Economic Impact Screening Analysis for Proposed Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export

 
		   Stratospheric Protection Division 
U.S. Environmental Protection Agency 
Washington, D.C. 20460 
            
Prepared with support from: 
ICF International 
1725 Eye Street, NW 
Washington, DC 20006 
            
June 2014




Contents
List of Tables	3
1.	Introduction	4
2.	Summary of General Approach and Key Analytical Assumptions	5
3.	HCFC-22	7
3.1.	Small Entities Potentially Subject to the Rulemaking	7
3.2.	Estimated Economic Impact on Affected Small Entities	7
Reporting Costs	7
Impact on Sales	8
4.	Other HCFCs	9
4.1.	Small Entities Potentially Subject to the Rule Making	9
4.2.	Estimated Economic Impact on Affected Small Entities	9
Compliance Costs	9
Impact on Sales	9
5.	Other Regulatory Changes	10
605(a) Use Exemption for HCFC-123 Fire Suppression Applications	10
De Minimis Exemption	10
Reporting Requirements for Reclaimers	10
6.	Conclusion	11
Appendix: HCFC Allocations	12


List of Tables
Table 1: Proposed Regulatory Options for HCFC-22	4
Table 2: Proposed Regulatory Options for Other HCFCs	4
Table 3: General Steps and Approach for Small Business Impact Analyses	5
Table 4: HCFCs, Alternatives, and Average Sales Prices ($/kg)	6
Table 5: HCFC-22 Consumption Allowance Holders Impacted By the Proposed Regulations	7
Table 6: Compliance Costs for Small Entities Submitting Paper Forms	8
Table 7: Estimated Economic Benefit of HCFC-22 Allowance Allocation (Thousand $)	8
Table 8: Other HCFC Small Business Allowance Holders	9
Table 9: Estimated Economic Impact of Allowance Allocation (Thousand $)	10
Table 10: Summary of Net Economic Benefit of the Proposed Allocations, By Company (Thousand $)	11
Table 11: HCFC-22 Allocations, by Small Business (MT)	12
Table 12: HCFC-123 Allocations, by Small Business (MT)	12
Table 13: HCFC-124 Allocations, by Small Business (MT)	12


1. Introduction
This screening analysis has been prepared in accordance with the Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA). For all rules subject to the RFA, a screening analysis is required to first determine what, if any, direct impact a proposed rulemaking may have on small entities. For rules that pose "a significant economic impact on a substantial number of small entities" (SISNOSE), an initial and final regulatory flexibility analysis is also required. 
The following screening analysis assesses the potential economic impacts on small entities associated with the adjustments to the allowance system for controlling HCFC production, import, and export from 2015 -  - 2019. The proposed allowance allocations are for HCFC-22, HCFC-142b, HCFC-123, HCFC-124, HCFC-225ca/cb, and HCFC-141b.
Table 1 provides a summary of the regulatory options proposed for HCFC-22 consumption allowances. EPA is finalizing Option 1b, a 5-year linear approach starting at 10,000 MT, with an annual decrease of 2,000 MT. 
Table 1: Proposed Regulatory Options for HCFC-22
                                    Option
                          Proposed Regulatory Option
                           HCFC-22 Allocations (MT)
                                       
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                       1
5-year linear approach with an allocation of 13,700 MT in 2015 and annual decreases of ~2,700 MT
                                                                        13,700 
                                                                         10,900
                                                                         8,200 
                                                                         5,500 
                                                                         2,700 
                                                                              0
                                      1b
5-year linear approach with an allocation of 10,000 MT in 2015and annual decreases of 2,000 MT
                                                                         10,000
                                                                          8,000
                                                                          6,000
                                                                          4,000
                                                                          2,000
                                                                              0
                                      1c
5-year linear approach with an  allocation of 16,700 MT in 2015 and annual decreases of 3,360 MT
                                                                         16,700
                                                                         13,340
                                                                          9,980
                                                                          6,620
                                                                          3,260
                                                                              0
                                       2
3-Year Linear Approach*
                                                                        12,400 
                                                                          8,300
                                                                         4,100 
                                                                           0   
                                                                            0  
                                                                           0   
                                       3
Estimation Approach
                                                                        23,100 
                                                                        20,900 
                                                                        15,100 
                                                                        11,500 
                                                                         6,200 
                                                                              0
*EPA also proposed a 3-Year Linear Approach starting at 15,000 MT in 2015.
Table 2 provides a summary of the proposed allocations for other HCFCs. For HCFC-142b, EPA is finalizing an allocation of 35 MT in 2015 with an annual decrease of 5 MT. For HCFC-123, EPA is finalizing its proposal to allocate 2,000 MT each year (which is 100 percent of the HCFC-123 consumption baseline). For HCFC-124, EPA is finalizing an allocation of 200 MT of production and consumption allowances each year. No allowances are being provided for HCFC-141b and HCFC-225ca/cb beyond 2014.
Table 2: Proposed Regulatory Options for Other HCFCs
                                     HCFC
                          Proposed Regulatory Option
                             HCFC Allocations (MT)
                                       
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                   HCFC-142b
35 MT in 2015, with an annual decrease of 5 MT
                                                                             35
                                                                             30
                                                                             25
                                                                             20
                                                                             15
                                                                              0
                                   HCFC-123
100% of baseline
                                                                          2,000
                                                                          2,000
                                                                          2,000
                                                                          2,000
                                                                          2,000
                                                                              ?
                                       
1900 MT in 2015 through 2017, declining to 1400 in 2018 and 2019
                                                                          1,900
                                                                          1,900
                                                                          1,900
                                                                          1,400
                                                                          1,400
                                                                              ?
                                   HCFC-124
200 MT per year
                                                                            200
                                                                            200
                                                                            200
                                                                            200
                                                                            200
                                                                              ?
                                   HCFC-141b
Remove petition process from regulations as of January 1, 2015
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                 HCFC-225ca/cb
Limited exemption to allow entities that have HCFC-225ca/cb in inventory prior to January 1, 2015 to continue to use HCFC-225ca/cb beyond that date.
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
The remainder of this report is organized as follows:
   * Section 2 presents the general approach and assumptions used, consistent with EPA guidelines.
   * Section 3 identifies the small entities potentially affected by the regulatory action for HCFC-22 and then estimates the economic impact on those affected entities.
   * Section 4 identifies the small entities potentially affected by the regulatory action for other HCFCs and then estimates the economic impact on those entities.
   * Section 5 addresses the potential small business impacts of other regulatory changes.
   * Section 6 summarizes the aggregate small business impacts of the rulemaking.
   * The Appendix provides a summary of HCFC allocations by entity and year.
2. Summary of General Approach and Key Analytical Assumptions
Table 3 shows the analytical steps and approach taken to prepare the screening analysis.
Table 3: General Steps and Approach for Small Business Impact Analyses
Step
Approach
Identify the companies that are expected to be directly impacted by each regulatory option
EPA regulations at 40 CFR 82.15(a) and (b) prohibit the production and import of HCFCs for which EPA has apportioned baseline allowances without calendar-year (or "annual") allowances. As a result, in the absence of a final 2015-2019 rule, production and import of HCFC-22 and HCFC-142b, as well as HCFC-123, HCFC-124 and HCFC-225ca/cb would be prohibited in 2015 and beyond. 

By allocating allowances for 2015 through 2019 to specific companies, this rulemaking directly impacts those allowance holders named in the rule. Other entities may experience indirect effects as a result of market changes influenced by the rule, but these are not to be considered in this analysis. See Cement Kiln Recycling Coalition v. EPA, 255 F.3d 855, 869 (D.C. Cir. 2001) (the D.C. Circuit "has consistently rejected the contention that the RFA applies to small businesses indirectly affected by the regulation of other entities."). 
Determine what proportion of allowance holders are small businesses
A North American Industry Classification System (NAICS) code was identified for each HCFC allowance holder identified in the proposed rule and at 40 CFR 82.17 and 82.19. Available economic data about each allowance holder (i.e., number of employees, annual sales) was obtained from the Dun and Bradstreet databases. Dun and Bradstreet is a public company that collects and licenses information on over 200 million businesses and corporations worldwide.
Of the allowance holders, small businesses were identified using the U.S. Small Business Administration's table of small business size standards matched to NAICS codes (table effective as of July 22, 2013). The small business threshold was defined by the number of employees in the company and varied between 100 and 1,000 employees.
For the purpose of quantifying the economic impact of the regulation, make assumptions about alternative refrigerants produced and imported in the absence of the proposed rulemaking
For the purposes of quantifying economic impact, this analysis has made some choices regarding which HCFC alternatives are imported and produced in the absence of the HCFC allowances allocated under the 2015-2019 rulemaking. These choices are not intended to imply expectations about the individual business decisions of allowance holders, or to represent the full range of available alternatives. For the purpose of this analysis, the selected alternative is a proxy for the set of alternatives that could be used, based on projections of the most common alternatives to existing HCFCs from EPA's Vintaging Model. The analysis assumes that alternatives are produced and imported in the same volumes as the HCFCs they would replace.
Quantify the economic impact on small businesses
This rulemaking authorizes allowance holders to voluntarily continue producing and importing HCFCs. As such, there are few direct costs of compliance. The proposed regulation does not change reporting requirements; however, production and import of HCFCs -- as authorized by this proposed rulemaking -- triggers HCFC reporting and recordkeeping requirements in 40 CFR part 82, subpart A.  These reporting costs are included in this screening analysis. 
No incremental capital costs are assumed to be incurred in order to comply with the 2015-2019 rule; this rulemaking allows allowance holders to continue to produce and import HCFCs after 2014. 
By authorizing allowance holders to continue producing and importing HCFCs, this rulemaking also provides some economic benefit to those allowance holders given the relatively higher selling price of HCFCs versus alternatives (see Table 4). This benefit is estimated by multiplying the sales price differential between the HCFC and the proxy alternative by the HCFC allocation proposed for each allowance holder.

All costs and savings values are expressed in constant year 2013 U.S. dollars. Because all costs and savings are experienced on an annual basis, no discounting was needed to present annual costs for the purposes of this screening analysis.

Table 4 shows the average sales prices of HCFCs and non-HCFC alternatives. As noted above, the selection of alternatives was based on projections of the most common alternatives to these HCFCs from EPA's Vintaging Model. Prices were based on publicly available information from refrigerant distributors, as well as information provided through industry inquiries.
Table 4: HCFCs, Alternatives, and Average Sales Prices ($/kg)
                                     HCFC
                               Sale Price ($/kg)
                                  Alternative
                               Sale Price ($/kg)
                            Price Difference ($/kg)
                                    HCFC-22
                                    $14.30
                                    R-410A
                                     $4.40
                                     $9.90
                                   HCFC-123
                                    $27.20
                                   HFC-134a
                                    $17.30
                                     $9.90
                                   HCFC-124
                                    $13.20
                                    R-404A
                                    $11.00
                                     $2.20
3. HCFC-22
For the purposes of this analysis, the economic impact of EPA's final allocation (Option 1b) of a five-year linear drawdown from 10,000 MT is singularly considered. 
   3.1. Small Entities Potentially Subject to the Rulemaking
Nine of the 19 HCFC-22 consumption allowance holders are classified as small businesses, based on the size standards associated with the NAICS code for each company (see Table 5). None of the HCFC-22 production allowance holders are classified as small businesses.
Table 5: HCFC-22 Consumption Allowance Holders Impacted By the Proposed Regulations
                                    Company
                                     NAICS
                          NAICS Industry Description
                              Number of Employees
                     Size Standards in Number of Employees
Altair Partners
                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                       4
                                      100
H.G. Refrigeration Supply
                                    423740
Refrigeration Equipment and Supplies Merchant Wholesalers
                                      10
                                      100

                                    423730
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers
                                       
                                       
Mexichem Fluor Inc.
                                    325998
All Other Miscellaneous Chemical Product and Preparation Manufacturing
                                      70
                                      500
Kivlan & Company
                                    423740
Refrigeration Equipment and Supplies Merchant Wholesalers
                                       3
                                      100

                                    423730
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers
                                       
                                       
Mondy Global
                                    423740
Refrigeration Equipment and Supplies Merchant Wholesalers
                                       4
                                      100
Reficentro
                                    423730
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers
                                      93
                                      100

                                    423740
Refrigeration Equipment and Supplies Merchant Wholesalers
                                       
                                       
R-Lines
                                    312111
Soft Drink Manufacturing  
                                       7
                                      500
Saez Distributors
                                    423730
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers
                                      30
                                      100
USA Refrigerants
No NAICS code, employee data, or sales data found. Other information suggests the company has fewer than 100 employees thus USA Refrigerants has been included in this analysis.
Company data obtained from Dun and Bradstreet (2013).
   3.2. Estimated Economic Impact on Affected Small Entities
This section summarizes the annual reporting costs for HCFC-22 small business allowance holders, as well as the economic benefit associated with the continued production and import of HCFCs. 
Reporting Costs
EPA monitors actual production and import of HCFCs through the recordkeeping and reporting requirements previously-established in the regulations in 40 CFR part 82, subpart A. Regulated entities are required to submit reporting forms in either paper or electronic format on a quarterly basis. These data are collected and maintained by EPA to help the agency oversee the total production and consumption of controlled substances and monitor compliance with limits and restrictions on production, imports, and trades.
Although the requirement to report is not is not a new requirement in the 2015-2019 rulemaking, entities must comply with 40 CFR part 82, subpart A to use allowances; thus EPA is accounting for this cost to estimate the economic impact of the proposed regulation. The costs differ depending on whether entities are submitting an electronic or paper report. In 2013, no small entities used the electronic reporting system; this analysis assumes that all small entities will be reporting using paper forms.
Information on the estimated burden of reporting is obtained from the EPA's 2012 Information Collection Request (ICR) for the Reporting and Recordkeeping Requirements of the HCFC Allowance System. The time required for an entity to submit one paper report is estimated at 4.5 hours based on consultations from industry. Operations and maintenance (O&M) costs are estimated at $5.00 for each report; these costs include photocopying, packaging, and postage. Table 6 summarizes the annual costs to comply with 40 CFR part 82, subpart A, which is approximately $1,970 per year.
Table 6: Compliance Costs for Small Entities Submitting Paper Forms

                                     Hours
                           Number of Activities/Year
                                  Hours/Year
                                Labor ($/Year)
                               O&M ($/Year)
                           Total ($/Year/Respondent)
Paper Submission
                                                                            4.5
                                                                              4
                                                                             18
                                                                     $1,949.72 
                                                                         $20.00
                                                                      $1,969.72
Impact on Sales
This rulemaking authorizes small business allowance holders to continue importing HCFCs in quantities equal to or less than their allowance allocation in a given year (see Appendix). In the absence of the rulemaking, it is assumed that importers and distributors would transition to an alternative refrigerant and sell similar volumes as HCFC-22. For the purpose of this analysis, it is assumed that entities would transition to R-410A in lieu of HCFC-22, and that the cost to the importer of purchasing and importing the chemical is approximately the same, regardless of whether it is an HCFC or HFC. Therefore, the economic impact is equal to the sales price differential between HCFC-22 and R-410A (see Table 4), multiplied by each allowance holder's HCFC allocation. The compliance costs associated with HCFC import are accounted for in Table 10, which shows the net economic benefit of the 2015-2019 HCFC allocations. Because HCFC-22 currently sells for a higher price than R-410A, the economic impact is a benefit, as shown in Table 7. 
Table 7: Estimated Economic Benefit of HCFC-22 Allowance Allocation (Thousand $)
                                    Company
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
Altair Partners
                                                                         $209.3
                                                                         $167.4
                                                                         $125.6
                                                                          $83.7
                                                                          $41.9
H.G. Refrigeration Supply
                                                                          $27.8
                                                                          $22.2
                                                                          $16.7
                                                                          $11.1
                                                                           $5.6
Mexichem Fluor Inc.
                                                                       $1,764.6
                                                                       $1,411.7
                                                                       $1,058.8
                                                                         $705.8
                                                                         $352.9
Kivlan & Company
                                                                       $1,442.1
                                                                       $1,153.7
                                                                         $865.3
                                                                         $576.9
                                                                         $288.4
Mondy Global
                                                                         $195.3
                                                                         $156.2
                                                                         $117.2
                                                                          $78.1
                                                                          $39.1
Reficentro
                                                                          $31.9
                                                                          $25.5
                                                                          $19.1
                                                                          $12.7
                                                                           $6.4
R-Lines
                                                                          $43.8
                                                                          $35.0
                                                                          $26.3
                                                                          $17.5
                                                                           $8.8
Saez Distributors
                                                                          $26.3
                                                                          $21.0
                                                                          $15.8
                                                                          $10.5
                                                                           $5.3
USA Refrigerants
                                                                          $10.3
                                                                           $8.2
                                                                           $6.2
                                                                           $4.1
                                                                           $2.1
4. Other HCFCs
This analysis also considers the final allocation options selected for HCFC-123 and HCFC-124. Specifically, this analysis assess the economic impact of allocating 200 MT of HCFC-124 consumption and production allowances, and 2,000 MT of HCFC-123 consumption allowances.
   4.1. Small Entities Potentially Subject to the Rule Making
Based on the small business size standards associated with the NAICS codes, there are three small businesses impacted by the 2015-2019 rulemaking for other HCFCs (see Table 8). Perfect Technology Center has allocations for HCFC-123, ICOR for HCFC-124, and Tulstar Products for both. There are no small businesses with HCFC-142b baseline allowances. 
Table 8: Other HCFC Small Business Allowance Holders
                                    Company
                                     NAICS
                          NAICS Industry Description
                              Number of Employees
                     Size Standards in Number of Employees
Perfect Technology Center, LP
                                    333249
Other Industrial Machinery Manufacturing
                                      40
                                      500

                                    334512
Automatic Environmental Control Manufacturing for Residential, Commercial and Appliance Use
                                       
                                       
Tulstar Products
                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                      16
                                      100
ICOR
                                    325199
All Other Basic Organic Chemical Manufacturing
                                      16
                                     1,000
Company data obtained from Dun and Bradstreet (2013).
   4.2. Estimated Economic Impact on Affected Small Entities
This section summarizes the annual reporting costs for the HCFC allowance holders identified in Table 8 and the economic benefit associated with the continued production and import of HCFCs. 
Compliance Costs
The reporting requirements for HCFC-123 and HCFC-124 allowance holders are the same as for HCFC-22. This analysis assumes that small entities are reporting quarterly using a paper form with the same time, wage, and O&M costs as outlined in Table 6. Tulstar Product is the only small entity with allowances for two HCFCs (-123 and -124); this analysis assumes that the reporting cost for two HCFCs is the same as for one HCFC.
Impact on Sales
Similar to the approach described for HCFC-22, this analysis assesses the impact of the regulation on sales of each HCFC by estimating the sales expected with and without the 2015-2019 rulemaking. See the Appendix for allowances allocated to each small business. For the purpose of this analysis, it is assumed that entities would transition to HFC-134a in lieu of HCFC-123, and to R-404A instead of HCFC-124, and that the cost to the importer of purchasing and importing the chemical is approximately the same, regardless of whether it is an HCFC or HFC. Therefore, the economic impact is equal to the sales price differential between the HCFC and the alternative (see Table 4), multiplying by the HCFC allocation proposed for each allowance holder. Because HCFC-123 and -124 currently sell for a higher price than HFC-134a and R-404A, respectively, the economic impact is a benefit, as shown in Table 9.
Table 9: Estimated Economic Impact of Allowance Allocation (Thousand $)
                                    Company
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
Perfect Technology Center, LP
                                                                          $90.1
                                                                          $90.1
                                                                          $90.1
                                                                          $90.1
                                                                          $90.1
Tulstar Products
                                                                        $386.44
                                                                        $386.44
                                                                        $386.44
                                                                        $386.44
                                                                        $386.44
ICOR
                                                                         $14.83
                                                                         $14.83
                                                                         $14.83
                                                                         $14.83
                                                                         $14.83
5. Other Regulatory Changes
EPA is also allowing for continued use of HCFC-123 as a fire suppression agent through 2019, allowing for a de minimis exemption from the CAA section 605(a) use prohibition taking effect in 2015, and making changes to the section 608 reporting requirements for reclaimers. For more specific information on these parts of the final rule, please see the preamble in the Federal Register (also available at docket ID: EPA-HQ-OAR-2013-0263).
605(a) Use Exemption for HCFC-123 Fire Suppression Applications
EPA is finalizing its proposal to align its regulations with the recent amendment to CAA section 605(a) and allow for continued use of HCFC-123 in nonresidential streaming fire suppression applications. EPA has not considered the economic impact further because this exemption is relieving a regulatory burden that would prohibit production and import of HCFC-123 for use in new non-residential streaming fire suppression products.
De Minimis Exemption
EPA is finalizing its proposed de minimis exemption allowing any person with HCFC-225ca/cb in inventory prior to January 1, 2015, to use that material as a solvent. EPA is also finalizing a de minimis exemption allowing any person with HCFC-124 in inventory prior to January 1, 2015, to use that material as a sterilant for biological indicators. EPA has not considered the economic impact further because this exemption is relieving a regulatory burden that would have required entities to destroy or render their existing inventory of HCFCs "used" before the prohibition on use as a sterilant or as a solvent takes effect.
Reporting Requirements for Reclaimers
EPA is finalizing its proposal (1) to require a reclaimer to notify EPA when there is a change in business management, location, or contact information and (2) to require disaggregated information for all reclaimed refrigerants as part of annual reporting to EPA. The agency is not finalizing its proposed incorporation by reference of AHRI 700-2012 at this time due to the ongoing review of the standard by ASHRAE and AHRI. 
EPA believes that notification of changes in business information would improve accountability and benefit reclaimers in the long run. Without accurate information, EPA may not be able to communicate with a reclaimer in a timely manner. Additionally, as a benefit to the public, the agency wants to ensure that its website listing certified reclaimers and their contact information is accurate. With regards to requiring refrigerant reclamation data, EPA believes this change will clarify what information it needs from reclaimers up front, and will alleviate the need for additional back-and-forth between EPA and reclamation companies that in the past were not submitting refrigerant-specific data.
 
These minor changes do not increase burden and may in fact lessen burden on small reclamation businesses by ensuring that businesses that have already reported do not have to spend additional time responding to follow-up requests from EPA. These changes also ensure that EPA can reach businesses in a timely manner with any necessary information and that reclaimer contact information provided to the public on EPA's website is accurate. As such, EPA does not consider there to be any additional cost to small businesses and the broader regulated community.
6. Conclusion
EPA's Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act (2006) recommends performing a sales test -- which calculates annual compliance costs as a percentage of annual sales -- and then comparing the results of that sales test to a decision matrix to determine whether to certify no significant economic impact on a substantial number of small entities (SISNOSE). A decision matrix typically defines threshold levels for the economic impact (e.g., net costs are less than 1% for all affected small entities). Based on the screening analysis presented in Sections 3 and 4 above, however, the proposed rulemaking is expected to have a net economic benefit to the small businesses that are directly affected (allowance holders). These net benefits are shown in Table 10 below for each impacted small business. 
Thus, this screening analysis suggests that the 2015-2019 rulemaking could be presumed to have no SISNOSE because it is expected to result in a net benefit to directly affected small businesses. 
Table 10: Summary of Net Economic Benefit of the Proposed Allocations, By Company (Thousand $)
                                    Company
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
Altair Partners
                                                                       $207.32 
                                                                       $165.47 
                                                                       $123.61 
                                                                        $81.75 
                                                                        $39.89 
H.G. Refrigeration Supply
                                                                        $25.80 
                                                                        $20.24 
                                                                        $14.69 
                                                                         $9.14 
                                                                         $3.58 
Mexichem Fluor Inc.
                                                                     $1,762.62 
                                                                     $1,409.70 
                                                                     $1,056.78 
                                                                       $703.87 
                                                                       $350.95 
Kivlan & Company
                                                                     $1,440.18 
                                                                     $1,151.75 
                                                                       $863.32 
                                                                       $574.89 
                                                                       $286.46 
Mondy Global
                                                                       $193.33 
                                                                       $154.27 
                                                                       $115.21 
                                                                        $76.15 
                                                                        $37.09 
Reficentro
                                                                        $29.89 
                                                                        $23.52 
                                                                        $17.15 
                                                                        $10.78 
                                                                         $4.40 
R-Lines
                                                                        $41.81 
                                                                        $33.05 
                                                                        $24.30 
                                                                        $15.54 
                                                                         $6.79 
Saez Distributors
                                                                        $24.32 
                                                                        $19.06 
                                                                        $13.80 
                                                                         $8.55 
                                                                         $3.29 
USA Refrigerants
                                                                         $8.33 
                                                                         $6.27 
                                                                         $4.21 
                                                                         $2.15 
                                                                         $0.09 
Perfect Technology Center, LP
                                                                         $88.12
                                                                         $88.12
                                                                         $88.12
                                                                         $88.12
                                                                         $88.12
Tulstar Products
                                                                        $384.47
                                                                        $384.47
                                                                        $384.47
                                                                        $384.47
                                                                        $384.47
ICOR
                                                                         $12.86
                                                                         $12.86
                                                                         $12.86
                                                                         $12.86
                                                                         $12.86
Appendix: HCFC Allocations

Table 11: HCFC-22 Allocations, by Small Business (MT)
                                    Company
                             Baseline Allocation 
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
Altair Partners
                                                                       302.011 
                                                                         21.14 
                                                                         16.91 
                                                                         12.68 
                                                                          8.46 
                                                                          4.23 
H.G. Refrigeration Supply
                                                                        40.068 
                                                                          2.80 
                                                                          2.24 
                                                                          1.68 
                                                                          1.12 
                                                                          0.56 
Mexichem Fluor Inc.
                                                                     2,546.305 
                                                                        178.24 
                                                                        142.59 
                                                                        106.94 
                                                                         71.30 
                                                                         35.65 
Kivlan & Company
                                                                     2,081.018 
                                                                        145.67 
                                                                        116.54 
                                                                         87.40 
                                                                         58.27 
                                                                         29.13 
Mondy Global
                                                                       281.824 
                                                                         19.73 
                                                                         15.78 
                                                                         11.84 
                                                                          7.89 
                                                                          3.95 
Reficentro
                                                                        45.979 
                                                                          3.22 
                                                                          2.57 
                                                                          1.93 
                                                                          1.29 
                                                                          0.64 
R-Lines
                                                                        63.172 
                                                                          4.42 
                                                                          3.54 
                                                                          2.65 
                                                                          1.77 
                                                                          0.88 
Saez Distributors
                                                                        37.936 
                                                                          2.66 
                                                                          2.12 
                                                                          1.59 
                                                                          1.06 
                                                                          0.53 
USA Refrigerants
                                                                        14.865 
                                                                          1.04 
                                                                          0.83 
                                                                          0.62 
                                                                          0.42 
                                                                          0.21 

Table 12: HCFC-123 Allocations, by Small Business (MT)
                                    Company
                             Baseline Allocation 
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
Perfect Technology Center, LP
                                                                         9.100 
                                                                          9.1  
                                                                           9.1 
                                                                           9.1 
                                                                           9.1 
                                                                           9.1 
Tulstar Products
                                                                        34.800 
                                                                          34.8 
                                                                          34.8 
                                                                          34.8 
                                                                          34.8 
                                                                          34.8 

Table 13: HCFC-124 Allocations, by Small Business (MT)
                                    Company
                             Baseline Allocation 
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
ICOR
                                                                         81.220
                                                                           6.74
                                                                           6.74
                                                                           6.74
                                                                           6.74
                                                                           6.74
Tulstar Products
                                                                       229.582 
                                                                         19.06 
                                                                         19.06 
                                                                         19.06 
                                                                         19.06 
                                                                         19.06 

