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Appendix 2: COPA hierarchy for end-of-life gas treatment
1. There is no international consensus regarding what gases, from an environmental perspective, are better suited for reclamation or destruction.
However, the Climate Protection Ozone Alliance (COPA) has prepared a ODS (ozone depleting substances) and HFC management hierarchy
(see Figure 1 below). The COPA hierarchy can be a useful tool for considering preferred end-of-life options for legacy ODS and HFCs.
Figure 1.
COPA’s hierarchy for end-of-life gas treatment
2. Under the COPA hierarchy, chlorofluorocarbons (CFCs, legacy ODS that can have a high GWP) are recommended to be destroyed rather than
reclaimed. The production of CFCs has now been phased out by the Montreal Protocol, with a near complete ban in place since 2010. CFCs
have not been imported into New Zealand since 1996.
3. Since CFCs are ozone depleting substances with high GWP and have been fully phased out globally, there is little rationale for extending the use
of these gases via reclamation.
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4. Hydrochlorofluorocarbons (HCFCs) are the other legacy ODS in the COPA hierarchy. These ozone depleting gases also can have high GWPs.
Under the Montreal Protocol, developed signatory countries phased out HCFCs by 2020. HCFCs have not been imported into New Zealand since
2015. Developing signatory countries started the HCFC phase-out process in 2013 and are working towards a completed phase-out by 2030.
5. Since HCFCs are still in use in many countries, the COPA hierarchy recommends reclamation before destruction, with an asterisk noting that
reclamation of HCFCs should be subject to a cutoff date that is aligned with a country’s HCFC phase-out timeline. In this context, it could be
argued that New Zealand has already moved well away from the use of HCFCs and that these ozone depleting gases may be better suited for
destruction.
6. For HFCs, these gases are being phased down (rather than phased out) under the Kigali Amendment. Since these gases are still in widespread
use internationally (including in New Zealand), the COPA hierarchy recommends reclamation before destruction.
7. s 9(2)(f)(iv)
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