R-22 Allocation Levels Can Be Lower Than the EPA Is Proposing
I would like to comment on the article titled “EPA Proposes Final R-22 Phaseout Timeline” in the Dec. 30, 2013 issue of The NEWS concerning the [Environmental Protection Agency’s] EPA’s proposed rule for HCFC allocations in 2015-2019.
While we do appreciate the EPA’s challenges with prescribing an allocation remedy that will suit the varying interests of stakeholders, as well as consumers, we believe there is a very strong case to be made that all three of the allocation options put forth by the EPA for the 2015-2019 HCFC allocation would far exceed actual service industry requirements.
There are some basic known facts that, if given the consideration they deserve, support much lower allocation levels than any of the EPA’s prescribed options, and especially their preferred option.
1. Many estimates have the surplus of R-22 as high as 100 million-125 million pounds. When you combine today’s surplus with the 51 million pounds of R-22 already allocated for 2014, there could be enough virgin R-22 to supply the industry’s needs for more than a year.
2. Over the last 10-plus years, R-22 replacement refrigerants have proven to be safe, reliable, and far more stable in price. Many were caught by surprise this year at the dramatic acceptance of R-22 replacements. With the exception of a few critical applications, such as flooded systems, the HFC alternatives are being used, with great success, in a broad range of R-22 applications, and they will continue to reduce our dependency on R-22.
3. The reclaim industry has a significant amount of unused capacity and is capable of processing and supplying the industry with millions of additional pounds of reclaimed R-22. Failing to provide the right balance to the 2015-2019 allocation could collapse an already crippled reclamation industry.
It basically boils down to this: When you consider the R-22 surplus inventories, the application range and rapidly growing base of alternative refrigerant users, and unused capacity of the reclaim industry, the R-22 allocation could be set well under any of the EPA’s proposed options without causing any disruption to service.
We are now within a 60-day comment period, and the EPA is asking for as much input as possible. If you have an interest in the 2015-2019 HCFC Allocation Ruling and would like to share your perspective, do not procrastinate. Address your email to: Ms. Drusilla Hufford, director, Stratospheric Protection Division Office of Atmospheric Programs, EPA, hufford.Drusilla@epa.gov.
ICOR Intl. Inc.
Publication date: 1/27/2014