FIRST RULEThe Feb. 2 issue ofThe NEWSdetailed one of those proposed rules - the one dealing with the sale, installation, and servicing of R-22 equipment after Dec. 31, 2009. While everyone knew manufacturers could no longer make such equipment as of Jan. 1, 2010, most everyone thought such equipment could stay in the distribution pipeline as long as inventory was available and serviced as long as contractors had supplies of R-22 and the equipment was repairable.
But initial readings of the proposed rule caused some head scratching and the industry spent much of the Christmas-New Year holiday preparing public comments in anticipation of a Jan. 7 hearing. Led by such major industry associations as The Air-Conditioning, Heating, and Refrigeration Institute (AHRI); Heating, Airconditioning & Refrigeration Distributors International (HARDI); and Air Conditioning Contractors of America (ACCA), presenters at that hearing showed one of the most united fronts ever by this industry. Virtually to a presenter, everyone was on the same page concerning how the wording of the proposed rule could cause true chaos.
Apparently that day of presentations was so effective that the EPA took an unusual step of issuing a fact sheet a week later that seemed to address the key points raised in the hearing and pointed to a final ruling later this year that would allow the sales, installation, and servicing of R-22 equipment for the inventoried and serviceable life of the equipment.
SECOND RULEThe second proposed EPA rule is discussed on the front page of this issue ofThe NEWS. It mainly deals with supplies of R-22 as of 2010.
The industry has known for a long time that the production of virgin HCFC refrigerants would take a drastic dive in 2010, from current 65 percent of the baseline cap set in the 1990s to 25 percent of that baseline. But that involves all HCFCs of which R-22 is just one. When the industry looked at the actual production allowances for R-22 in 2010, it found supply issues even more critical than originally thought.
The industry said we would need 137 million pounds of R-22, and we are going to get about 110 million pounds.
There is no question that the EPA has not been thrilled with efforts by contractors to recover, recycle and, most importantly, bring in used R-22 for reclamation. Had that been done in recent years at a much better pace, it was the opinion of the EPA that there would not be a shortfall.
It is interesting that in regards to this issue, the initial response to the industry is to push the reclaim option more than pushing the EPA to up the allocations of R-22.
“With this new projection, it’s become increasingly clear that the industry will need to rely on the recovery and reuse of recycled and reclaimed R-22 as well as retrofits of existing equipment to HFC replacement products to avoid shortfalls going forward,” said Diane Juliano Picho, global business manager for DuPont Refrigerants.
NOT A DONE DEALThe continuing concern is based on two situations. One is that the proposed rules are not done deals. The final rulings will not come until summer at the earliest. The second situation is that once they come down, we will be just a few months away from when they take effect.
In the back of the minds of some people is that the final ruling on sale and installation of R-22 could still be subject to some confusion to where there are calls now to get as much R-410A equipment into the pipeline as possible. And the calls for stepped up reclamation of R-22 are greater than ever.
For contractors, there seems to be two messages. One is to guard that precious R-22 of yours. Recover and recycle and take a hard look at reclamation options and start using them.
And the second message is to move to R-410A equipment at perhaps a faster pace than you - or your customers - might have wanted to do. Issues related to R-22 are still shaky. That is not the case with R-410A equipment.