TL: FULL OF HOLES - THE MONTREAL PROTOCOL AND THE CONTINUING DESTRUCTION OF THE OZONE LAYER SO: GREENPEACE INTERNATIONAL, with contributions from OZONE ACTION, (GP) DT: 1997 INTRODUCTION The Parties to this Convention, DETERMINED to protect human health and the environment against adverse effects resulting from the modifications of the ozone layer Have agreed as follows... -Vienna Convention for the Protection of the Ozone Layer, 1985 With these words, countries of the world took an historic step. Ozone depletion had been recognized as the world's first truly global environmental problem. As such, the preservation of the ozone layer - and the life on earth that depends on it- would require the unprecedented cooperation of nations for their common good. Self interest, and self preservation were redefined as synonymous with global interests, and nations of the world were forced to see themselves more clearly than ever before as a common community. Ten years later much progress has been made, but the final outcome is still unclear. In 1987 the largely toothless Vienna Convention became the Montreal Protocol, which has served as the mechanism to encourage and enforce global phaseout of ozone depleting substances. Amended several times since 1987, the Protocol has been widely hailed as the solution to the ozone crisis. On the paper of the Montreal Protocol, the world is safe. BACKGROUND "If creditable scientific data...show that any chlorofluorocarbons cannot be used with a threat to health, Du Pont will stop production of these compounds" - Du Pont testimony before US Congress, 1974 When chemists Sherwood Rowland and Mario Molina first postulated a link between chlorofluorocarbons and ozone layer depletion in 1974, the news was greeted with scepticism, but taken seriously nonetheless. The vast majority of credible scientists have since confirmed this hypothesis. The ozone layer around the Earth shields us all from harmful ultraviolet radiation from the sun. Without the ozone layer, life on earth would not exist. Exposure to increased levels of ultraviolet radiation can cause cataracts, skin cancer, and immune system suppression in humans as well as innumerable effects on other living systems. This is why Rowland's and Molina's theory was taken so seriously, so quickly - the stakes are literally the continuation of life on earth. One of the most pressing questions before the scientific community was how bad will it get, and how fast will it happen? In an attempt to answer this, various different models - all much more complex than any previous attempts - were developed. From 1974 to 1983 these models predicted anywhere from 19% ozone depletion (50 years down the line) to a loss of only 3% of the ozone shield [Benedick, Richard, Ozone Diplomacy, Harvard University Press, 1991, p.13]]. None of these models predicted the appearance of the Antarctic ozone hole, which was first reported by British scientists in 1985. Although the forces behind its annual creation are more fully understood now, the hole's initial detection came as quite a shock in 1985. Scientists had already acknowledged ozone depletion as a real threat, but it was generally assumed that it would come on gradually. This complacency generated policies to gradually phase out global use of ozone depleting chemicals. The emergence of the ozone hole proved that our understanding of atmospheric science is less than perfect - yet the policies remained generally unchanged. More importantly though, the appearance of the hole showed that changes could be non-linear, and sudden. This fact should be placed firmly in the minds of negotiators at the Protocol as they set policy under a gradually thinning global ozone layer. The unexpected, and at the time, unexplained, appearance of the hole is the best argument possible for the need for the precautionary principle to govern environmental policy. Briefly stated, the precautionary principle suggests that policy makers accept the notion that our scientific understanding of our ecosystem is incomplete, and prescribes policies which take this into account by seeking to avoid environmental harm. Perceived short-term economic costs should be viewed as secondary, given the enormous potential costs associated with environmental disaster - in this case, widespread ozone depletion. The Montreal Protocol is not an example of the precautionary principle at work. Rather, the Protocol continues to be based on a premise of environmental management, or a balancing of economics and ecology based on best available science. This is the fatal flaw in the Protocol. Negotiators at the Protocol, armed with the latest (but always imperfect) scientific data, manage the ozone layer at the margins. While it may be possible to phase out chemicals faster and more completely, such steps are often deemed too expensive. These decisions are justified on the basis of science, which may, or as in the case of the appearance of the hole, may not be correct. As a later section in this report shows, even that science concedes that a certain level of impacts will come to pass. This environmental management practice is called risk-assessment. In short, this risk assessment attempts to weigh the economic costs of banning ozone depleting chemicals outright vs. the human and environmental "costs" (deaths, cancers, extinctions) of additional damage to the ozone layer. When negotiators in Vienna in late 1995 decide whether or not to ban all CFCs immediately or by 2010, they are deciding whether or not an additional amount of ultraviolet radiation will be allowed to strike the Earth, and whether or not an additional number of deaths from skin cancer are acceptable costs of perceived economic needs. The stakes involved in these discussions are quite literally life and death. Risk assessment has been widely criticized for giving governments the power to decide how many deaths are acceptable, how many illnesses are bearable, how many extinctions are manageable. The major reason that the Protocol incorporates this philosophy is the pervasive influence of the chemical industry at all levels of the Protocol. It is often assumed that the appearance of the Antarctic ozone hole was the impetus behind the crafting of the Protocol in 1987. In fact, Antarctica was never discussed at the negotiations. Rather, it was industry's late endorsement of the Protocol (led by Du Pont) that paved the way for the global agreement. Corporate capitulation on their stance that CFC substitutes were still years away provided a framework of possibility for governments to point to in crafting the Protocol. This industry defined framework is the foundation of the Protocol today. At every level of the Protocol, industry representatives exert a tremendous influence. For instance, the World Bank, which is responsible for the majority of the funds given by the North to help the South phase out of ozone depleting substances, relies heavily on chemical industry experts for technical expertise. As a result, decisions regarding alternatives to CFCs have been skewed towards other environmentally damaging technologies, although pressure from environmental groups has begun to change this in the last year. More subtly, while industry representatives sing the praises of the Protocol and its processes, they have been hard at work in developing countries to ensure their market share - sometimes of the very chemicals they have agreed to phase out. As an industrial trade agreement, meant to ensure markets for Northern chemical companies, the Protocol has indeed been a success. The language of the Protocol guarantees that Northern chemical companies will be allowed to continue producing CFCs for at least 10 more years. In addition, as the markets for CFCs shrink around the world, chemical company alternatives (e.g. HCFCs and HFCs) are being entrenched despite the fact that other, more environmentally friendly, and more economic options exist. If one understands the objective of the Protocol as phasing out consumption of CFCs in the North, then, to some extent, it can be viewed as a success. However, this narrow interpretation is skewed. The health of the ozone layer, and the global use of ozone depleting substances, is the issue. The Protocol sanctions continued use of ozone depleting substances, funds the adoption of new ozone depleting technologies, and creates new environmental problems. Good for industry, maybe. Good for the environment? Certainly not. "Under the current CFC phaseout schedules, global UV levels are predicted to peak around the turn of the century...The recovery to pre-ozone depletion levels is expected to take place gradually over the next 50 years" - UNEP Scientific Assessment, 1994, p.iv In practice though, the ozone layer and the planet are still in grave danger. The truth is that the Montreal Protocol, as it is currently constructed, will not save the ozone layer. The success of the Protocol depends, as this paper shows, on a series of assumptions, or "IFS", that are questionable at best, and demonstratably unrealistic at worst. Briefly stated, the Montreal Protocol has saved the ozone layer; * IF production of ozone destroying substances stops (it has not) * IF Northern countries keep their promises (they're not) * IF Southern countries operate in good faith (they're not) * IF the North doesn't dump obsolete, polluting technology in the South (they are) * IF the scientific predictions are right (they rarely have been) * IF scientific sceptics don't undermine the Protocol (they are trying) * IF we don't mind additional impacts from exposure to ultraviolet radiation (we do) Far from being a "model international environmental agreement", the Montreal Protocol is in danger of failing in the only way that matters - the future health of the ozone layer. If any one of the above assumptions proves incorrect the effects on the environment and society will be enormous. IF THE PRODUCTION OF OZONE DEPLETING SUBSTANCES STOPS (IT HAS NOT) One would think that the Montreal Protocol ensures that the production and use of ozone depleting substances will stop. It doesn't. Chemical companies will, for the most part, phase out sales of CFCs in the north this year, but they will continue to be produced for export for another 10 years. CFCs will likely not be phased out in the South until 2010, their use is increasing, and production will not even be capped for several more years. HCFCs, which are potent ozone destroyers in the short term, are increasing in usage globally, are not set to be phased out in the North until 2030, and may never be phased out in the South. Methyl bromide, a potent ozone destroyer used as a pesticide and fumigant, is virtually unregulated by the Protocol (although various national regulations cover it and there is a cap on developed nation consumption). For all of these chemicals, safer alternatives exist, and yet their continued production and use remains sanctioned by the Parties to the Montreal Protocol. CFCs As of January 1, 1996, it will be illegal for developed nations to produce or import virgin CFCs, except for "essential" and "feedstock" uses and production for export to the South. Additionally, for every 100 tonnes of CFCs destroyed by US companies, they may in turn produce 85 tonnes of new CFCs in 1996. In addition, large amounts of recycled and recovered CFCs will continue to be available, although at inflated prices. In 1996, 151,811 tonnes of new CFCs can be produced, legally in the north for export to developing countries. This production loophole was inserted into the Protocol mostly at the urging of developing nations, which were concerned about the availability of CFCs after the North's phaseout. Provisions for continued legal production were added to the Montreal Protocol five years ago, when industry was still maintaining that CFC replacement was going to be a difficult proposition. Experts now agree that the continued access to CFCs by developing countries is hindering the switch to safer alternatives. Nevertheless, developing countries will continue to consume CFCs, and that consumption is expected to rise in the next several years. Continued consumption of CFCs by the developing world is one of the most important issues that will be discussed this year in the Montreal Protocol. Early indications are that Parties will most likely agree to do nothing, and to keep the phaseout date for the South at the year 2010. Other options on the table at the moment would actually weaken current phaseout schedules. This is despite the fact that a recent study of available options concluded that a 2001 phaseout would be cheaper overall to fund, and would speed the recovery of the ozone layer by approximately 8%. (Study on the Financial Mechanism of the Montreal Protocol, March 1995, COWIconsult) HCFCs Currently, controls exist on the production of HCFCs in developed countries only. These chemicals are recognized as "transitional substances" rather than permanent replacements, precisely because of their potential to deplete the ozone layer. The current phaseout schedule (which some nations have accelerated domestically) will freeze HCFC production at a specified "cap" level in 1996, and allows for gradual reductions until 2020 when 99.5% of production must stop, with a final phaseout in 2030. Despite efforts by some European nations to accelerate the global phaseout of HCFCs, the United States, Japan and France in particular, continue to resist additional controls. This split is an industrial, not an environmental one. In Europe, most manufacturers have switched almost entirely away from HCFCs in favor of environmentally safer alternatives. The US, Japan, and France, in contrast, continue to rely heavily on sales of these ozone depleters, and so act to ensure their continued market availability and protect their investments. Methyl Bromide Methyl bromide, a pesticide and fumigant, is the only ozone depleting chemical that is virtually unregulated by the Montreal Protocol. Methyl bromide use has been almost completely eliminated in the Netherlands, and other countries are following suit, as it becomes clear that alternatives are available or in an advanced state of development for about 90% of all uses. According to the United Nations Environment Programme, a rapid phaseout of methyl bromide is the most significant short term step that countries can take to protect the ozone layer. Formalization of a global ban is currently in jeopardy at the Protocol negotiations because of unfounded economic concerns fostered by an industry propaganda campaign initiated by methyl bromide producers in the US and Israel. The United States, which had initially supported a progressive position, is now backpedaling as the Clinton administration has realized that Florida and California (two very important states in the upcoming election) are the two states that will be affected the most by a methyl bromide phaseout. Developing countries generally oppose controls on methyl bromide because of unfounded concerns regarding the costs of alternatives. IF NORTHERN COUNTRIES KEEP THEIR PROMISES (THEY'RE NOT) "A gradual recovery is predicted, but the layer will be damaged for half a century to come. These predictions were made...on the basis of a fairly optimistic scenario, including the assumptions that there will be full and worldwide compliance with the Copenhagen amendments [to the Montreal Protocol]." - UNEP Science Assessment, p.i Saving the ozone layer is not a game in which there are winners and losers. Either everybody wins, or we all lose. Recognizing this, and recalling that ozone depleting chemicals were developed in the industrialized North, the Protocol incorporates a system to aid developing countries in their phase out of ozone depleting substances. The Multilateral Fund, established in 1990, is this system. While in theory the system should work, in practice it is proving very difficult. One of the obvious assumptions underlying the faith in ozone layer recovery is that countries will live up to their committments. In many key respects, they are not. For the Protocol to work as it is designed (much less as it should), several key things must happen. First, industrialized countries of the North have to phase out their use of these chemicals. Not all of them are. Second, those same Northern countries have to pay (via the Multilateral Fund) for Southern countries' phase out. Not all of them are. Third, there has to be no substantial black market production of CFCs from either Northern or Southern countries. There is. Northern countries are simply not living up to their end of the bargain. In short, there isn't enough money, or even as much money as the North had promised. Currently, the North is over $50 million in arrears to the Fund, which of course has the effect of slowing down CFC phase out in the South. Italy, the worst example, has simply not paid anything yet. Canada is also significantly in debt to the Fund. In many other cases, differring accounting practices between governments complicate reliable projections. In at least one case (the US), politicians are threatening to pull funding entirely. The cumulative effect undermines confidence in the South that the Fund will work. This lack of faith threatens to unravel the entire agreement with developing countries wary of committing themselves to further action. At the last meeting of the Protocol in August of 1995, the meeting completely broke down over these issues and was simply adjourned, rather than closed. A significant problem, both for funding and phase-out in the North, is the economic chaos in parts of Eastern Europe and the former soviet union. These economies in transition are in a difficult position to either convert their economies away from ozone depleting chemicals or pay into the Fund - measures agreed before the dissolution of their planned economies. Many have suggested that they now simply be reclassified as developing countries under the Protocol, but of course that would both increase the amount of money needed and additionally increase the amount of damage to the ozone layer. Most production is concentrated in Russia which is widely recognized to be a major source of the growing trade in black market CFCS. The emerging black market in CFCS is pointed to by industry and governments as the most significant problem in compliance with the Montreal Protocol. The US government has mobilized Operation "Cool Breeze", which involves the US Federal Bureau of Investigations (FBI), the Environmental Protection Agency (EPA), the Customs Service, the Central Intelligence Agency (CIA) and Interpol. While the estimated 10,000 to 20,000 US tons per year entering the US alone are certainly a major, if predictable, problem with Protocol compliance, this trade pales in comparison to "legal" production by US multinationals. One wonders whether the real concern here is ozone layer protection, or market share. IF SOUTHERN COUNTRIES OPERATE IN GOOD FAITH (THEY'RE NOT) If Northern countries can be fairly accused of viewing the Protocol as a market creation and preservation device for their industries, Southern countries can be similarly accused of behaving as if the Protocol were a developmental, rather than an environmental agreement. Nowhere is this clearer than in the ongoing discussion on "basic domestic needs". "The real issue is this;" said the representative of one large developing country, "do you want CFCS produced in the North by large chemical companies, or produced in the South by our own industries". Under the terms of the Protocol, a country in the South "shall, in order to meet its basic domestic needs, be entitled to delay for ten years its compliance with the control measures..."[Article 5, 1] Since only a handful of developing countries (including China, India, and Brazil) actually have the capacity to produce, this is a fight over who gets that remaining market share. No matter what one may think of the relative merits of Southern vs. Northern industry, the Protocol is quite clear that Southern production for export is not allowed. Southern governments which seek a re-opening of this question need to find a way to articulate their arguments in environmental terms. If, for instance, these governments argued that keeping production in the South would allow them to phase out CFCS faster, and to bypass HCFC substitutes, negotiation might ensue. At the moment, though, these governments' arguments simply appear to be attempts to bolster their own industry. At the same time, Northern arguments for maintaining the status quo both bolster their industry and appear to favor the environment. The North argues that it is in their industry's economic interests to phase out CFCS as soon as possible, so that they can continue to create markets for HCFCs and HFCs. Many observers feel less than confident on this point, but at least it makes an environmental argument - albeit one that rests on the premise that HCFCs and HFCs are acceptable substitutes to CFCS. In truth, neither North or South need to be producing more CFCS, as existing stockpiles and readily available replacement technology are more than sufficient to meet economic demands. Another area in which some Southern countries are violating at least the spirit of the Montreal Protocol is by increasing production. When the Fund was set up and the South joined the Protocol it was recognized that equity issues dictated that the South be allowed to continue to develop and expand its use and production of ozone depleting chemicals. However, no one foresaw the zeal with which developing countries would seek to expand this capacity, and of course, the increasing bills this would give to Northern governments for an eventual phaseout. India, for example, has actually said that unless the North compensates it for not building new CFC plants, it will go ahead and build them. While technically this is their right under the Protocol it hardly adds to the spirit of international cooperation for governments to behave this way. Finally, Southern countries are failing to provide accurate and reliable data to negotiators at the Protocol regarding the amount of ozone depleting substances that their countries consume. The lack of this data makes it virtually impossible to accurately forecast future needs for phaseout, or impacts of delays in that phaseout. IF THE NORTH DOESN'T DUMP OBSOLETE, POLLUTING TECHNOLOGY IN THE SOUTH (THEY ARE) "Maybe some time next century there will be better answers than HCFCs and HFCs" - Mike Harris, ICI (currently a World Bank Montreal Protocol advisor) When the chemical industry endorsed the Montreal Protocol they thought they had a no lose situation. As CFCS were phased out, HCFCs and HFCs would be phased in. With the help of the Protocol's Fund, the industry was eagerly anticipating moving into new markets in Southern countries. Rather than paying for the problems they caused, these polluters faced the prospect of profiting from their damage to the ozone layer. Environmental groups were both relieved and alarmed. Relieved that CFCS would be phased out (although they haven't yet been), but alarmed because of the fact that neither HCFCs nor HFCs are even close to being environmentally benign. It should have surprised no one that chlorine based industries came up with chlorine based alternatives. Almost immediately, a search for "not in-kind alternatives" (NIKAs) began. For some applications, such as aerosols and electronics cleaning, environmentally benign alternatives were readily available. In refrigeration and foam blowing though (the two sectors with the most growth potential in the developing world) HCFCs and HFCs seemed to dominate the market. In March of 1993, as the first "Greenfreeze" - a hydrocarbon based refrigerator - was produced in Germany, all that changed. Isobutane and cyclopentane, two readily available hydrocarbon products, are now clearly established as NIKA technologies for refrigeration and foam blowing, respectively. They are the standard technology in Europe today, and have gained worldwide market share. Despite this, it took years for the Protocol's implementing agencies (the World Bank, the United Nations Development Programme, and the United Nations Industrial Development Organization) to recognize this shift and begin to fund these technologies. The Bank and UNDP in particular, continue to rely on chemical company "experts" for advice on their technology choices. Last year, the Executive Committee of the Fund noted "a presumption against HCFC projects" and yet this year UNDP has continued to submit HCFC projects - without adequate justification or estimates of the cost of a second conversion away from HCFCs. Both steps are now supposedly required in order for HCFC projects to be approved. At the Fund's July meeting, these requirements were conveniently overlooked. The Protocol uses public money meant for environmental protection to phase out CFC use. The fact that the majority of this money has gone towards other environmentally damaging technologies is a scandal, and a clear violation of the spirit, if not the letter of the Protocol. IF THE SCIENTIFIC PREDICTIONS ARE RIGHT (THEY RARELY HAVE BEEN) Even if we assume that production of ozone depleting substances will stop, and that all countries will be in full compliance, the claims that the ozone layer will recover are based on scientific understanding of our atmosphere that, while improved from ten years ago, is still far from perfect. Science has consistently under, rather than over-estimated the speed and severity of ozone depletion. Clearly this history points to the need for policy to err on the side of caution. Reassuringly though, there is no single area of global ecological science that is as clearly established as the connection between industrial chemicals and ozone depletion. In 1994, NASA scientists announced the results of a major study that conclusively proved the connection between ozone loss and CFCS - once again confirming Rowland's and Molina's hypothesis. What is still debated among credible scientists is at what levels depletion will bottom out and when we will reach them. According to United Nations Environment Programme projections, (upon which negotiators depend in the Montreal Protocol) the ozone layer will fully recover by the middle of the next century, and ozone depletion is expected to reach its peak around the year 1998. As mentioned before, those projections are based on full compliance. UNEP projections are also based on the best available science, and on the assumption that there will be no positive feedbacks, or nasty surprises, that could accelerate ozone depletion. Several trends are disturbing in this regard. For the past three years, ozone depletion has outstripped the predicted rate of ozone loss. At first, in 1993, scientists noted that "the decline over much of the United States, Europe, and Asia may only be a transitory effect from the eruption of the Mt. Pinatubo volcano...If that is the case ozone levels should return to more normal levels in a year or two..."[New York Times, 4/23/93] The next year, UNEP reported that as the aerosols from Pinatubo had been swept out of the air, ozone levels had returned to levels consistent with the models. However this year, the US National Oceanic and Atmospheric Administration (NOAA) and the World Meteorological Organization both reported "unusually low ozone levels", up to 35 percent depletion in some areas. In addition, this year a new and unexplained depletion happened over the southern hemisphere in the summer, which runs completely counter to model predictions. Ozone depletion is only one of the global ecological crises facing Earth's atmosphere today. The other is climate change, caused by global warming. Scientific opinion is now clear that human activity is linked to the global warming of the atmosphere. (New York Times, 9/10/95) We know that greenhouse gases trap heat, and we know that the concentrations of these gases are rising in our atmosphere. The debate now is over how severe and where the impacts will be - an experiment on a global scale. Disturbingly, several models have predicted that as climate change accelerates, it could also exacerbate ozone depletion. Ironically, HFCs, a major replacement chemical for CFCS, are also potent global warming gases. Clearly something else is going on in the stratosphere. The Pinatubo aerosols are gone. However, we still are not able to fully and accurately predict the behavior of the ozone layer. Until we can (and that point may be decades away) we must err on the side of caution in designing policies to protect the atmosphere. IF SCIENTIFIC SCEPTICS DON'T UNDERMINE THE PROTOCOL (THEY ARE TRYING) Particularly since 1990, industry scientists, "wise use" organizers, politicians and the media have begun to cast doubt on the science of ozone depletion. These attacks range from denying that chlorine (from CFCS, HCFCs and other chemicals) and bromine (from methyl bromide and halons) cause ozone depletion, to asserting that ozone depletion has not resulted in increased levels of UV-B striking the earth. Most worrying is the ongoing attempt by methyl bromide producers to wreck negotiations on a phase out of the chemical. Despite agreement by international scientists that methyl bromide is one of the most dangerous ozone destroying chemicals in use and that the ozone layer will never recover unless it is banned, companies are staging drawn out debates over minor scientific uncertainties in order to delay action. Meanwhile, methyl bromide emissions are on the increase. According to the sceptics' arguments, we just don't have enough science yet to justify the policy steps outlined by the Montreal Protocol. Imagine, however, if one applied this logic to the public health arena--governments would not promote safe sex because it's only a theory that HIV causes AIDS. These scientific sceptics pose a grave threat to continued developed country contributions to the Multilateral Fund, particularly in the US. Recently, US contributions to the Fund have been threatened by the 104th Congress. During the House Appropriations process, several key Republican Members of Congress threatened to attach a rider to the Environmental Protection's Agency budget which would have stripped all funding to the Multilateral Fund. As well, several Senators led by the Chair of the Foreign Relations Committee Jesse Helms (R-NC) also attempted to end US funding for the Fund. If these efforts succeed, developing countries will almost certainly walk out of the Protocol. National legislation is under similar attacks. Despite near worldwide agreement on the upcoming ban on CFCS in 1996, Congressman Doolittle (Republican-California), aided by Representative Delay (Republican-Texas), has proposed legislation to repeal the ban. This action by the US Congress comes on the heels of legislation recently signed into law in the state of Arizona which vows to defy the domestic and global ban on CFCS in 1996. Although state law is superseded by both the Clean Air Act and the Montreal Protocol, this legislative move offers evidence of both the sway of the sceptics and the potential threat of Doolittle's legislation in the current political climate. The fact that such backlash is occurring in the US, which was the world's largest consumer of ozone depleting chemicals and is the central country in the Protocol negotiations, gives these domestic issues international importance. IF WE DON'T MIND ADDITIONAL IMPACTS FROM EXPOSURE TO ULTRAVIOLET RADIATION (WE DO) Let's assume that the Protocol will overcome its many shortcomings, and that sometime in the middle of the next century the ozone layer will fully recover. Even with this assumption, we are still facing years of increasing impacts from exposure to ultraviolet radiation. There is a direct correlation between increases in the amount of industrial chlorine and bromine in the atmosphere, increases in stratospheric ozone depletion, increases in the amount of UV-B radiation reaching the earth and increased damage to human health and other life forms . Given this equation, one wonders why the Parties to the Protocol continue to sanction the production of ozone depleting chemicals. These alarming impacts are highlighted in numerous reports, including the 1994 UNEP Assessment of the Environmental Effects of Ozone Depletion". They include: * Skin cancer rate on the rise: Between 1979 and 1993, the incidence of non-melanoma, the most common form of skin cancer, is already believed to have risen an average of 10% in the Northern Hemisphere, between the latitudes 55N and 35N. Even larger increases are believed to have occurred in the Southern Hemisphere. UNEP forecasts that a sustained 1% decrease in stratospheric ozone will result in a 2% increase of this type of skin cancer. In 1994, UNEP confirmed that increases in UV-B radiation are likely to increase "the incidence and morbidity from skin cancer" and that "epidemiological data indicate that the risk of melanoma increases with sunlight exposure, especially during childhood." (1994 Science, Environmental Effects and Technology and Economic Assessments, Synthesis Report/ page 13) * Human immune system at risk: Exposure to UV-B is now known to lower the effectiveness of the human immune system. There is mounting evidence that UV-B has the ability to activate latent viruses such as papilloma viruses, herpes, and perhaps HIV. UNEP suggests that UV-B exposure might adversely influence immunity to infectious diseases, such as leishmaniasis, and malaria.. UV-B exposure also may reduce immunization rates, exacerbate photosensitivity disease such as lupus, and cause medication reactions in individuals taking the birth control pill and certain antidepressants and antibiotics. [Dr. K.D. Cooper, University of Michigan at Ann Arbor] As well, excessive UV-B radiation can trigger herpes simplex virus infections of the oral cavity (UNEP, Environmental Effects of Ozone Depletion, 1991] * Increased incidence of eye cataracts: In November, 1991 UNEP projected that the effects of increased UV-B radiation will result in substantial increases in cataract (the clouding of the eyes lens) cases and blindness worldwide. Latest finding indicate that each 1% decrease in ozone levels leads to 0.6% to 0.8% increase in cataracts. The World Health Organization estimates that a 10 percent reduction in the ozone layer will result in two million new cases of cataracts per year. * Fish stock at risk: 16% ozone depletion could result in 5% loss in phytoplankton (the basis of all food in the seas), which would lead to a loss of about 7 million tonnes of fish per year -about 7% of fishery yield. Under the Antarctic ozone hole productivity from phytoplankton was down by 6-12%. * Damage to plants: UV-B radiation can alter plant form, damage tree and plant growth, change the time of flowering, make plants more vulnerable to disease and cause them to produce toxic substances. There may well be losses of biodiversity and plant species, but our ignorance of the effects of UV-B on ecosystems as a whole is far too great to allow figures to be put on these losses. * Air pollution: With loss of ozone in the upper atmosphere, it is expected that UV-B radiation will cause ground-level ozone to increase in urban and suburban areas, reaching potentially harmful concentrations earlier in the day. Scientific research into the impact of increased UV-B radiation upon the biosphere is tragically under funded. The UNEP Scientific Committee On Problems of the Environment (SCOPE) forewords its 1993 report "Effects of Increased Ultraviolet Radiation on Global Ecosystems" with the following forthright admonition: "The fact that the number of experts on the effects of increased UV-B impacts on living systems due to ozone depletion continues to be rather small, illustrates that for the past 20 years, the governments of the world seemed not to take seriously this potential threat to the biosphere. Candidly stated, research funding for "effects" research has been paltry at best." CONCLUSION Atmospheric chlorine loading has steadily risen from 1.5 ppb in 1970 to 2.5 ppb in 1980 to 3.6 ppb today. (1991 & 1994 Synthesis Report). If all the assumptions underlying the Protocol turn out to be valid ones, it is expected that chlorine loading will peak at 3.8 parts per billion around the turn of the century. If one or all of these assumptions are wrong, ozone depletion will get much worse, for much longer. The logical goal should be to reverse this trend as quickly as possible and to allow the ozone layer to restore itself to pre- industrial levels. Unfortunately, the Montreal Protocol does not seem aimed at this goal. The shortest route to reducing the atmospheric levels of chlorine and bromine, hence reducing the amount of ozone depletion and the risk of adverse health and environmental impacts from ultraviolet radiation is the immediate elimination of the production and use of ozone destroying compounds. And yet, the majority of the proposals currently on the table at the Montreal Protocol would actually extend global use of ozone depleting chemicals. It is the moral obligation of governments to protect the public, and the environment, from undue harm. Clearly, it is their responsibility to help speed up the recovery of the ozone layer if they have the means to do so--which they do. We now have the know-how to replace all ozone depleting substances with environmentally safer technologies. All we are lacking is the political will.