The REVENGE of Dry Units
Now that almost one-third of all equipment sold is in the form of DRY units, and that percentage is growing every month due to unprecedented consumer demand. What could possibly happen to alter the course to where R-22 is again the dominant refrigerant in the marketplace? Here enters the Environmental Protection Agency (EPA)…
In early January one of the principal manufacturers of R-22 wrote the following excerpt to a major HVAC wholesaler…
“As you are probably aware, on December 30, 2011 the U.S. Environmental Protection Agency (EPA) published its proposed rule for HCFC-22 Production and Consumption Allocation Rights for 2012.
These rules reduce and phase-out, over time, ozone-depleting substances in compliance with the Montreal Protocol.
The previous rule allocated 45.4 KT (100 Million Lbs) in 2011 and 40.7 KT (90 Million Lbs) of R-22 for 2012. In this latest proposed rule, the EPA may reduce the quantity available for production and import in 2012 to between 25.1 to 36.2 KT (55 Million Lbs to 80 Million Lbs)…
As of today, no producer or importer has the legal right to manufacture or import R-22 for refrigeration or air-conditioning use. Under such circumstances they are expected to issue ‘non-enforcement’ letters to allow business continuity.
Consequently, given the current absence of the non-enforcement letters and the possibility of significantly higher than previously expected reduction in allocation rights, ______ (manufacturer’s name deleted) must now evaluate the impact such a reduction may have on our ability to meet customer demands….”
Another manufacturer writes…
“The proposed ruling (concerning production limits) will not be approved until later this year. However, in the interim the EPA has yet to release to the right holder (all the folks who have rights to make and or import R-22) their “authorization to proceed for 2012” or as it is known the “Non-Enforcement letter”. Therefore, nobody can make and or import product. We expect this letter very soon and we also expect this letter to state a significant reduction in our rights….”
I know it is tough running a government and all, but this is patently absurd! Literally thousands of businesses and countless numbers of consumers rely on an uninterrupted flow of the necessary refrigerant, R-22. To not have the printed information available weeks ago (back in 2011) concerning how much will be available is a recipe for shortages, black-market entrepreneurs and skyrocketing prices to contractors and ultimately consumers. The government solely created this “crisis” in supply, and only they can rectify the situation. This “rectifying” needs to be done sooner rather than later! The consumer demand for R-22 dry units has certainly aggravated the situation moving it from an inconvenience to a “crisis”. Knowing the above, any contractor recommending an R-22 system with the strong likelihood that there will not be reasonably priced refrigerant in the very near future to use for leaks or refrigerant part replacement is misguided at least and perhaps totally negligent in their counsel to consumers. This turn of events is truly the revenge of dry units.
Looking out for you…
Bob Cochell
Guest column written by Bob Cochell, a FRACCA Board member and member of the Energy Technical Advisory Committee of the Florida Building Commission. If you have questions or have feedback to give on this article, contact your local chapter office, or contact the FRACCA executive office at mail@fracca.org or 727-576-3225.
