Response 1031753792

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Submitter details

5. Please choose any you are associated with:

Please select all that apply
(Required)
Academic or subject matter expert
Agricultural process or representative
Business
Farmer/grower
Iwi/Hapū
Local council
Local government
NGO
NZ ETS participant
Rural professional or farm advisor
Other
Not applicable

Section 2: Regulated product stewardship

1. Do you agree in principle that a regulated framework should be introduced to ensure effective product stewardship for synthetic refrigerants?

Please select one item
Yes
No
Please explain your answer here
As the supply and end-of-life treatment of these gases is part of a commercial enterprise any variation in quality of service has an impact on the competitive market. Regulating these activities ensures a level playing field for the market and does not give a competitive advantage to participants doing the wrong thing.

2. Do you agree with the proposal to make it mandatory to sell a product only in accordance with an accredited scheme for synthetic refrigerants?

Please select one item
Yes
No
Please explain your answer here
As a local installer of heat pumps we are at the mercy of our international suppliers with regard to the refrigerants they use. The proposal would ensure an "underground" market of lower priced but harmful products does not spring up.

3. What would be the impacts on your business if your participation in the proposed schemes is required? Please provide details of anticipated costs, benefits and other impacts.

Write your answer here
We already invest in training and treating harmful F gases in a safe way. Sustainability is a selling point for us, so any investment required would be welcome as long as the rest of the market are involved.

4. Do you agree with the proposal to restrict sales of F-gases, in bulk, pre-charged units or products, to companies that are registered with an accredited scheme or an individual who can demonstrate appropriate competence recognised by an accredited scheme under section 23(1)(b) of the Waste Minimisation Act 2008?

Please select one item
Yes
No

5. Do you agree with the proposal to require businesses decommissioning, dismantling, disposing of or recycling equipment containing refrigerants or other synthetic greenhouse gases to register with an accredited refrigerant stewardship scheme and demonstrate appropriate competence recognised by the scheme under section 23(1)(g) and (h) of the Waste Minimisation Act 2008?

Please select one item
Yes
No
Please explain your answer here
As per reasoning above

6. Do you agree with the proposal to require businesses that install, service, modify or dismantle any equipment containing or designed to use any controlled substance that is a refrigerant, or the direct handling of these substances involving a possible risk of their release into the atmosphere, to: (a) register with the accredited refrigerant stewardship scheme and (b) demonstrate that employees have the appropriate competence recognised by that scheme for their work, under a new regulation using section 11 and section 16 of the Ozone Layer Protection Act 1996?

Please select one item
Yes
No
Please explain your answer here
As per reasoning above

7. What would be the impacts on your business if registration with an accredited refrigerant stewardship scheme and appropriate competence assurance for technicians were required for the sale and management of F-gases?

Please provide details of anticipated costs, benefits and other impacts.
Probable costs associated with training staff and any equipment required.

8. Do you agree in principle that a regulated refrigerant scheme should be funded in the first years through New Zealand Units earned under the New Zealand Emissions Trading Scheme by the Trust for the Destruction of Synthetic Refrigerants while longer-term funding options are developed and consulted on?

Please select one item
Yes
No
Please explain your answer here
I feel this is an investment in the environment

9. Do you agree that any person whose business is or includes the decommissioning, dismantling or degassing of any equipment containing or designed to use controlled substances, or any representative of such persons, be required to ensure that disposal of F-gases or other synthetic greenhouse gases is through full destruction (eg, plasma arc plant) or recycled into plant with documented leak-testing and repair protocols, never by release to the air under section 23(1)(g) and (h) of the Waste Minimisation Act 2008?

Please select one item
Yes
No