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NEA’S RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE PROPOSED CONTROL OF HYDROFLUOROCARBONS (HFCs) IN SINGAPORE
The National Environment Agency (NEA) has concluded the public consultation on the proposed control of Hydrofluorocarbons (HFCs) in Singapore. The three-week consultation exercise was open for public comments from 4 Sep 2017 to 25 Sep 2017.
2 From this consultation exercise, a total of 3 submissions were received from companies and there was no feedback received from the members of public on the proposed control of HFCs in Singapore.
3 NEA has reviewed the submissions received and provided our responses to the submissions in the table below.
4 The NEA appreciates the feedback and comments received on the proposed control of HFCs in this consultation exercise. We would like to thank all stakeholders who have participated in the consultation exercise and would like to encourage all parties to actively participate in future calls for comments.
Introduction
The National Environment Agency (NEA) is conducting a public consultation on the proposed plan to include 18 types of Hydrofluorocarbons (HFCs) in the Environmental Protection and Management Act (EPMA) for licensing controls. The consultation exercise will last for 3 weeks, starting from 4 Sep 2017 to 25 Sep 2017.
2 Singapore is a Party to the Montreal Protocol on Substances that Deplete the Ozone Layer. The main aim of the Montreal Protocol is to reduce and eliminate the production and consumption1 of Ozone Depleting Substances (ODS). At the 28th Meeting of the Parties (MOP-28) to the Montreal Protocol held in October 2016, an agreement known as the Kigali Amendment was adopted by all Parties to phase down the production and consumption of Hydrofluorocarbons (HFCs), which are not ODS but are potent greenhouse gases (GHG).
3 Commonly used as refrigerants in Refrigeration and Air-conditioning (RAC) equipment, HFCs are key replacements for Hydrochlorofluorocarbons (HCFCs), which are ODS that are being phased out under the Montreal Protocol. In view that the consumption of HFCs is increasing as a result of the mandate to phase-out HCFCs, the control of HFCs has come under the ambit of the Montreal Protocol.
Key Elements of the Kigali Amendment
4 Entry into force: The Kigali Amendment will only enter into force, earliest on 1 Jan 2019 provided that there are 20 instruments of ratification2 deposited. In the event this condition is not fulfilled by 1 Jan 2019, the Amendment will only enter into force on the 90th day following the date on which it is fulfilled. As of 1 Aug 2017, 4 Parties have ratified the Amendment, namely Marshall Islands, Rwanda, Federated States of Micronesia and Mali.
5 List of controlled HFCs: Under the Kigali Amendment, 18 types of HFCs are listed as controlled substances in Annex F of the Montreal Protocol. Apart from controlling pure HFCs, any blends and mixtures that contain one or more of the listed HFCs will also be controlled. The list of HFCs to be controlled is in Annex A.
6 Consumption phase down schedule: Differentiated production3 and consumption phase down schedules were established for 4 different groups of Parties. Singapore belongs to Article 5 Group 1 and the HFCs phase down schedule for this group is illustrated in Fig. 1 below. The phase down of the consumption of HFCs in accordance with the schedule will only apply when Singapore ratifies the Kigali Amendment as a Party and after the Kigali Amendment enters into force.
Fig.1 : HFCs Consumption Phase Down Schedule for Singapore
7 National consumption baseline level: Referring to Fig. 1, the phase down schedule will start in 2024 with a freeze at 100% of the national consumption baseline level. Singapore’s consumption baseline level for HFCs is calculated in terms of carbon dioxide equivalent (CO2-equivalent) based on 2 components, namely (i) Average HFCs consumption in Year 2020 to 2022 and (ii) 65% of the earlier established HCFC baseline.
Proposed Regulatory Control
9 To prepare Singapore for the ratification to the Kigali Amendment and to meet the related provisions, NEA proposes to include the 18 types of HFCs as Hazardous Substances in the Second Schedule of the EPMA for licensing controls.
10 Companies that are importing and exporting any of the listed HFCs will be required to obtain a Hazardous Substances licence from NEA (Pollution Control Department) and comply with the stipulated licensing conditions.
12 Parties/public who wish to provide feedback on the proposed control of HFCs should submit their comments to lim_kai_yun@nea.gov.sg. The consultation exercise will end on 25 Sep 2017.
13 In order to ensure that the consultation is productive and focused, respondents are requested to adhere to the following guidelines when providing their feedback:
a. Identify yourself as well as the organization you represent (if any) so that NEA may follow up with you to clarify any issues, if necessary.
b. Be clear and concise in your comments.
c. Focus your comments on the proposal and how it can be improved.
d. Substantiate your points with illustrations, examples, data or alternative suggestions.
14 This proposal is released for the purpose of consultation. All relevant comments received during the consultation exercise will be taken into consideration.
1 Consumption in Singapore’s context is computed based on “Total Import Quantity minus Total Export Quantity”.
2 Ratification in this context is broadly used to represent instruments of ratification, acceptance or approval of the Amendment deposited by States or regional economic integration organizations that are Parties to the Montreal Protocol on Substances that Deplete the Ozone Layer.
3 As there is no HFC production in Singapore, the production phase down schedule will not apply to Singapore.
