GASES, WELDING & SAFETY PRODUCTS

Airgas, Inc.

259 North Radnor-Chester Road

Suite 100

Radnor, PA 19087-5283

Tel : 610- 902-6228

Fax : 610-687-6932

http://www.airgas.com

john.batt@airgas.com

June 27, 2013

Luke Hall-Jordan

Stratospheric Protection Division

U.S. Environmental Protection Agency

1200 Pennsylvania Ave, NW (6205J)

Washington, DC 20460

Dear Luke,

At the industry stakeholder meeting with the Alliance for Responsible Atmospheric Policy

member companies on May 14, 2013 the EPA solicited input as it drafts a proposed rule for the 

allocation of HCFC allowances for 2015-2019. Airgas, Inc. appreciates the opportunity to 

provide its comments from the perspective of a refrigerant distributor and reclaimer.

HCFC-22 reclamation has been hovering at about 20% ±2-3% of estimated industry reclamation 

capacity for the past 5+ years, despite EPA’s stated objective to increase reclaimed product 

substantially. The data from 2005 - 2011 show that the EPA has consistently issued more 

HCFC-22 Allowances than actual consumption indicating a consistent overestimation of actual 

demand as well as the amount of product being reclaimed for resale. By adding Recoupme nt 

Allowances of 2,984 MT in each of 2013 and 2014 without a commensurate offset to the base 

consumption allowances, this additional HCFC-22 volume will, in effect, reduce the volume 

amounts which the EPA assumed would be supplied from reclaimed product an d/or inventory 

drawdown, so long as the estimated service demand is indeed correct. This compounds the 

problem of the EPA’s historical overestimation of demand and failure to incent an increase in 

reclaimed volumes. 

To remedy the above problems, Airgas suggests it would be best to issue allowances for HCFC22 for 2015 to 2019 on an accelerated reduction (larger percentage decreases in early years, 

slower in later years, i.e. 30%, 25%, 20%, 15%, 10% of the total reduction) towards the complete 

phase-out of allowances of HCFC-22 in 2020. 

This accelerated reduction would counter the historical overestimation of service demand and 

promote the increased amount of HCFC-22 being recovered and returned for reclamation. This 

would provide a continual decline in availability of virgin material toward the elimination in 

2020 versus a sharp drop-off, enhancing planning ability, promoting relative stability and 

reducing uncertainty in the market, forcing continued market conversion, and giving the volumes 

of reclaimed material a chance to reach its full potential in the U.S. 
Any concerns over being overly aggressive with reductions of available consumption allowances 

in any given year are unwarranted. There is little risk because of the untapped safety valves of 

reclaimed product and inventory drawdown. There are arguably large volumes of HCFC-22 

currently sitting in inventory - some estimates place this at 45,000 to 90,000 MT - and there will 

certainly be a considerable build in inventories in 2013 and 2014 espe cially due to the nearly 

3,000 MT of additional recoupment allowances awarded each year over and above what EPA 

originally deemed sufficient. Also, an abundance of available virgin material each year has 

historically been the reason that reclaimed volumes have not significantly increased and remain 

at only a fraction of the reclamation industry’s total capacity. More importantly, a shortage, or 

perceived future shortage, of available virgin material is exactly the incentive needed to induce 

higher volumes of HCFC-22 recovery and reclamation. Free market dynamics will determine 

the pricing of HCFC-22 which in turn drives conversion and quantities of HCFC-22 being 

recovered/reclaimed.

Again, thank you for providing an opportunity for stakeholder input as t he EPA reviews its 

Vintaging Model and prepares a Proposed Rule for HCFC Allowances for 2015 -2019. I would 

be pleased to discuss our comments further and answer any questions you may have. Please do 

not hesitate to contact me. 

Sincerely,

John M. Batt

Director of Product Stewardship & Regulatory Advocacy