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From April 6 to 15, parties to the Montreal Protocol will discuss limits on the production and use of HCFCs, chemicals which are supposed to be transitional substances to replace CFCs, but which will needlessly deepen and extend damage to the ozone layer. Civil servants are using a measure known as "Ozone Depletion Potential" (ODP) which may underestimate the short and medium term impacts of HCFCs. The UK Government's own scientists describe the ODP of HCFCs as "quite unreliable" in this respect.[1]
Because HCFCs release their chlorine much more quickly than CFCs, they will have their most serious impact within the next few decades, at the time when the ozone layer faces its maximum exposure to chlorine pollution from CFCs already in the air. This will increase the amount of ultraviolet light penetrating the ozone layer during the period of maximum risk.
The UK Government's own Stratospheric Ozone Review Group (SORG) scientists have rejected ODPs as a way of assessing the risks to the ozone layer in the short to medium term.[2] Instead, they recommend using "chlorine loading potentials," which are not based mainly on models of long term chemicals as ODPs are, but on more straightforward calculations and observations of how much pollution actually gets into the lower and upper atmosphere in the short to medium term.[3]
If chlorine loading potentials were used, HCFCs would be seen to be significantly more damaging than ODPs make them appear. Consequently their use would need to be curtailed, not allowed to grow to substitute for CFCs.
The ozone depletion potential of HCFC 22 calculated over 200 to 500 years is 5% of that of CFC 11. But, the chlorine loading potential of HCFC 22 is 15.2% of CFC 11 - greater than that of methyl chloroform (11.4%), which is a recognised major ozone- depleter.[4]
In 1990, SORG stated that "the use of ODP is limited by the failure of models to predict ozone depletion correctly and by the fact that it refers to steady state conditions which precludes predictions of changes over the next few decades."[5]
A year later, the 1991 SORG report reinforced the point. It observed that "although ODPs purport to give a true basis for comparison between halocarbons, the models of atmospheric chemistry by which they are calculated cannot reproduce measured ozone depletions. Furthermore, ODPs are calculated with reference to CFC 11 (a long lived compound) and are seriously misleading when applied to short lived compounds in the short term. For example, the relative impact, in terms of chlorine loading of an emissions of HCFC 141b after ten years would be over half that of a similar emission of CFC 11, yet its steady state ODP is only 8%.[6]
This suggests that for some HCFCs, ODPs underestimate the destructive potential by six times or more.
The 1991 SORG report also stated: "the ozone depletion potentials (ODPs) of HCFCs are quite unreliable as guides to the short term impact of these substances on the ozone layer and chlorine loading is the most relevant parameter for examining the effects of controls on halocarbon emissions." Chlorine loading is expected to rise and peak over the next few years.[7] This will create a period of magnum risk of ozone depletion resulting in a period of maximum increase in W-B penetration.
EC Environment Commissioner, Carlo Ripa Di Meana, stated in February: "HCFCs also contain chlorine and can therefore destroy ozone. They have approximately only 5% of the ozone depletion potential of CFCs. Nevertheless, it is of paramount importance that HCFCs are controlled under the Montreal Protocol and that the system of control is complied with globally. To this end, I will propose to the Commission that a quantitative limit -- to be known as a cap --- should be placed on the amount of transitional substances consumed globally. The exact level of a cap will still have to be discussed in the framework of our consultations with industry, but I see the figure of 5% of a total ozone- depleting potential as only a starting point and would feel happier with a lower figure."[8]
Clearly, the Commissioner seems to believe that because HCFCs shave approximately only 5% of the ozone depletion potential of CFCs" the target "figure of 5% of a total ozone depleting potential" will mean that the damage that could be done to the ozone layer by use of HCFCs will be 5% of that otherwise done by the CFCs which they could replace. But this is likely to be wrong.
The UK Department of Trade and Industry's September 1991 publication Protecting the Ozone Layer: Action for Business, also makes this mistake and states under the heading "HCFCs (Transitional Substances)" that "HCFCs (such as 22) . . . have ozone depletion potential -- typically one twentieth that of CFCs 11 and 12."
So, even a straight substitution of HCFCs for CFCs would cause more damage than politicians seem to think. But they also intend to allow growth in HCFC production and use.
A February 1992 Coopers and Lybrand study for the UK Department of Trade and Industry forecasts a growth in demand for HCFCs of more than 10% a year. The study states that "suppliers anticipate growth at up to 10% per annum to 1996 with a decline after 2006". This implies that demand could double.
It adds, "manufacturers of newer products dependent on HCFCs anticipate slower growth. However, these expectations do not take full account of the demand for servicing equipment. We believe that demand for HCFCs could grow at more than 10% per annum, unless potential users are further deterred."[9]
The UK Government has made no statement on HCFC use but clearly foresees the production and consequent release of substantial quantities. In February, a Department of the Environment civil servant foresaw "necessary investment in HCFCs" taking place within a period of continued use long enough to allow a reasonable payback.[10]
There are no official UK Government figures for HCFC production or use, but ICI presently has production capacity for 30,000 tonnes of HCFC 22 a year at its plant in Runcorn, Cheshire.[11]
ICI describes HCFCs and HFCs as "meeting societal needs" and "protecting the environment." ICI claims that HCFCs and HFCs offer an option for safe, timely, cost-effective solutions to the ozone depletion and global warming concerns presented by CFCs.[12] Yet, this is clearly wrong. HCFCs are a significant threat to the ozone layer, while ICI's product HFC 134a, with which the company is keen to capture a significant part of the former CFC market, is a greenhouse gas 3,200 times stronger than carbon dioxide.[13]
The main concern of companies producing CFCs and HCFCs may in fact be to deny markets to truly alternative systems which may not offer the same profit but which will do the job.
In reality, HCFCs are not essential substances for society, only for HCFCs manufacturers and commercial users who want to avoid investing in new, less harmful equipment. The Coopers reports states that "there are no current or potential applications of HCFCs in the sectors examined for which no other technically feasible alternatives exist or are likely to be available in the short to medium term."[14]
Greenpeace believes that in permitting significant production and use of HCFCs, governments are about to make a mistake which will consign the ozone layer to deeper and longer-lasting damage than politicians realize. Consequently, they will needlessly extend and intensify the period of greatest risk from raised levels of ultraviolet radiation. Civil servants and governments are misleading themselves and the public because of their misuse of ODP to asses the damage that HCFCs will cause to the ozone layer.
The real policy question which governments should be adding is how to minimize the risk to people, agriculture and nature in this maximum risk period. But they are not asking that question, and if they think they are, they are using the wrong tools to do the job. They are also ignoring real alternatives to CFCs and other ozone depleting chemicals already on the market or close to it.
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