America has abandoned the “E” (environmental initiatives to mitigate effects of climate change) in ESG. The announcement by President Trump and EPA director Lee Zeldin is summarized here in three minutes:
“Trump revokes basis of US climate regulation, ends vehicle emission standards” | Reuters, https://www.reuters.com/legal/litigation/trump-administration-set-revoke-basis-us-climate-regulation-2026-02-12/
The February 18 edition of S&P Global’s letter “Sustainability Weekly” points out the wide-ranging ramifications of this change:
If the action survives court challenges, it would invalidate existing GHG reduction mandates for the US energy sector and oil producers. It would also make it harder for future administrations to regulate climate-warming emissions. The EPA also said it is rescinding all GHG reduction mandates for vehicles — the largest US source of climate-warming emissions.
(The Sustainability Weekly, February 18, 2026, S&P Global Energy Horizons. To subscribe, see https://spgi-mkto.spglobal.com/ESG-Insider-Newsletter-Subscribe.html?utm_source=marketo&utm_medium=email260218&utm_campaign=S1-EMC-2401-C-GL-CRTA-ESG+Insider+Newsletter)
The economic dislocations are huge, starting with borrowed federal money (remember, there’s a budget deficit) directed at updating coal power plants in four states. Auto emission standards will be reversed or eliminated. Renewable sources of energy were already under attack; that situation worsens. To exist going forward, renewables will compete for permitting against fossil fuel expansion. They face hostile economic forces that essentially slow or stop the wind/solar initiative. What happens to modular nuclear power plant construction is not clear.
I wrote about Zeldin on December 29, 2024, when he was first announced by Trump and before the Trump 2.0 inauguration. Here’s the link:
“Lee Zeldin, HFCs & The New Year”
https://kotokreport.com/lee-zeldin-hfcs-the-new-year/
My biggest fear now is that Trump 2.0, under the influence of Russell Vought and Lee Zeldin, will abrogate the Montreal Protocol established and signed by Republican President Ronald Reagan and reaffirmed many times, including by Trump 1.0.
The reason for my concern is outlined below. I have excerpted from the December 29, 2024, missive:
I want to focus again on hydrofluorocarbons (HFCs) as a specific example of what Zeldin’s deregulatory efforts could mean if they lead to the US backing out of global commitments.
I wrote about hydrofluorocarbons on Sept. 1, 2024, in “Climate Change, Markets, Economics – Part 2,” https://kotokreport.com/climate-change-markets-economics-part-2/. To briefly review, hydrofluorocarbons are the manmade substances that were introduced to replace chlorofluorocarbons (CFCs, also manmade) once the evidence of CFCs’ impact on the Earth’s ozone layer was widely accepted. The effort to phase out CFCs involved intense, protracted cooperation among global governments, leading to the Montreal Protocol, finalized in 1987.
The US ratified the Montreal Protocol in 1988 and then approved all five of the Protocol’s subsequent amendments. The US has been a leader in implementing the Protocol and has put in place strong domestic policies and programs to phase out ozone-depleting substances (ODS) such as CFCs and halons. The elimination of ODS is estimated to have prevented up to an additional 2.5°C temperature increase by the end of this century, while also protecting us all from harmful UV radiation. The EPA estimates that Americans born between 1890 and 2100 will avoid some 443 million cases of skin cancer, approximately 2.3 million skin cancer deaths, and more than 63 million cases of cataracts – and those are just the benefits within the US. (“The Montreal Protocol on Substances That Deplete the Ozone Layer,” https://www.state.gov/key-topics-office-of-environmental-quality-and-transboundary-issues/the-montreal-protocol-on-substances-that-deplete-the-ozone-layer/)
The mitigation of the ozone layer damage worked and has been reversed — so far…
The Montreal Protocol’s Scientific Assessment Panel estimates that with implementation of the Montreal Protocol we can expect near complete recovery of the ozone layer by the middle of the 21st century. I want to remind readers that this initiative occurred under Republican President Ronald Reagan’s Administration and has been reaffirmed many times by Democrats and Republicans of all political persuasions.
The Montreal Protocol has 197 signatories, making it the first United Nations treaty to be ratified by every country in the world.
HFCs, originally selected to replace the CFCs, don’t do further damage to the ozone layer. They do, however, create a lot of heat. In fact, the global warming potential of HFCs may be hundreds or even thousands of times greater than that of carbon dioxide (CO2) per unit of mass (“Powerful climate forcers with global warming potentials many times that of carbon dioxide,” https://www.ccacoalition.org/short-lived-climate-pollutants/hydrofluorocarbons-hfcs).
When this fact was recognized, the United States played a crucial leadership role in the development of the Kigali Amendment to the Montreal Protocol in 2016. Extensive US diplomacy in the years leading up to the amendment’s adoption created the international political support needed to reach a consensus to add phase-down obligations on HFCs to the Montreal Protocol. (“The Montreal Protocol on Substances That Deplete the Ozone Layer,” https://www.state.gov/key-topics-office-of-environmental-quality-and-transboundary-issues/the-montreal-protocol-on-substances-that-deplete-the-ozone-layer/)
The amendment, which entered into force on January 1, 2019, has been ratified by 163 countries (including the US, in 2022) and the European Union. President Trump affirmed it in his first term. Under the amendment, countries committed to cutting the production and consumption of HFCs by more than 80% over the next 30 years to avoid more than 70 billion metric tonnes of CO2 equivalent emissions by 2050. In July 2023, the EPA finalized a rule to reduce US HFC use 40% by 2028. (“Hydrofluorocarbons (HFCs),” https://www.ccacoalition.org/short-lived-climate-pollutants/hydrofluorocarbons-hfcs)
The following image from the Alliance for Responsible Atmospheric Policy offers an overview of the Montreal Protocol and its amendments. (We added the ratification of the Kigali Amendment by the US in 2022.)
Russell Vought used Project 2025 to call for repeal and abrogation of this protocol. Here’s the excerpt from the Project 2025 document, Mandate for Leadership: The Conservative Promise. On page 425, Project 2025 addresses HFCs:
Subtitle: Regulating Hydrofluorocarbons (HFCs) Under the American Innovation and Manufacturing (AIM) Act22
Repeal Biden Administration implementing regulations for the AIM Act that are unnecessarily stringent and costly.
Refrain from granting petitions from opportunistic manufacturers to add new restrictions that further skew the market toward costlier refrigerant and equipment.
Footnote 22 in the subsection above links to the Cornell Law School document that sets forth the actions the EPA is required by law to carry out under US Code Title 42 for the mitigation of HFCs (“42 U.S. Code § 7675 – American Innovation and Manufacturing,” https://www.law.cornell.edu/uscode/text/42/7675).
The banning of HFCs has worldwide support, as did the elimination of CFCs. So, any change in this specific policy is a clear litmus test of extremes. Remember, HFCs are totally a manmade substance; there is no “it’s nature” argument to be made.
EPA Administrator Lee Zeldin has not specifically announced abrogation of the Montreal Protocol and the Kigali Amendment. That is where the courts and the Congress will have a role. I expect lots of litigation about the entire policy shift. We know that is coming.
This is personal for me. I have scars from burns obtained on one of my visits to Patagonia when the ozone hole’s thinning was at its worst. I witnessed the effects firsthand. The abrogation of the Montreal Protocol and Kigali Amendment would be deadly, in my opinion.
Beyond concerns about whether policy will continue to enable the ozone layer to recover, we have just witnessed the three hottest years in human history, as Climate Adaptation Center CEO Bob Bunting explained to the audience at the CAC’s Annual Climate Champions Award Lunch on Wednesday, March 11, in Sarasota. The heat dome news about next week suggests that 2026 may be hotter and set a new record:
“A record heat dome is about to hit the West — in March” | Washington Post, https://www.washingtonpost.com/weather/2026/03/12/record-heat-west-drought-california-utah-arizona/
Note that this KR was prepared prior to the start of the Iran War, which is a major economic and geopolitical shock to many countries and to the worldwide fossil fuel industry. The Iran War doesn’t change the narrative about US policy: The Montreal Agreement and its amendments remain essential.
A reading list follows, documenting the effort it took President Ronald Reagan to get to the Montreal Protocol, as well as all that has happened since the 1980s with regard to the only worldwide treaty EVERY SINGLE COUNTRY has agreed upon.
Further Reading
“Montreal Protocol” | Britannica,
https://www.britannica.com/event/Montreal-ProtocolA documentary for a Sunday afternoon:
“Ozone Hole: How We Saved the Planet” | PBS,
https://www.pbs.org/show/ozone-hole-how-we-saved-planet/“Statement on Signing the Montreal Protocol on Ozone-Depleting Substances” | Ronald Reagan Presidential Library and Museum,
https://www.reaganlibrary.gov/archives/speech/statement-signing-montreal-protocol-ozone-depleting-substances“The Montreal Protocol on Substances That Deplete the Ozone Layer” | US Department of State,
https://www.state.gov/the-montreal-protocol-on-substances-that-deplete-the-ozone-layerCurrent and historical images of the ozone layer taken from space:
“NASA Ozone Watch” | NASA Goddard Space Flight Center,
https://ozonewatch.gsfc.nasa.gov/monthly/SH.html
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