Toll free: 877.372.7732 

Toll free fax: 877.572.7732

Website: www.raprec.com 

Providing outstanding, nationwide refrigerant recovery for the HVAC/Refrigeration/Demolition/Marine industries.

8971 W Bloomfield Rd Peoria, AZ 85381 

EPA Allocation Actions

Dear Stratospheric Ozone Depletion EPA team,

My name is Adam Dykstra; I am the CEO of Rapid Recovery. Please allow me a moment of your time to 

reintroduce you to our company and comment on the current state of our industry.

Rapid Recovery is a nationwide network of local refrigerant recovery companies. We are uniquely 

positioned in a very specialized niche in this industry. We provide one very specific service, refrigerant 

recovery. As a franchise network we are made up of more than 30 small businesses with well over 100 

individuals and their families supported by our organization. Our team works hard everyday to provide 

value added services in 35 major metropolitan areas across the country. As a result we are the largest 

refrigerant recovery company in the country. We provide our services to demolition, HVAC, refrigeration 

and mechanical contractors, appliance decommissioning plants, facilities managers and government 

agencies. Our company was created and continues to exist solely to meet the demand for services related 

to compliance with Section 608 of the Clean Air Act.

As a company we have discovered that there are only three reasons our customers comply with the laws 

governing the recovery, recycling or reclamation of refrigerant - altruism, fear of enforcement and 

financial incentive. Throughout my nearly twenty years in the industry our company and our industry have 

lobbied for two actions from the EPA; restricted supply to support contractor incentives and visible 

enforcement actions. These are the two mechanisms over which the EPA alone has direct impact. 

We firmly believed the EPA’s option to use a carrot and stick approach would have been the best way to 

increase compliance and as a result reduce emissions. As a result, this letter will focus on the areas of 

influence independently held by the EPA.

Enforcement: Contractor level enforcement, the only truly viable place to enforce these regulations, is 

non-existent. Contractors have no fear of enforcement. The true reality of the landscape is that the 

altruistic few who desire to protect the environment find themselves at a significant competitive 

disadvantage. HARDI, ACCA, The Alliance and numerous reclaimers have voiced the need to enforce the 

law in order to restore a healthy and competitive industry. Years of engagement at the local level have 

persuaded us that enforcement is the single most effective way to assure compliance.

Supply: In the late 1990’s supply restrictions put in place as a result of the phase out of CFCs had a 

significant impact on the value of R-12. Prices of R-12 rose in both the new and used refrigerant markets 

and as a result more refrigerant was recovered. Most of the R-12 during the CFC phase out cycle was 

deployed in automobiles and as a result the market quickly peaked and fell away in lock step with the 

typically short life cycle of an automobile and it’s air conditioning system.

Fast forward a decade to the initial phase down of HCFCs. In 2008 the EPA’s allocation phase down plan 

and resulting concern over future supply, began to have a limited impact on the value of R-22. We, along 

with others in the recovery and reclamation industry, were able to begin offering small contractor 

incentives. In 2011 the EPA withheld issuing updated allocations and instead issued “no action 
Providing outstanding, nationwide refrigerant recovery for the HVAC/Refrigeration/Demolition/Marine industries.

8971 W Bloomfield Rd Peoria, AZ 85381 

assurance” letters. The HVAC/R industry immediately took notice and as a result created the perception 

of a looming shortage. Almost immediately prices of HCFCs began to climb and Rapid Recovery, along 

with others, was able to increase buyback prices for recovered refrigerants. In many cases these 

incentives offset the entire cost of recovery resulting in a significant increase compliance with EPA 

regulations. Contractors in all of our target market segments and in all of our territories who had 

previously illegally vented HCFCs began to recover.

Earlier this year the EPA did an about face by allowing allocations to increase to nearly double the 

market’s anticipated volume. This action effectively wiped out the R-22 contractor incentives provided to 

the market by reclaimers. This quickly impacted refrigerant recovery compliance. Rapid Recovery has 

been forced to reduce our refrigerant incentive by more than 75% and as of today the price continues to 

fall. One reclaimer recently released a statement to all of their customers and prospects cutting their 

contractor incentive from a high of $8 per pound to $1 per pound on R-22. Their announcement included 

a refusal to accept other refrigerants unless accompanied by R-22. The R-22 allocation increase has an 

immediate and significant impact on recovery compliance for all refrigerants.

This incredible price collapse is a move of desperation by a damaged industry. For many reclaimers their 

actions were simply about survival. One publicly traded reclaimer has seen its company’s valuation drop 

by more than 65% as a result of the EPA’s recent action. One could interpret the collapse of our 

“competitors” as an opportunity for us, but such an assumption would be incorrect. All quality businesses 

need a healthy, competitive, and vibrant marketplace. In fact, because the market is in disarray reclaimers 

can no longer offer an incentive - the carrot - that was convincing contractors to recover refrigerants. 

On August 8, 2013 the EPA issued letters to reclaimers requesting specific information under section 

114(a) of the Clean Air Act. Although Rapid Recovery is a network of recovery companies and is not a 

reclaimer and therefore did not receive the letter directly, we feel compelled to provide additional insight 

that may not otherwise be presented. Additionally, in an effort to provide a more comprehensive insight 

into the recovery and reclamation industry, we have included information beyond what was requested of 

the reclaimers. We are hopeful that doing so will provide a better perspective of the refrigerant recovery 

industry.

The chart provided below graphically depicts the volume of refrigerant, measured in pounds, that was 

recovered by the Rapid Recovery network annually between 2008 and 2012. These volumes are broken 

down into three major categories: R-22 returned for reclamation (blue bar), refrigerant of any type 

recovered and left on-site with the contractor (red bar), and all other refrigerants which were recovered 

and sent for reclamation or destruction (green bar). The white line, measured on the right vertical axis, 

represents the corresponding price paid to contractors for recovered used R-22. 
Providing outstanding, nationwide refrigerant recovery for the HVAC/Refrigeration/Demolition/Marine industries.

8971 W Bloomfield Rd Peoria, AZ 85381 

Please note that, as contractor incentives and new refrigerant values for R-22 have risen, recovery rates 

for all refrigerants have correspondingly climbed. You’ll also note that the volume of refrigerant left on-site 

has also risen which indicates that a significant volume of recovered refrigerant is being reused as 

opposed to being reclaimed. This phenomenon is most common in the grocery industry where refrigerant 

that is left on-site is normally reused in the same system or in other systems under common ownership. It 

is important to note that these refrigerants are not included in annual EPA reclamation reports simply 

because they are never returned for reclamation. 

Both reuse and reclaim are options which indicate compliance with recovery requirements. Much of the 

EPA’s information is limited to reclamation data only, however as you can see recovery has risen 

considerably as a direct result of previous phase down allocation restrictions. Just as recovery rates 

climbed as a result of an increase in new R-22 pricing and therefore contractor incentives also climbed, it 

is also reasonable to project that compliance will correspondingly fall as R-22 purchase prices and 

contractor incentives return to previous low values. 

The following chart provides a breakdown of recovery services Rapid Recovery provides to various 

industries. 
Providing outstanding, nationwide refrigerant recovery for the HVAC/Refrigeration/Demolition/Marine industries.

8971 W Bloomfield Rd Peoria, AZ 85381 

What should be noted in the previous pie chart is the very limited volume of refrigerant removed from 

contractors who service residential and light commercial systems.

It is worth pointing out that most of the refrigerant in our country is contained in systems which hold less 

than 20 pounds. This can anecdotally be shown by viewing any metropolitan area with a satellite level 

overview and comparing the shear number housing units and the refrigerated appliances they contain, 

including refrigerators, freezers, dehumidifiers and air conditioning units, to the number of grocery stores 

and large buildings which utilize larger refrigerant volume systems. Tabulate the volumes in each 

category and it becomes clear where the majority of refrigerant lies, in the small systems. This conclusion 

can also be evidenced by the statistical data available from HARDI and AHRI regarding the number of 

systems sold by size and the life cycles of those units.

As a result, residential and light commercial contractors should “produce” the highest volume of recovered 

refrigerant. This simply is not the case. In our significant experience in the refrigerant recovery 

marketplace the size, ownership structure and makeup of these contractors lend themselves to be less 

likely to have environmental motives for recovery and typically respond more readily to enforcement fear 

or financial incentives. 

The EPA has never provided a level of effective enforcement surrounding Section 608 and as a result 

there is no stick in the carrot and stick approach necessary for compliance. The environment and those of 

us that have developed business models around the recovery equipment, transportation systems, 

processing facilities and educational and technical support for Section 608 compliance have paid the price 

for that lack of enforcement. The combination of limited enforcement along with the recent decision by the 

EPA to significantly increase the surplus of R-22 has removed contractor incentives to recover and 

reclaim refrigerants across the industry. The lasting impact is significantly decreased compliance, 

increased ozone depletion and significant long term negative climate change. There is no longer a carrot 

and never has been an effective stick available to persuade the local contractor to comply.
Providing outstanding, nationwide refrigerant recovery for the HVAC/Refrigeration/Demolition/Marine industries.

8971 W Bloomfield Rd Peoria, AZ 85381 

While Rapid Recovery is not a recipient of allocations, the decisions relating to the overall volume of 

refrigerant in the marketplace have significant financial impact on everyone involved in the industry, 

including reclaimers and recovery companies.

We respectfully request that you immediately amend the allocations for 2013 and carefully consider a 

much more aggressive reduction in allocations in 2014. Limited supply will raise prices thus encouraging 

reasonable contractor incentives. These incentives will in turn create better compliance, reduce venting, 

limit ozone depletion and result in a reduction of global warming. We also implore you to use the most 

impactful compliance tool available to you, enforcement. There can be no doubt that there is a direct 

cause and effect relationship between the decisions you make and the health of our industry and the 

environment.

Thank you for your consideration,

Adam Dykstra

CEO

Rapid Recovery