I wish all readers a healthy and happy new year. Let’s get to a very specific item that may impact every one of us in 2025.
President-elect Trump has proposed former New York congressman Lee Zeldin to head the Environmental Protection Agency (EPA). While in Congress, Zeldin had a lifetime League of Conservation Voters score of just 14%. According to the LCV, he voted against the Inflation Reduction Act, against cracking down on Big Oil price gouging, against clean water and clean air protections, and against the EPA’s own methane pollution safeguards (https://x.com/LCVoters/status/1856072834558124461). (He also voted against certifying the 2020 election.)
On Aug. 17, 2023, the America First Policy Institute announced Zeldin as the chair of its “Pathway to 2025”initiative (“AFPI Welcomes Lee Zeldin to Pathway to 2025 Initiative,” https://americafirstpolicy.com/issues/afpi-welcomes-lee-zeldin-to-pathway-to-2025-initiative); and on Sept. 27, 2024, Zeldin was additionally named as the chair of AFPI’s China Policy Initiative (“AFPI Names New Chair of Its China Policy Initiative,” https://americafirstpolicy.com/issues/afpi-names-new-chair-of-its-china-policy-initiative).
The America First Policy Institute is a rival organization to the Heritage Foundation, and its “Pathway to 2025” has been termed “the other Project 2025.” Now, with Zeldin’s nomination, it is possible that Trump may somewhat favor AFPI’s presidential transition initiative over that of Heritage. As of 2023, AFPI had 172 employees, including eight former cabinet secretaries, from the previous Trump administration (“America First Policy Institute,” https://en.wikipedia.org/wiki/America_First_Policy_Institute). But let’s keep in mind that at least 140 people who worked in Trump’s first administration, including six former cabinet secretaries, have been involved with Project 2025 (“’The Other Project 2025′: The Lesser-Known Blueprint for Trump 2.0,” https://www.commondreams.org/news/america-first-policy-institute).
In nominating Zeldin on Nov. 11, Trump said, “[Zeldin] will ensure fair and swift deregulatory decisions that will be enacted in a way to unleash the power of American businesses” (“Trump picks former Rep. Lee Zeldin to be his EPA administrator,” https://www.npr.org/2024/11/11/nx-s1-5187039/trump-lee-zeldin-epa-environment).
Today, as we enter 2025, 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.
The Montreal Protocol has 197 signatories, making it the first United Nations treaty to be ratified by every country in the world.
The HFCs, 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 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. 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)
Now, with Trump’s re-election, our country’s commitment to preserving the environment and protecting public health may be at serious risk. Despite his “disavowal” of the Heritage Foundation’s Project 2025 and warmer embrace of the America First Policy Institute’s Pathway to 2025, Trump has nominated to his cabinet or other high-level posts at least seven people who had a role in the drafting of Project 2025 (“The Trump Administration Picks With Ties to Project 2025,” https://www.usnews.com/news/national-news/articles/2024-12-03/these-trump-administration-picks-have-ties-to-project-2025).
With specific regard to the phasing out of HFCs, Project 2025 says (page 425):
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 section subtitle 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” there.
The banning CFCs made a huge difference in the healing of the planet’s ozone hole, as can be clearly seen here:
Global agreement mitigated and reversed the damage – a positive example of what can happen if the new Trump–Zeldin regime doesn’t reverse the agreement on HFCs.
Let me add a relevant history lesson here. I recently presented a talk entitled “Climate and Infectious Disease: An Example from History” to the Climate Adaptation Center’s 4th Annual Florida Climate Conference. I discussed how the Plague of Justinian in the 6th-century Byzantine Empire was made worse by a climate shift at the time. Here’s a link to my address: “David R. Kotok discusses the ‘Plague of Justinian’ and how a change in Rome’s weather amplified it,” https://www.youtube.com/watch?v=Gza7aoLzxQk.
And a final personal note. I still have the scars from burns on the top of my ears that I got when I traveled to Patagonia, where the ozone layer was thin. One day I spent about 3 hours wearing a hat without flaps. My bad. Third-degree burns were the result. IMO, HFC elimination is critical to life and health, as was the elimination of CFCs.
We are about to enter 2025. There is risk, and what it is and how it impacts each of us remains to be seen.
