Comment submitted by Rick Boettcher, Owner, Bettcher Enterprises, Inc

I am the owner of small refrigerant recovery business. I own and operate a Rapid Recovery franchise in Cleveland, Ohio. Using the only EPA certified gasoline power recovery equipment manufactured today, I and my EPA certified technicians specialize in recovering refrigerants for the HVAC, demolition, recycling, and refrigeration industries. All the refrigerants we recover are recycled, reclaimed, or destroyed. Refrigerants that are not left on site with the customer are shipped to Consolidated Refrigerant Reclaim in Peoria, AZ. Recently I was made 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 as outlined in the proposed rule. 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 competitors who find it easier and more profitable to vent. 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.