As regular visitors to this blog will be aware, as part of our Global Environment Campaign, EIA has been fighting an ongoing battle against the illegal trade in ozone depleting substances for many years now.
An unfortunate – yet avoidable – consequence of the global phase out of first CFCs, and now HCFCs, black market trade in ODS has the potential to wreak havoc on the ozone layer. It is the Achilles heel of the Montreal Protocol – the most successful environmental treaty to date – and as such, requires urgent and decisive action.
Our illegal trade investigations have taken us to many far-flung destinations over the years. Few, however as far-flung as Mongolia, a name, which for me at least, had always been endowed with a certain mystique.
However, when it comes to tackling ozone depletion, no country is too remote, which is how, a couple of weeks ago, EIA came to co-host the Summit with the Private Sector on Trade in Ozone Depleting Substances with the United Nations Environment Programme (UNEP) in Ulaanbaatar.
It seemed fitting that an ozone summit should take place in Mongolia, Land of the Blue Sky, where rather than being an abstraction, the “environment” is central to the country’s national identity. Sandwiched between Russia and China, Mongolia has been subject to a range of foreign influences (as the euphemism goes) over the years – and indeed conquered vast tracts of Central Asia and Europe itself back in the heyday of Genghis Khan.
Now an independent and fully fledged democracy, Mongolia has been behind some novel initiatives in recent years, including the convening of a Cabinet Meeting on Climate Change, which was held in the Gobi Desert in December 2010. Although a sparsely populated country, deforestation, overgrazing and the depletion of water resources are leading to the expansion of the Gobi at a rapid rate of knots, imperilling the livelihoods of the herders, who still make up around a third of the population. Air pollution is also a huge problem in cities, where coal and wood-burning stoves are used by a majority of the population for heating and cooking. In addition to this, plentiful supplies of raw materials including coal, copper, tungsten, phosphates, nickel, zinc, fluorspar, gold and silver make it an Eldorado for mining companies.
While Mongolia has no domestic production of ozone depleting substances to speak of, its customs officials are well versed in the challenges posed by illegal trade in ODS – as were the many other national officials present at the Summit, hailing from as far afield as Thailand, Malaysia, China and Indonesia. Along with representatives from multinational chemical manufacturers, and international organisations including UNIDO and the World Customs Organisation (WCO), they spent three days discussing how to avert a massive spike in illegal ODS trade as developed and developing countries implement their HCFC phase out – whose differential nature (developed countries are on schedule for a total phase-out by 2020, developing countries have until 2030) only increases the risks of part of the market going underground. The resulting “UB 2.0 Declaration” lists concrete actions to help stamp out illegal trade and will be available online shortly. EIA and UNEP will also be bringing out a Risk Assessment of Illegal Trade in HCFCs within the next few weeks – watch this space for details on both of those.
As mentioned above, illegal trade has been a problem for as long as initiatives to rid the planet of ozone depleting chemicals have existed. At one point, a staggering 20% of trade in CFCs was estimated to be illegal. That’s a sobering figure, but what’s even more sobering is the realisation that with the HCFC phase-out, the problem could turn out to be considerably worse. This is mainly because of the comparatively more rapid pre-baseline increase in developing countries’ consumption of HCFCs, which is currently growing at 15% per annum.
In the past few years, we’ve seen increasing incidences of HCFC smuggling related to the developed country phase out, including high-profile seizures in Florida and evidence of criminal activity in Southern Europe, where it is estimated that up to 10 small ships a day are ferrying small consignments of HCFCs between ports bordering the EU where trade controls are not in place, and ports within the EU where import of virgin HCFC is banned.
Not to paint too bleak a picture, there are some great initiatives out there to help stem the flood of illegal ODS trade. One of these – the eccentrically-named “Project Sky Hole Patching II” – deserves a special mention. Originally an initiative of a group of Asia Pacific countries, it led to a total of 26 seizures, amounting to 640 tonnes of ODS and over 600 pieces of equipment containing ODS, over a 6-month period in 2010. Improved cooperation between customs authorities, notably through the “informal prior and informed consent” – or iPIC – system has also proved its worth over the years. However, even ground-breaking initiatives such as these look paltry in the face of a potential tidal wave of illegal ODS trade as the HCFC phase out begins to take hold. It’s time to face up to the fact that illegal trade exists and that we need to do something about it. Fast.
Global Environment Campaigner