Consultation meeting on revisions to Ozone-depleting Substances Regulations: chapter 2

Presentations and Discussion - Segment II

A. Hydrofluorocarbons

Martin Sirois (EC) provided some general background on HFCs and an overview of the proposal for a permitting and reporting system under which companies would be required to have a permit to manufacture, import and export HFCs in bulk, whether alone or in a mixture.

EC also indicated its intention to prohibit the import of HFC refrigerants in non-refillable containers and that this would help ensure a level playing field across Canada and would have a positive effect on the environment.

EC directed participants to Annex 2 of the Consultation Document, which contains a list of HFCs that would be subject to the permitting and reporting system, and indicated that hydrofluoroolefins (HFOs) would not be captured, as they do not meet the definition of HFCs included in Schedule 1 of the Canadian Environmental Protection Act, 1999.

B. Discussion

Heel

A question was raised on whether the provisions would apply to the “heel,” meaning the residual quantity left in a container after it has been emptied. Another participant asked whether the permitting system would apply to HFC in bulk or in products.

EC responded that the proposed provisions would not apply to the “heel” (“heel” is defined in the Regulations) and that they would apply to HFC blends, and pure HFCs, in bulk, and not to manufactured items, such as vehicles.

Inclusion of HFOs

A participant questioned why HFOs were not covered by the proposal.

EC responded that HFOs have low global warming potentials (GWP) and are considered to be environmentally friendly alternatives to HCFCs and HFCs. In addition, HFOs are added to HFC blends/mixtures to reduce GWPs of the blend/mixture.

Scope of reporting

Another participant asked for clarification on the reporting system and whether regulatees would be required to report HFCs that are a component of blends.

EC responded yes. If HFC is present in a mixture, a report will have to be submitted, and each HFC in the mixture will have to be reported individually.

Permit system and stewardship program

Another participant inquired as to whether the permit for HFC activity would be tied to participation in the stewardship program.

EC responded that this is not currently the intent. However, EC is open to considering comments submitted on such a proposal.

Permitting system

Another participant sought clarification on his understanding that there was no intention to introduce caps on the volumes manufactured, imported or exported.

EC confirmed that no cap or phase-down is being proposed.

Another participant questioned the need for permits that specify quantities and specific uses, and the burden it would place not only on stakeholders, but also on EC in issuing the permits in a timely fashion. He added that this seemed like an unnecessary level of bureaucracy, and that quarterly or biannual reporting could be considered instead as a means to acquire information on quantities and uses.

EC indicated that the permit could be an estimate of the quantity manufactured, imported or exported, and that annual reports would contain actual quantities that were manufactured, imported or exported over that calendar year. Alternatively, the permit could authorize the manufacture, import or export of HFCs without specifying the use or quantity.    

With respect to a permit being issued for multiple purposes as opposed to one permit per use, EC indicated that it would consider this and try to make the permitting system as effective and efficient as possible.

One participant noted that the permitting system puts a framework in place in the Regulations for when a phase-down may be considered in the future.

Finally, a participant asked if any restrictions existed on who could obtain a permit.

EC responded that anyone who is an Importer of Record and has a place of business in Canada could apply for a permit.