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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
2
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
3
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
4
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
5
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
6
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
7
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
8
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
9
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
10
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
11
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
12
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
13
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
14
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
15
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