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6 Fire Protection

Summary

This sector is a very small source of HFC emissions because there are such low discharge and leakage rates. It would be relatively easy to include in the ETS (if imported equipment is covered) with just one or two import points of obligation.

However, apart from ETS consistency with other sectors and within the sector, there are no clear benefits when there is such a low leakage rate. The HFC price is already high enough to ensure that recycling is maximised.

The main supplier stated that ETS pricing would probably “kill the market” if it includes imported equipment, so there may be no new HFC installations. If the ETS point of obligation is only on bulk supply, there may be little change in the costs of current systems because of the low leakage rate.

HFCs are used as substitutes for halons in portable (streaming) and fixed (flooding) fire protection (fire suppression) equipment. Halons have traditionally been used in areas that contain high-value equipment and where risks to personal safety are high. These include computer rooms, data centres and on aircraft.

Within the New Zealand fire protection industry, the two main supply companies were identified as using relatively small amounts of HFC-227ea. The systems installed have very low leak rates with most emissions occurring during routine servicing and during accidental discharges.

For the inventory, a 1.5% leakage rate was assumed from an HFC bank of 28 tonnes resulting in emissions of just 0.4 tonnes in 2006 (CRL Energy 2007).

6.1 Stakeholders and potential points of obligation

Chubb is the main supplier and about 90% of its HFC imports are pre-charged in equipment (Boff 2008). The company also imports about 0.2 tonne of bulk HFC annually for servicing and accidental release. Tyco Wormald has been a minor supplier in earlier years but imported none in 2006. There are also some very minor suppliers of marine fire protection systems (some of which may purchase their HFC from bulk suppliers).

Clearly, this sector would be relatively easy to include in the ETS (if imported equipment is covered) with just one or two import points of obligation. However, apart from ETS consistency with other sectors and within the sector, there are no clear benefits when there is such a low leakage rate. The HFC price is already high enough to ensure that recycling is maximised.

6.2 Export implications

There appear to be no current export implications in this sector. Conceivably, ETS pricing could cause a shift away from current HFC systems and the reclaimed chemical could be exported.

6.3 Compliance costs

The two main suppliers already keep detailed records that would readily meet the audit requirements for an annual return.

6.4 Potential for alternatives

There are currently a couple of alternative fire protection systems that operate very differently from the HFC systems. Tyco Wormald markets Inergen and Chubb markets Argonite. Both are based on nitrogen/argon mixtures where the gas is relatively inexpensive while the hardware is very expensive, making the whole system more expensive than an HFC system currently with its high gas cost but low hardware cost. Chubb also referred to Novec, a very expensive fluorinated ketone that presumably has a low Global Warming Potential.

6.5 Price impacts

Chubb stated that if a $30 per tonne CO2 price translates to a price increase of $87/kg HFC-227ea, “that will kill the market” (Boff 2008). The current gas price for bulk supply is $43/kg and with good service records, any retired gas is readily reclaimed for stock.

Presumably, if the ETS point of obligation is only on bulk supply, there may be some shift in new installations away from HFC with little change in the costs of current systems because of the low leakage rate. If instead the ETS point of obligation includes imported equipment, there may be no new HFC installations. Either way, with a low leakage rate, the ETS pricing will have a negligible impact on emissions by 2015 compared with BAU.

If some minor marine system installers purchase HFC from bulk chemical importers, an equity issue may arise within the sector that might need further investigation.

6.6 Uncertainties

With the main suppliers keeping excellent records, there would be no uncertainty around coverage of these stakeholders. It is uncertain how many minor suppliers might be affected and how significant their sales are.

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