Hydrofluorocarbons (HFCs) are synthetic gases that are primarily used for refrigerants, air conditioning, and heat pumps. They’re also found in foams, aerosols, fire protection and solvents. Originally developed as a substitute for other gases that were depleting the ozone, HFCs are now among the fastest growing source of greenhouse gases (GHGs) in the world. Considering they are more potent than C02, it is critical that HFCs are properly managed and handled carefully when recycled or disposed.
To help address the problem, on behalf of our client Global Shapers, the ELC prepared two submissions that raise questions and provide recommendations for how governments could more effectively address HFCs.
Federally, we asked the Commissioner of the Environment and Sustainable Development to investigate Canada’s approach and to address gaps in the safe recycling and disposal of HFCs. We provided our evaluation of Canada’s policies around HFCs and identified a clear and compelling need for law and program reform with respect to safe disposal of HFCs. Specifically, we recommended the federal government:
- Identify gaps in stewardship program coverage of HFC disposal across Canada and implement solutions to address them.
- Investigate how and where HFCs are being collected, destroyed or recycled in Canada, and have the information available to the public.
- Evaluate whether Canada is doing enough to comply with its goals with respect to HFC replacement education, research, and development.
Provincially, we asked BC’s Minister of Environment and Climate Change Strategy to investigate the need for recycling plans and stewardship programs specifically for automobile air conditioners and heat pumps containing HFCs. Automobile air conditioners and heat pumps are regulated differently than other products containing HFCs (i.e., refrigerators) that are captured under BC’s Extended Producer Responsibility Program.
While regulations to control air conditioners and heat pumps require sellers to prepare a stewardship plan for managing HFCs, there are no current programs for recycling, converting or disposing of these specific HFC products in BC, which raises serious concerns as there are large climate risks associated with the ineffective regulations of safe HFC disposal for millions of automobiles in BC and the ever-growing number of heat pumps. Global Shapes hopes to use the two ELC submissions to raise awareness that will lead to change in dealing with this growing problem.
I learned a great deal writing the ELC’s submission to the Federal Commissioner for the Environment and Sustainable Development, but what surprised me the most was how difficult it was to get a good sense of what every level of government was doing to regulate HFCs. By virtue of Canada’s constitutional structure, federal and provincial governments must both regulate greenhouse gases to meaningfully mitigate their impact. This leads to some unsettling possibilities. A policy initiative may be taken up by Ottawa but not be meaningfully supported the provinces, or an initiative may be addressed comprehensively in some provinces and less so in others. No matter what political jurisdiction they leak from, greenhouse gases always end up in the same atmosphere. I spent a lot of my ELC semester piecing together who was doing what and, more importantly, what wasn’t being done by anyone, when it came to HFC regulation. The number one thing I want people to learn from this submission is this: eliminating HFC usage worldwide has been estimated to avoid between 0.3 and 0.5 degrees Celsius of total global warming by the year 2100. That’s a lot! Eliminating HFC leakage and promoting a transition towards using alternative coolants is an important goal that at the moment goes under-discussed by the public.
Parker Fogler, ELC Clinic student