Comment submitted by Jeff Greer, Owner, Greer Holdings, LLC

I am a small businessman. I own and operate a Rapid Recovery franchise in Minneapolis, Minnesota. My business is refrigerant recovery. Using the only EPA certified gasoline power recovery machine in the world, my company specializes in recovering refrigerants for the HVAC, demolition, recycling, and refrigeration industries. All the refrigerants we recover are recycled, reclaimed, or destroyed. All the work we do is performed by EPA certified technicians using EPA certified equipment. Refrigerants that are not left on site with the customer are shipped to Consolidated Refrigerant Reclaim. Recently I became aware that the EPA is considering decreasing the production and consumption allowances for the production of HCFC refrigerants, specifically R-22. I am writing to encourage the EPA to reduce the amount of virgin R-22 that is manufactured and imported for sale in the U.S. In my experience my customers are far more inclined to recover R-22 if they receive payment for the used gas. At the present price level it is nearly impossible for Consolidated, or any other reclaimer, to offer a buyback price that will meet the cost of recovery on most projects, much less provide a profit for the contractor. It is painfully obvious that the economic realities of the past few years have been hard on small businesses. Even those contractors, who want to follow the law, find themselves disadvantaged by those who find venting easier and more profitable. If the availability of R-22 were to decrease, the value of reclaimed product would increase and the industry would be incentivized to increase the buyback price paid to contractors. The result would be more recoveries, more product for reclaimers, and far less refrigerant vented into the atmosphere. Therefore, I encourage the EPA to enact the proposed rules, decreasing the quantity of available virgin R-22 to the fullest extent proposed. Jeff Greer Greer Holdings, LLC 9200 Cedar Forest Rd Eden Prairie, MN 55347 952-297-2011