OZONE PROTECTION ISSUES THAT NEED URGENT ATTENTION

• Current control schedules for HCFCs and methyl bromide production and consumption, in both industrialized and developing countries, fail to protect the ozone layer at the rate which is environmentally warranted and is technologically feasible. Failure to require early substantial reductions in the use Rapid Ozone Destroying Substances (RODS), such as HCFCs and methyl bromide, risks delaying or slowing the decline in stratospheric chlorine/bromine loading once the peak occurs. An emergency phase-out schedule for these substances is absolutely necessary. In addition, the Protocol must avoid loopholes and exemptions to established controls in all categories of ODSs. An emergency phase-out schedule for HCFCs and methyl bromide is technologically feasible, as safe alternatives to both of these ODSs are available for most applications.

• ODS use in developing countries remains in the 200kt/year range, far above the levels that would allow for rapid reductions in chlorine/bromine loading. This consumption has increased an alarming 45% during the past decade. Consequently, a significant number of Article 5 countries may not meet the 1999 CFC freeze, which may then reverse current trends, and lead to a net increase in global ODS consumption. The 2010 CFC phase-out date for developing countries needs to be moved forward at least to 2006, but preferably closer to the turn of the century, to provide greater incentives for these countries to scale down consumption.

• The resources available to the Multilateral Fund should be at least doubled in order to facilitate the earliest possible phase-out of ODSs in Article 5 countries. These funds should be secured in the form of an 'eco-tax' levied upon the producers of ozone depleting substances, calculated as a percentage of their total ODP-tonnage production over the years.

• The Multilateral Fund continues to fund projects utilizing ozone destroying HCFC technologies, contrary to the decision of the Parties calling on members to limit the use of HCFCs to applications where environmentally safer alternatives do not exist.
  The Parties need to issue a clear directive to the Executive Committee of the Multilateral Fund to: (a) show preferential consideration in funding to CFC replacement technologies that contribute neither to ozone depletion nor global warming; and (b) encourage projects that have been approved for transitional (HCFC) substances, but have not yet been implemented, to switch to zero-ODP and zero-global warming technologies wherever possible.

• Inadequate funding for the Multilateral Fund, withholding of committed funds to the Fund on the part of Article 2 countries, and delays in disbursements and implementation by Implementing Agencies mean that the peak period of chlorine/bromine loading could be extended several years.

• The unreliability and inaccuracy of some of the data that is fed into the computers of the Ozone Secretariat and the Fund Secretariat regarding national consumption and production levels of ODSs, may mean that the actual global ODS production and consumption levels may be substantially greater than is presently acknowledged. The inadequacy of the data may also be compounded by administrative difficulties in the processing of the reported information. Out-of-date or inaccurate data undermines the ability of the advisory technical committees and the Parties to draft and implement appropriate policies for the protection of the ozone layer. Adequate funding must be made available to the Ozone Secretariat to ensure that all the necessary data is gathered and processed in a reliable manner.

• The continued release of halons from existing equipment is leading to a growth in atmospheric concentrations of this very potent ozone depleting substance.¹³

• Non-compliance is a problem in some regions (e.g. Russian Federation) and the releases of ODS are significant in terms of the recovery of stratospheric chlorine levels.

• Illegal trade in CFCs: The delayed phase out of CFCs in Article 5 countries, the non-compliance status of some industrialized countries, and differential pricing and taxation schedules (e.g. between Canada and the United States) foster the lucrative illegal trade and consumption of CFCs, which further endangers the ozone layer and undermines the objectives of the Montreal Protocol.

• The world wide recapturing and safe destruction of ODSs in existing equipment requires detailed attention and further resources. Preventing the venting of such banked ODSs is one of the few steps that is available to us to limit greater damage to the ozone layer.

• By encouraging the wide-scale use of HFCs (especially HFC-134a) as CFC replacements, when environmentally safer alternatives exist, the Montreal Protocol is exacerbating the threat of global warming and climate change. Rising CO₂ levels and other atmospheric changes are likely to enhance the ozone depletion effect of stratospheric chlorine and bromine levels. The Parties must no longer turn a blind eye to the global warming contributions of ODS replacement technologies, such as HFC-134a.

• Severe technological problems associated with HFC-134a, especially in the area of servicing of domestic refrigerators in Article 5 countries, may well convince companies to remain with, or even switch-back to CFCs. This would have negative ramifications for the ozone layer, as well as for further technology transfers between Article 2 and Article 5 countries.

¹³ SORG 1996 notes that: "The continuing growth of the Halons contrasts markedly with the behaviour of other ozone depleting substances controlled by the Montreal Protocol process, such as CFCs, whose concentrations have shown signs of levelling off and decay." (SORG 1996 p.17). [return]