Transcript Update on the New EC Regulations

EC Control of Ozone Depleting Substances
Update on the Draft EC Regulation
Presented by Pacific Scientific
at the
International Halon Replacement Working Group Meeting
Bremen - May 2000
EC Control of Ozone Depleting Substances
Update on the Draft Regulation
• Background and Status
• Halon
– Controls
– Critical Use
– Import / Export
• Impact for Aerospace
• Airline Strategy
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Background
• New Regulation first seen in draft form in Aug
1998.
• Proposes controls on the production, use,
sale, import, export and recovery of ODS’s,
including Halon.
• Includes Halons, CFCs HCFCs etc.
• Will replace regulation 3093/94, which
prohibited production of Halon and other
ODS’s.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Current Status
• 2nd reading of the EU Parliament Dec 99
• Some outstanding issues on HCFCs
• Halon aspects are agreed.
• Could be adopted June 2000.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Current Status - Entry into Force
• Probable date is 1st October 2000.
• UK and others suggested 1st Jan 2001 to
allow time for national ratification.
• Will supersede current national legislation in
those countries which already have local
controls (e.g. Germany)
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Halon Controls (Article 4)
• Prohibits sale or use of Halons after entry into
force, except as allowed below:
– Use and sale of recovered/reclaimed Halons in
existing systems until 31 Dec 2002
– All systems and extinguishers must be decommissioned by 31 Dec 2003.
• Exceptions for critical uses which are listed in
Annex VII of the regulation.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Critical Uses of Halons (Aircraft)
• Halon 1301
– “In Aircraft for the protection of crew compartments,
engine nacelles,cargo bays and dry bays.”
• Halon 1211
– “In hand-held fire extinguishers and fixed extinguisher
equipment for engines for use on board aircraft”
– “In Aircraft for the protection of crew compartments,
engine nacelles, cargo bays and dry bays”
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Import Controls (Articles 6 & 7)
• Import Licensing
– The restrictions are similar to those in 3093/94.
– An Import Licence issued by the Commission is
required for bulk imports. There will be quantitative
limits.
– Affects both Free Circulation and IPR imports.
– Free Circulation import only permitted for essential or
critical use or destruction.
– In the event of a Halon shortage, obtaining an import
Quota/Licence is likely to be a protracted process.
– No restrictions on products for critical uses.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Export Controls (Articles 11 & 12)
• Export of products and equipment containing Halon will be
permitted for Critical Uses
• It is understood that bulk export of Halon will not be
permitted, even for Critical Uses
• Applies from Entry into Force date.
• Export Licences issued annually with quantity limits and
stated destinations.
• Applications will need the support of the national
enforcement agency.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Impact for Aviation
• Users need to secure supplies before phase-out date.
• Affects non-EC users that are dependant on EC Service
Providers.
• Airline is the Critical User, not Service Provider.
• Service Providers are unlikely to accept the full risk of
Investment / Destruction Costs.
• US shortage of Halon could affect new aircraft deliveries ?
• Waste Bin Extinguisher not a Critical Use?
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Factors Affecting Future Needs
• Unknown existing stocks (Banked or Installed)
• Unknown end dates for each application.
• Fleet growth
• New regulation (D to C, etc.)
• Consumption ( Fires, False Warnings, Hydrostatic Testing)
• Economics, Feasibility and Timescale for a changeout on
existing aircraft.
• Emergence of new technologies.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Airline / Airframe Mfr Strategy
• Forecast of Future Needs is a priority.
• Strategy for continued availability.
– Airline Halon Bank
– Contracted Halon Bank or Contracted Supplies.
• Plan should consider the risk of a US Shortage
– Possible need to source the Halon needed for new
aircraft.
• Regular purchases during Phase-out
– Minimise Financial Impact/Availability risks.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Support from Service Providers
• Provider/Repair Station probably can:
–
–
–
–
Assist with the Airlines requirements forecast.
Assist with the sourcing of Halon before Phase-out.
Provide recovery and banking facilities.
Provide ongoing Overhaul and Recharging facilities.
• Provider/Repair Station probably won’t/can’t :
– Provide or guarantee the needs of the industry from their
own resources.
– Take the risk of subsequent destruction costs unaided.
– Stabilise Halon prices - now a commodity.
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Conclusion
• Airlines and Manufacturers need:
– A forecast of future Halon requirements, which includes
a “What if” analysis.
– A plan on how this will be provided.
– The plan should be reviewed regularly to take account
of changing availability and alternatives progress.
– Active management of their Halon source, either
through an Airline Bank, a Contracted Bank or a
Supply agreement.
– Waste Bin Extinguisher replacement ?
May 2000
Pacific Scientific Maidenhead UK
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EC Control of Ozone Depleting Substances
Finally
• If an Airline is going to rely on a Supplier
agreement alone:
– They need to be pretty confident the supplier will still
be in business and able to supply when Halon is
needed.
– They are gambling on the Airline’s future, because the
Halon price could be nothing, or a fortune.
May 2000
Pacific Scientific Maidenhead UK
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