David Blackhurst - Legislation + Regulations = Change

This is a video recording of David Blackhurst's presentation at the Star Refrigeration Roadshow 2013 in Glasgow, highlighting the latest developments in legislation and regulations.

Good morning Ladies and Gentlemen, it’s a pleasure to be here. As you can see, my presentation is titled “Legislation and Regulations”, which immediately puts most people to sleep, but I’m going to try and keep you awake at least for the first half hour. I’ve only been in the fridge industry now for nearly 24 years, and when I was leaving my last job – which was a marine engineering background – my then boss was a bit concerned for me. His concern was that I was moving from a dynamic and forward-looking industry (...ship building?), into what he considered to be quite a narrow and small niche field. And his concern was that I was going to get bored very quickly because nothing very much happened. I certainly didn’t realise, and he certainly didn’t realise either, that actually I was moving into an industry which at that point in 1990 was just beginning to become aware of the issues that were associated with the introduction of the Montreal Protocol. In the last 24 years, I have to say, I’ve been in an industry that hasn’t stopped changing, hasn’t had to continually look at what it’s doing, and adapt, change, and bring forward new ideas. We’re at the stage now where I think we face further changes going forward, which I think right now most of us can’t fully appreciate, except that it’s at least as big an issue going forward as it has been for the last 23/24 years.

So, where did it all start? Well, it started back in the 1970s when a couple of scientists were doing some studies and realised that there was a significant potential of the use of chemicals that contained chlorine and bromine were likely to have some of effect on our ozone layer. And it wasn’t until the early 1980s that British Antarctic Survey actually brought forward evidence that this was the case. Of course, we now all know it as the hole in the ozone layer, which is most manifested at the North and the South Poles. This picture is of the largest observed hole in the ozone layer, which was seen in September of 2006. In a sense, we’ve dealt with that. The Montreal Protocol came about because both the scientific evidence and the support from the scientists on the ground identified that the theory was in fact happening in practice. The Montreal Protocol was signed in 1987 and we are, in a sense, facing the tail end of what that has meant for our industry, which is that – by the end of next year, the end of 2014 – it will be illegal to use any chlorine-containing refrigerants. So, primarily R22, for those of us in our industry, to service and maintain plants.

Behind that – although, not really behind that, kind of to the side of it – was another issue that some people were certainly aware of. I only became aware of it, if I’m being honest, probably around the mid 1990s. Alongside creating holes in the ozone, because of the use of certain types of refrigerants, the amount of carbon dioxide that is in our atmosphere has been increasing exponentially since the start of the industrial revolution. The issue, with regards to CO2 of course, is that it’s a greenhouse gas and it has the ability to increase the temperature of the Earth. We’ve got a new set of scientific data coming out even as we speak now, and of course, this year we passed a particular milestone which is unprecedented in the history of mankind, as we’ve existed for the last few hundred thousand years. CO2 levels, background levels in the atmosphere now, have reached 400 parts per million. As Captain Kirk said, we’re definitely boldly going where no men – or women, for that matter – have been before. We’re in a new place, we don’t quite know what that means. There’s still a lot of debate amongst the scientists, but there’s no doubt that, I think, we’re in an uncomfortable place. The question is – are we going to do anything about it? Well, coming out of the identification of the fact that CO2 levels were increasing and this was having an effect on climate temperatures, is the Kyoto Protocol. It’s an interesting thing, a lot of countries signed up to it. This picture just really gives you a snapshot of where we’re at right now. The countries marked out in dark green are those countries that have committed themselves to the binding reduction targets. As you can see, it’s primarily Western and Eastern Europe, and Australia. The countries that are in orange and red are either countries that never signed up to the Kyoto Protocol, or initially signed up and then backed out. The countries in purple are countries that initially had a target, but in fact, in the second phase of the manifestation, the protocol no longer have binding targets. The rest in lime green are what as defined as “Article 5 countries”, developing countries – who again, there are no binding targets for. So, this is where we’re at. There is no significant consensus on targets for reducing CO2, other than in Europe and Australia.

And what’s the issue? Well, just in case you didn’t realise, this is carbon dioxide. This is the global warming potential of it, it’s the benchmark of it. CO2 is one. Alongside CO2, the Kyoto Protocol also identified other chemicals that are greenhouse gases. The HFC refrigerants that were developed in response to the phase-out of the chlorine-containing refrigerants affecting the ozone – their challenge is that yes, they have no ozone depleting potential, but their major issue is that they have a very high direct global warming potential. This series of pictures is representative of that. CO2 is one, R404a and R507 – which are probably the most widely used within the refrigeration industry as a replacement for the likes of R22 – has a GWP of 3800, and even the better ones in GWP terms are still much, much higher than CO2. So, these are identified as an issue, and of course they also have been part of the debate that’s been going on, with regards to the reduction of greenhouse gases. The issue with continuing to use HFCs is that – in the same way that CO2 levels have been growing exponentially over the last 200 years, since the advent of the HFC refrigerants back in about 1990 – we’ve seen the same exponential growth in use and, worse than that, leakage into the atmosphere. And because they’re such aggressive global warming gases, there’s a huge concern about their ongoing use as well.

However, it’s not all bad news. Certainly, there’s no apparent, clear direction with regards to CO2 emissions, but it’s interesting to see that – as of June of this year – both the USA and China have agreed to work together with other countries to effectively use the framework that has worked very successfully for the phase-down and phase-out of CFCs and HCFCS, to do the same with regards to consumption and production of HFCs. So, there seems to be a much clearer insight into something needing to be done with regards to the usage of HFCs.

That brings me to my almost favourite topic, which is legislation. I’ll spend the next few minutes just talking you through some of the key legislation that affects all of us who are involved in using refrigeration, and these chemicals. Let’s go back to the Montreal Protocol – as I’ve said, it was introduced in 1987, and in response to it, the European Union brought out regulations to manage and then to phase-down and phase-out the use of these refrigerants. CFCs were the initial target, because they were the most aggressive in terms of their ozone depleting potential. They’re all history – R11, R12, R502. I was just coming into the industry at the time when they were well on their way out. In response to the EU legislation, which the most recent legislation was number 2037 in 2001, 2005 and 2009 on substances that deplete the ozone layer. The UK introduced its legislation in support of that, which is the Environmental Protection (Controls on Ozone-Depleting Substances) 2011, and Ozone-Depleting Substances (Qualifications) Regulations 2009. These are the regulations that are affecting us today, in terms of how we manage the use of these refrigerants as they’re continuing to be used, but also in terms of their final phase-out at the end of next year. Just to make a point – because I was discussing with someone just before the start of this presentation – it’s not illegal to continue to use R22 in your refrigeration system after the end of next year. You just can’t service it, top it up with R22, and there are a number of strategies that companies are adopting to manage the reality, which is that a lot of companies are going to continue to be using R22 after the end of next year. They’re working on strategies to allow them to be doing that legally. Star Refrigeration will not, at the end of next year, be charging more R22 into systems, because that will be illegal – but there different strategies for managing that.

So, we had the Montreal Protocol that dealt with the ozone depletion, and in 1997 we had the Kyoto Protocol. The UK signed up to it and made commitments to meeting an admissions target for CO2, or CO2 equivalents. The primary legislation that it affects within the UK is the Climate Change Act 2008. Just in case you had forgotten – hard to forget because it’s in the news a lot – but the primary aim for the legislation is for the UK to have reduced its greenhouse gas emissions by 80% from a 1990 base (?) by 2050. That’s the target that the Climate Change Act is heading us towards. Of course, a lot of that is to do with energy efficiency and how you manage your plant. A lot of it has to do with the issue of refrigerant usage as well. But that’s the primary aim, we’re looking for a reduction in greenhouse gas emissions of 80% by 2050.

What are the key activities of the act? Well, they’re setting our policy and our strategy. Everything you hear in the news about “are we going for carbon (? can’t make out 12:42)”, all this sort of stuff is around the strategies and policies that are being set through the act. It’s about reducing the demand for energy and helping people in businesses more efficiently, so the strategies have got lots and lots of strands. Some of it affects us at a personal, domestic level. Others affect us in terms of what companies are doing and saying in the retail market, and others affect us – those of us that are in our industry and making decisions and specifications, so on and so forth – as to how best to put in that next piece of kit that we’re looking for. It’s also about developing opportunities for investing in low carbon technologies. Reporting carbon emissions from businesses is public sector. Again, I suspect that many of you here are involved in that, as part of your day-to-day business. And finally, taking international action – trying to affect what’s happening not just in our own country, because at the end of the day, even if Britain or the whole of Europe went completely green next year, there’s still an awful lot of greenhouse gas emissions happening elsewhere. Within the initiatives, the ones that most people hear or are most aware of are the EU emissions training system, the climate change agreements which incorporate the CCL (Climate Change Levy). That’s been running now for 10-14 years. And finally, the Carbon Reduction Commitment (CRC) scheme, which I suspect that David is going to be talking a little bit more about. So, legislation has been driving a huge amount of change. We can’t get away from it. You may not realise that it’s legislation that is driving some of the stuff that’s happening in your  business, but that’s the reality. A lot of that is about energy efficiency. It’s about reducing CO2 directly into the atmosphere. For the refrigeration industry, we also have another strand – the Kyoto Protocol. The HFCs and other chemicals that have high direct global warming potential within the basket of chemicals , the Kyoto Protocol captured and said “we’re going to have to deal with these”. With regards to HFCs, which were the refrigerants with zero ODP that replaced the slightly high GWP, there are regulations in place and I suspect that most of you are aware of them. They’re called the F-Gas Regulations, and they have had quite a considerable impact on the industry over the last six or seven years. The F-Gas Regulations are there because of an EU regulation on certain fluorinated greenhouse gases and the UK’s legislation to support or back that up, which is our own Fluorinated Greenhouse Gases 2009. You may know this, but very quickly, this is what it’s about – the requirements of the EU are to prevent leakage and you need to repair any leakage as soon as possible. It’s interesting, I always thought that meant that as soon as you found the leak, you had to fix it. But I’ve been working with one client who can’t shut down his plant, except for once a year and so, he goes looking for his leaks and identifies them. But his position is that he can’t repair them for –depending on when he finds the leak – anything up to nine or ten months. The interpretation of what that means is interesting.

Other requirements are to arrange proper recovery by certified personnel – so we don’t let any Tom, Dick and Harry go and deal with these things now, at least we’re not meant to. Carry out scheduled leak checks, ensure that only certified competent personnel carry out the checks, and maintain records. On the whole, my team do quite a lot of legislative compliance work, we do a lot of inspection work. When we go looking for records, most places we go have quite good ones, and some not so, but I would say better, on the whole, than not. Unfortunately, those particular regulations were up for review. There was always the case that they were going to be reviewed around 2011, and an initial position paper was presented from the EU at the end of 2011. More importantly, that position paper said “good news, guys, the F-Gas Regulations are having an effect”. The view from the studies that were being done were that the emission rates were stabilising – but unfortunately, the position paper went on to say “if they’re stabilising, that isn’t really what we’re about. We’re not about trying to stabilise emission rates, we actually want to drive emission rates down, and consequently we’re now going to look at a range of options as to how we go forward to achieve that.” And the outcome of that paper in 2011 was an update that came on 7th November 2012 – so, about 10 months ago – and this announcement has had a really, really profound impact on our industry. I mean, the impact was a lot of headless chickens initially. The impact was “what do we do now?” And the reason for that was that the key proposal for this announcement – which, by the way, isn’t yet law, there is still a lot of water to run under the bridge before the final decision on exactly what shape this is going to take comes out – but as it stands at the moment, the key proposal is that there will be a phase-down measure, that from 2015 – so not that long now – there’ll be a total limit on the amount of HFCs that can be sold in the EU, and reduces this step to one tenth of today’s sales by 2030. So, that’s only fifteen years. With the Montreal Protocol, we’ve had 25/26 years to deal with. This is saying that, from the beginning of the year after next, there is going to be a limit and a phase-down on the usage of HFCs. The announcement that came out in November of last year gave some particular target, so it looked at the use of HFC R203 – which, by the way, has a GWP of 12,000, so I’m really quite glad that they’re dealing with that one. There will be a complete ban at the beginning of 2015 on its use in fire protection systems and fire extinguishers. Domestic refrigerations and freezers, from the beginning of 2015, will not be allowed to use HFCs with GWPs of above 150, so that kind of limits them. I’ll show you a picture in a minute of how limiting that can be. It has defined some particular recommendations – but most strikingly, I think, for industrial and commercial users of refrigeration, it also added the re-charging of existing refrigeration equipment (by the way, Star put in a nice R404a plan for you two and a half years ago, great result guys). Except existing equipment with a charge size of over five tonnes of CO2 equivalent with HFCs of very high GWPs – and at the moment, the figure is above anything over two and a half thousand – will not be permitted from 2020. So, hold the two thoughts – five tonnes of CO2 and GWP above 2500 will not be permitted in existing equipment from 2020.

Drop-in refrigerants with low GWP are already widely available in the market. I’m going to ask someone very clever at the moment, like Andy Pearson, if he can name any that he would like to use in place, but he’s shaking his head. To me, that was a really odd statement because I don’t believe that, but anyway, it’s what was in the document. So, five tonnes of CO2 equivalent, just for your information, is a refrigerant charge of 1.32kg. We’re not talking somebody’s big hairy-chested industrial refrigeration plant making whatever, we’re talking about a split air conditioning system. That’s a tough place to be. If you’ve got a charge of five tonnes of CO2 equivalent or greater, with a GWP of 2500 – R404a, if you remember, is 3800 so it’s affected – well, let’s put something else. Just let me talk through what that means for refrigerant status. Thank you very much to Bitzer for the use of this slide. This is a list of alternative refrigerants to CFCs and HCFCs. We have transitional service refrigerants, these are refrigerants that typically have some R22 in them. Then you have what we define as medium and long term. So, the HFCS – which were developed really as the long term alternatives to the chlorinated refrigerants – because the industry, certainly for 10 years, has been aware that the environmental lobby have not been happy with the use of high GWP refrigerants. The industry has been off looking at if they can make low GWP stuff, and they have came up with some interesting blends – HFOs: 1234YF, 1234ZE, and one that’s got some HFC in 1234YF. I’m not a chemist, but there’s guys out there cooking this stuff up in their labs. And then you have what’s kind of generically or euphemistically described as natural refrigerants, the far(?) and Halogen free. So, what’s the status, as of today, in terms of what we’ve heard and what we’re aware of in general terms? Well, these guys are dead, they’re gone. You’re not going to be allowed to use R22 after the end of next year, so forget about them. In terms of what the latest information coming out is telling us, anything over 2500 GWP will cause you problems after 2015, so you’re going to want to start putting systems in with it. All these guys here have GWPs above 2500, so let’s just say that they’re out. You might want to use R32 or R15a, but they’re flammable, some more flammable than others. They’re certainly potentially usable, but bring a raft of issues associated with that.

In terms of the HFCs, the fluorinated refrigerants that are chlorine free, you’re left with the likes of R134a – it’s got 1300 GWP – and in terms of it’s characteristics, it’s got some that are good for certain applications, but maybe not for others. You’ve got blends like R407, which again there is a range of these, of R407 designated refrigerants, but they suffer from temperature glide in the evaporator. Particular applications find this difficult. Particularly if you’re looking at retrofits – maybe not so much with new installations. R410a, great refrigerant, but relatively speaking has very high operating pressures, and R417a. So, fluorinated is okay at the moment. We don’t actually know what the final outcome is going to be, coming from Europe, but as things stand on the information available with regards to low GWP, there’s a bit of a question mark. This is because they’re relatively new. They are available and market-ready, some companies have been producing chillers using 1234YF and ZE. Star has done work on its chiller range using the ZE designated one as well. This one, in particular, is mildly flammable and if you ever read any of the trade magazines about air-conditioning and cars and the big debate that’s been going on there – should they use CO2, should they go for this stuff, or should they go with Mercedes who’s saying “we’re not going to touch this stuff”? They’re actually continuing to use R134a, despite the fact that there’s another regulation called the MAC (Mobile Air Conditioning regulations) which bans the use of R134a in cars now. Mercedes say, “too bad, we’re still going to be doing it”. So, question marks over these guys. Not applicable in every situation.

That then leaves us with the natural refrigerants. That’s great, there seems to be a reasonable number there, but actually all these guys are flammable. I don’t know what picture that’s painting in your head, but when I did this I realised that it’s a picture, to me, of potential restriction or reduction in options. And that’s what we face. There’s uncertainty because we don’t know, as of today, what the European Union is going to say with regards to the use of these HFCs. Except to say, I don’t think they are going to go away from the fact that 2500 will be a target. If anything, they might tighten that up and bring it even lower. There are some advocates that are saying “let’s just get down the road and ban them completely, just get rid of them all now and that’ll be done and dusted”. If you’re a betting man or woman, I’m sure that one of the betting shops would take some money off you to make a prediction on which way to go. I don’t know – and I don’t think any of my colleagues in the room would pretend to know – exactly what the final outcome will be.

I just want to run through a little bit about natural refrigerants. We all want the perfect refrigerant, and this is the criteria that all reasonable people would say is what we’re looking for. Chemically stable and inert – we don’t want it to fall to bits inside our systems. We want it to be suitable for as wide an operating range as possible. Let’s go down to -75o – there’s not a long going on below that in vapour terms, up to about 20o. Good thermodynamic characteristics, we want it to be efficient. Non-toxic – definitely, we don’t want it to harm people. Non-flammable, because that makes life hard. Zero ODP of course, low or zero GWP. We want it to be inexpensive, cheap, and we want it to be available. I want to just look at ammonia and CO2 because these are the natural refrigerants that have seen a renaissance in the last 10 or 15 years. So, what’s good about ammonia? Well,  it’s chemically stable and inert, it has a wide operating range, it’s got excellent thermodynamic properties, it has zero ODP, zero GWP – which is why it has become such an attractive working fluid to put into systems. It’s low cost,  compared to the HFCs, both for the refrigerants and the oils. Roughly £1 a kilo, or £1.50. It’s available, and it’s got a good safety record, I just want to emphasise that. There are issues, and we as a business continue to try and – in terms of our engineering and in terms of our support of clients – work very hard to try and make sure that remains the case. But it has got a very good safety record. The downside is, for those of you who have looked at it are probably aware, that it’s toxic. It will kill you, above 5000ppm. But the good news is that you it’s there when it’s at about 5ppm, so actually in terms of some of the health and safety issues associated with working fluids and some of the refrigerants, it’s self-alarming. That’s something that none of the others are. So, is it bad? Well, yes but it’s self-alarming, so you wouldn’t hang around if you smelt it. It is flammable at certain concentrations in air, but it’s not highly flammable in the way hydrocarbons are flammable. In technical terms, there are some issues, so if you want to drop it into an existing system, it’s not compatible with copper or copper alloys. There are some limitations that really affect single stage operation for reciprocating compressors, screws have pretty much dealt with them. There are oil management issues, and every time you hear something bad has happened – 12 people were killed in China just a few weeks ago through a major ammonia leak – that’s bad, and that gives the use of it a poor public perception.

In terms of how you deal with it – legislation, the regulations, the standards, the guidelines – are there to do that. They’re not overwhelming, and if there’s one message that I want to get across it’s that we shouldn’t look at legislation, regulations and guidelines as a burden, we should look at them as a means of framework within which we are allowed to operate. Under toxicity, you deal with that through the management of health and safety at work regulations and the cost regulations. In terms of flammability, the dangerous substances in explosive atmosphere regulations gave you the framework within which you can manage and deal with these particular issues. The point I wanted to make as well was – you think, “well there’s three sets of regulations I need to deal with, this is a nightmare”. But in terms of, say, toxicity and flammability with regards to ammonia – actually, the general requirements are the same for all of them. So, you need to assess the risk to health and safety. You need to prevent it if you can, you need to get rid of ammonia if you can or control its use. Put it in with control measures, and the safety standards give you a very clear guidance in some areas, not necessarily in others. You need to inform and train your staff, too many sites in the past have effectively said “well that’s an ammonia plant over there, we’re not going to tell anyone about it” and the problem then arises when you have an accident or an emergency because you have to deal with that. There’s some places where it has not gone very well, or as well as it could have, because people didn’t know what to do. So, you need to inform and train and then you need to put in place a response plan to deal with that. In many ways, all these issues – save toxicity and flammability of ammonia – can be dealt with within one document. In the same hazard assessment, you can manage those issues.

Carbon dioxide has been a real renaissance in the last ten years. It has been really interesting being involved in an industry that has brought back this killer chemical. What’s good about it? Well, it’s chemically stable and inert – it almost fits the perfect refrigerant criteria. It’s got a wide operating range, as low as -55o or thereabouts, and we’ve been running systems up that cost 20 using CO2. It’s non-toxic, it’s non-flammable. It has a positive pressure across its complete operating range, it’s very efficient at low temperatures – very efficient across the range – and it’s very cheap compared even to ammonia, it’s 10-15p a kilo. As opposed to say, £5-15 a kilo for some of the synthetics. The positive attributes do provide some potential benefits – and we’ve seen this in a number of projects that we’ve been involved with – it can significantly enhance performance. We put a plate freezer plant in for a company about 10 years ago in Doncaster, and the guy supplying the plate freezer said “you’re going to need sixteen of these for what you are wanting to do”. 1000 tonnes a week of processed meat. And when we ran the plant, we discovered that we can actually do the full 1000 tonnes with 10 or 11 plate freezers. We had effectively – not quite, but almost – doubled the performance using CO2. Smaller components – the characteristics of the gas mean the compressors’ volume requirements are less. Heat exchangers can be smaller, pipe work sizes can be smaller. In one example – a retrofit project for a large coffee manufacturer down in the South of England – it was really the fact that we were able to bring the pipe sizes down that we were able to do the retrofit project, because we were able to put the pipe work through places that, if we’d had to use ammonia or what we were replacing R22 or another refrigerant with, we would have needed much bigger pipes. And that would have been a tough call in that particular project. It has the potential, because of some of these benefits of lower cost installation now – I think most people who have put CO2 plants in would disagree with me on that – but I believe it has that potential. It definitely has the potential for lower cost operation, and there are no recovery or safe disposal problems. If you need to manage by blowing off some CO2, go ahead and blow off some CO2. It’s not an issue. Don’t blow off ammonia, because that’s an issue – and certainly don’t blow off HFCs, because that’s illegal.

It has challenges – it’s got relatively high operating pressures. CO2 at -45o is 7.3 bar gauge. The equivalent of ammonia is just sub-atmospheric at that pressure, and R404a is just about atmospheric. By the time you’re up at 0o, you’re up at 33/34 bar compared to the others. The challenge there was that when we first started looking at CO2, the industry did not have components that we could easily use. I mentioned Bitzer – the first compressor we ran, or probably the second compressor we ran with CO2, was a little Bitzer which they sold us, but they wouldn’t give us a warranty for which I was always a bit disappointed about, but there we are. The problem was operating pressures. The industry has responded over the last 10 years, and you can get standard components now – so costs are coming down, the issue of high operating pressures, I think, are not really an issue anymore, except in people’s heads. That’s some good news. Low critical temperature is a bit of an issue because it restrains the operating range as a standard vapour compression system. CO2 is 31o, ammonia is 133o, R404a is 73o. It limits where we can go. But we’ve used CO2, it has been used in cascade systems, and the industry now – I did have another graph of transcritical operation which is taking the operation of the CO2, the discharge, and operating above the critical point and that has been widely applied now in smaller systems. Supermarkets across the UK and across Europe are using transcritical CO2 very widely, hundreds of systems operating with that. So is it a problem? It’s a challenge, but the industry, again, has responded. It does affect the breathing reflex around 2% - it doesn’t asphyxiate it, but your breathing reflex just stops. Yes, it’s an issue, and you need to deal with that within your hazard assessments, but people don’t realise that in general terms it is no different from the issues you have with HFCs and HCFCs. But people don’t see that as a big issue. Again, it’s management within regulations and doing the hazard assessments.

The perfect refrigerant – that’s what we all want, but it doesn’t exist. The application of all refrigerant options and the systems that go with them is a compromise. Each carries benefits and challenges. I’ll leave you with the thought that regulation standards and guidelines aren’t there as a barrier to use. They’re there as a framework within which you can operate, and as long as you do that, then it can be done safely whichever way you happen to go. The final thought is that the way you go – there’s no one way. There’s no right answer. I can’t stand here and say “I know the right answer for every single system that’s going”, because the direction you go depends on the criteria that you decide to apply, and the waiting that you give to each. By that, I mean that things like your process requirements, the size of your load, the profile of your load, the operating temperature, the infrastructure constraints that you might have. Lots of sites exist, and you might have power or water or space constraints. The location of the site – you might say that you can’t put ammonia into this installation because... there’s one example here, an ice rink, where their plant is in the building. We can get over that. How important is that to you? Is it a new system, is it an existing system? So, there’s a range of criteria that you are going to apply, and there are relative waitings that you’re going to give to that. If the fridge guy or your consultant is saying “I know the answer, there’s only one way to do it” – I would challenge him on that question because I don’t believe that either. Thank you very much, I’ll hand back to Rob.

Last modified: Tuesday, 22 October 2013, 2:25 PM