated on R410A are being charged with R454b and we cannot get supply of the refrigerant in New Zealand as European OEM's are sucking up all the capacity. We have experienced firsthand the inability to source any commercial quantity and as the global market for Refrigerant packaged in disposable containers is shrinking we could run into difficulty servicing these gasses as no Supplier in NZ has invested in Bulk Refrigerant storage and repackaging

Absolutely support and practice this. We provide Engineering advice and guidance to contractors in retrofitting R404A to R448A in medium temp applications and R452A in Low temp. We are about to start pushing the retrofit of R134a to R513. Having read pages 113 & 114 I agree and endorse the majority of suggestions with the exception of a few applications where there are technical challenges that need to be addressed, these can be catered for with a targeted approach.

Page 113:
Residential airconditioning, heatpumps and airconditioners - You propose the use of a <750GWP in servicing at 2023 using R466A. This refrigerant developed by Honeywell has not been taken up by any Compressor manufacturer or OEM as it was found to be chemically incompatible with system components and was causing system failure. My Advice is to move the service ban to 2026 at which time if a domestic AC fails the better move would be a new, low GWP, energy efficient Heat Pump

Page 114
Commercial air conditioning, eg, office buildings and retail including VRF systems - Proposed Servicing Phase out Limit 2023 <750GWP
This fails to recognize that there is no effective replacement for R410A in VRF or VRV systems. It should be written that these systems are allowed a <2000 GWP limit only for legacy equipment. As these systems are typically charges greater than 20Kg in occupied commercial spaces you would be unable to use any flammable alternative as per the Standards AS/NZS 5149

Commercial refrigeration – food retail, eg, supermarkets and self-contained cabinets - Proposed Servicing Phase out limit 2023 <750GWP
Does not allow for Low temp units operating R404A. Suggested these low temp units are allowed to use R452A. Where the charge may exceed 500grams and HC is not permissablw there is no suitable refrigerant other that R452A as it has a discharge temperature post compression roughly the same as R404A. Other gasses we have tried have elevated discharge temperatures of 25% to 38% higher than R404A causing the compressor to fail.

Commercial refrigeration with <40kW rated capacity excluding food retail and applications below -50°C, eg, food service, restaurants, walk-in cold rooms, milk vats - Proposed servicing Phase out limit 2023 <1500GWP
Overall I support this but suggest the Kw limit be increased to 50Kw as below this threshold there is little benefit from CO2 as the installed carbon footprint of the plant would be 4 times that of a HFC plant and in transcritical mode power consumption would be significantly higher. We can certainly meet the sub 1500 GWP in medium temperature however in low temp (-20 deg C or below) the only solution currently is R452 with a GWP of 1945 so I would create a separate application for low temp with a service ban on refrig over 2000 GWP. These low temperature applications would make up around 20% of the <50Kw commercial refrig applications (including Ice banks for Dairy)

Transport refrigeration, eg, refrigerated trucks, shipping containers, fishing boats and reefer vessels - Proposed service Phaseout limit <1500GWP
Like commercial refrigeration consideration needs to be given to Low temperature application with a <2000 GWP limit imposed

We are Engineering and designing Glycol systems for large 100Kw + medium Temperature cool stores now and expect this to increase. CO2 has limitations and challenges but find it a good choice for Supermarkets and large industrial Low temperature applications over 50Kw but find CO2 systems are expensive to install, difficult to maintain stable operation and very inefficient in ambients above 28 degrees. My view is as the available HFO's are expanded and commercialised these will become the dominant refrigerants in the sub 50Kw range and Chillers

None come to mind in terms of design other than a greater use of chilled water in larger plant as previously discussed