We’ve all heard the phrase when hell freezes over. It’s probably one of the more overused statements in the English language. Recently, while trying to figure out a way to describe a recent meeting in Washington regarding the Environmental Protection Agency’s (EPA) rulemaking to govern the allocation of HCFC-22 (R-22) for the years 2015-2019, the phrase came to me as the only way to describe what I saw and heard. On a coincidentally cold day in our nation’s capital, it appeared that all of the stakeholders in the room — producers, distributors, reclaimers, environmental advocates — all agreed to one major point, that there is an oversupply of R-22 in the system.
Normally we would applaud the EPA for being able to bring these groups together. Unfortunately the reason that these parties all identified the same problem was that EPA had erred greatly in establishing the allocation for the years 2013 and 2014. The rule also included the year 2012, but was released after 2012. It’s D.C. logic, so please bear with me. In what was a shock to nearly everyone in the refrigeration community, the EPA decided to allocate roughly 33 million more pounds of R-22 than had been anticipated.