On December 23rd, 2013, the U.S. Environmental Protection Agency published a proposed rule titled, “Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import and Export (2015-2019).” This rule, when finalized, will determine the amount of HCFCs, and in particular, R-22, that can be produced and imported over the next five years. As part of the ruling process, industry stakeholders have the right to call for a hearing to share their perspective. A hearing was requested and on Thursday, January 23rd, a number of industry stakeholders gathered in Washington, D.C. to provide perspective.
From all accounts it was an emotionally charged hearing that was attended by a large number of representatives from nearly every sector of the HVACR industry, as well as a couple of very high profile environmental protection organizations. Many of those sharing perspective at the hearing emphasized the damages caused to the environment, to industry, and to consumers as a direct result of the EPA’s over allocation of R-22. Industry stakeholders and environmental groups have voiced their concerns about the EPA’s service requirement estimates for many years now, but despite the volumes of data and commentary, the EPA continued to allocate far more product than the industry needed. One of the commenters at the hearing summed it up well by saying, “If the holders of allocations can make virgin 22 for as low as 50 cents a pound, who will invest in reclamation and alternative refrigerants? The effect of the 22 oversupply is so evident and so devastating on the reclamation and alternatives industry — and the environment — that it is difficult to fathom how something like that could be allowed to happen. As a result of the April 2013 rule alone, EPA increased the 22 supply by 24 million pounds. That is 825 tractor-trailer loads of gas, with the same impact on the environment as eight coal-fired power plants’ annual emissions of CO2”.
The collective voice at EPA’s January 23rd hearing made it crystal clear, the EPA’s actions to date regarding HCFC allocation have caused tremendous damage and the only responsible, and reasonable course of action that will put the phase out of ozone depleting HCFC’s back on track, and restore market confidence, is to drastically reduce, or even terminate, R-22 allocation.
Many now believe that the EPA cannot deny the facts any longer and they will reduce the allocation beyond their “preferred” option as stated in the December 23rd proposed ruling. The current surplus of R-22, and vast capacity of the reclaim industry, will be more than capable of supplying adequate amounts of R-22 for critical applications where alternative refrigerants are not suitable. The EPA is expected to publish a final ruling in April of this year and the HCFC market has already begun to respond.
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