Congress Urges EPA to Accelerate Phase-down of R-22

Seal_of_the_United_States_Congress

WASHINGTON, DC (February 21, 2014)- Congressman Scott Peters (CA-52) and Senator Chris Murphy (Connecticut) led their colleagues in a letter to Gina McCarthy, Administrator of the Environmental Protection Agency (EPA), calling on EPA to take more aggressive action to cut down on production of an industrial “super pollutant” that does 1,800 times more damage to the climate that carbon dioxide. The letter was signed by 17 Senators and 24 Members of the House of Representatives.

In December, EPA unveiled a new proposal to reduce production of HCFC-22, a refrigerant chemical that’s also a potent greenhouse gas. HCFCs — hydrochlorofluorocarbons — are currently being phased-down under the Montreal Protocol, a Reagan-era treaty to end the use of chemicals that harm the ozone layer. HCFCs are used in refrigerators, air-conditioning systems, and foam blowers.

The consensus among the letter’s signatories is that EPA’s initial proposal will still allow far too much new HCFC-22 to be produced, on top of a substantial existing stockpile of the environmentally harmful chemical.

The text and signatories of the letter can be seen here.

HCFC Allocation Rule for 2013, 2014 is Signed

According to the EPA’s memo (2012 to 2014 Allocation Overview Memo), the EPA will continue to use the same HCFC-22 baseline as established in the 2011 Interim Final Rule. The Final 2012 – 2014 Allocation Rule will provide fewer HCFC-22 consumption allowances relative to the 2009 Final Rule and the same percentage of baseline for HCFC-22 production allowances relative to the 2009 Final Rule.

A pre-publication copy of the rule can be found here –2012-2014 Pre-Publication HCFC Allocation Rule

HARDI Sees Significant Reduction in R-22

In HARDI’s December 21st E-Newsletter update entitled “HARDI Advocacy Advisory”, HARDI suggests that “Distributors should prepare for both another delay in the issuance of “no action assurance” letters by the EPA and a further reduction in the amount of R-22 which will be allocated. In 2012, approximately 55 million pounds of R-22 were allowed for production/importation in the United States and it is the recommendation of HARDI that distributors plan for another significant reduction in R-22 availability, likely to 45 million pounds nationally in 2013.”

Are Your Customers Really Getting $6.00/lb. for Their Recovered R-22?

A Market Study in R-22 Refrigerant Recovery

Recently, our wholesale partners have been asking us how a reclaimer can offer their customers $6.00 per pound for recovered R-22.  The answer is found in the details of competing reclamation programs, transaction costs and an analysis of the refrigerant recovery market.

Payment Schedules

DynaCycle’s payment schedule has the broadest tier-one purity level (97%-100%) in the industry and pays on purity-levels as low as 90%.

 

Three reclaimers are offering the $6.00 per pound buyback program at this time.  Their average purity-level to get a $6.00 payment is 99.5% and above.  In addition, they charge a shrinkage fee (5-10%) to account for the lubricants and other impurities, which further reduces the amount paid.  Here is an average of several payment schedules from competing reclaimers.  This payment schedule illustrates how quickly rates can drop when purity-levels go below 99.5%.

99.5-100%                 $6.00 (net $5.40 with 10% shrinkage fee)

99.0-99.4%                $4.00 (net $3.60 with 10% shrinkage fee)

98.5-98.9%                $2.00 (net $1.80 with 10% shrinkage fee)

98.0-98.4%                $1.00 (net $0.90 with 10% shrinkage fee)

Transaction Costs

While reclaimers will accept 50# cylinders, most prefer to have the gas delivered in 120, 240 or 1000 pound cylinders.  This requires the contractor to transfer gas at their shops and then prepare the cylinders for delivery.  The more gas that is transferred, the better the opportunity for diluting the refrigerant and driving down purity levels.

 

We did a quick study on the locations we visited that transferred their recovered R-22 into larger cylinders.  We found that half of the tanks contained gas that was 97% pure while the other half was either mixed gas or less than 97% pure.  Utilizing the payment schedule above, half of the transfer tanks would have no payment value.  Conversely, the DynaCycle 50 lb. cylinders yield an average of 84% tier-1 and 11% tier-2 R-22 refrigerant (The remaining 5% is other refrigerants and mixed gas). That means you and your customer can get paid 95% of the time.

Market Conditions

Over the last year, we sampled hundreds of thousands of pounds of recovered R-22 that came in to our program.  We found that the average purity level was 98.53%, and it has been falling throughout 2012 as the price of R-22 has increased.  There has been an increase in the number of commercial system owners reusing the R-22 that is recovered during maintenance, instead of replacing it.  R-22 that is recovered from larger commercial systems acts as a source of high-purity R-22 that increases the overall average purity-levels of recovered R-22.  Should this trend continue (and we think it will) the average purity of recovered gas will fall below 98% in the near future.

Competitive Analysis

Back to the original question…How much will your customer actually get paid for the gas they ship off to the reclaimers offering $6.00 per pound.  It is impossible to say exactly for each of your customers.  What we do know is that the average purity-level for recovered R-22 is 98.53% which yields a payment of $1.80 to $1.90 per pound ($2.00 less the 5-10% shrinkage fee).

 

So is the competition’s $6.00 figure false advertising? No.  Those programs inform the market about their purity-based payment schedule. What they don’t tell your customers is that the average of R-22 reclaimed is 98.53% pure.

 

Some may say that their average is higher than our survey. That is possible. However, logic would dictate that the difference is very small. The average purity-level of recovered R-22 does fluctuate.  Our numbers show that this average is driven by the cost of R-22.  The higher the cost, the lower the purity level of recovered R-22.

 

The DynaCycle Advantage

DynaCycle’s advantage comes from a competitive payment schedule that is properly aligned with market conditions, and an innovative, lightweight 50 lb. composite recovery cylinder.  Here are some other advantages you can share with your customer:

 

84% of the total gas on the DynaCycle program is tier one (97-100%) Which means they would receive 28% of the Market Price or $3.36 per pound vs. an average of less than $1.90 (remember the shrinkage fee) with the other programs.

 

You offer convenient wholesale branch drop-off locations so your customers don’t need to transfer gas in their shop and ship their recovered R-22 to a distant location.

 

Using the lightweight DynaCycle cylinder yields twice as much gas per cylinder than a steel cylinder.

 

The unique design of the DynaCycle cylinder makes recovering R-22 faster easier than a steel cylinder.

 

You always get your own cylinder back from your wholesaler.

 

Your customers do not have to use their credits to buy R-22.  They can use the money from their efforts to purchase anything they need for their business.

 

Your customers have 100% of their EPA paperwork done at no charge under the DynaCycle program.

 

Your customers are welcome to watch the testing of their R-22 before we pump down their cylinders and buy their recovered refrigerant.