Uncertain Shadows

The Montreal Protocol’s Legacy, HFO Risks, and New Zealand’s Role in a Global Climate Experiment

Mar 22, 2025

Triumphs and Tensions

As an independent researcher with a critical yet fair lens, I approach the Montreal Protocol and New Zealand’s climate and research direction with both admiration and caution. The Montreal Protocol, enacted in 1987, is often hailed as a pinnacle of global environmental cooperation, successfully phasing out ozone-depleting substances (ODS) like chlorofluorocarbons (CFCs). A 2023 *Nature* article celebrated this achievement, projecting the ozone hole’s recovery to pre-1980 levels by the 2060s (Nature, 2023; NASA, 2023). The 2016 Kigali Amendment extended this legacy by targeting hydrofluorocarbons (HFCs), ushering in hydrofluoroolefins (HFOs) as a low-global-warming-potential (GWP) alternative. Yet, beneath this triumph lies a complex web of emerging risks—HFOs’ environmental impacts, New Zealand’s dual role as a climate research hub and a vulnerable nation, and ethical questions surrounding technocratic governance, geoengineering, global climate finance, and local resource management strategies. This article critically examines these dynamics, exploring how local councils’ Resource Management Act (RMA) strategies, private sector climate financial disclosures, civil defense responses, and planned retreats intersect with these broader issues, while addressing recent changes in aerosol standards and a new *Nature* article from March 2025.

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The Montreal Protocol: Success with Caveats

The Montreal Protocol’s achievements are undeniable. By phasing out CFCs and hydrochlorofluorocarbons (HCFCs), it reduced ozone depletion, curbing UV-related health risks like skin cancer (UNEP, 2023). New Zealand, a developed nation, eliminated CFCs by 1996, adopting HFCs with zero ozone-depleting potential (ODP). The Kigali Amendment addressed HFCs’ high GWPs—e.g., HFC-134a’s GWP of 1,430 (IPCC, 2014)—introducing HFOs like HFO-1234yf (GWP < 1) as a climate-friendly substitute (UNEP, 2016).

However, this narrative of success warrants skepticism. A 2024 study exposed significant underreporting of HFC-23 emissions, a potent greenhouse gas (GWP 14,800), particularly in Eastern China (Stanley et al., 2024), revealing enforcement gaps in the Kigali Amendment. More critically, the shift to HFOs introduces new concerns. Their degradation produces trifluoroacetic acid (TFA), a persistent “forever chemical” that accumulates in water bodies, potentially threatening ecosystems and human health (Solomon et al., 2016). A recent *Nature* article from March 2025 highlights ongoing concerns about HFOs, noting that while they reduce direct climate impacts, their long-term atmospheric interactions remain understudied, potentially exacerbating indirect warming effects (Nature, 2025). While the protocol’s ozone-focused victories are commendable, these emerging issues suggest that celebrating its broader environmental success may be premature.

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HFOs: A Double-Edged Solution

HFOs were designed to mitigate HFCs’ climate impact, but their low GWP belies a more complex environmental footprint. Three key concerns emerge: their indirect contributions to global warming, the role of energetic electron precipitation (EEP) in amplifying these effects, and the persistence of TFA in water tables.

Indirect Climate Impacts

HFOs degrade into compounds like TFA, altering atmospheric chemistry. Research from New Zealand’s Deep South National Science Challenge in the Southern Ocean suggests that TFA can enhance cloud reflectivity, potentially cooling the planet (Revell et al., 2021). Yet, this effect is uncertain, and other feedbacks complicate the picture. TFA deposition into oceans may increase CO₂ uptake, exacerbating ocean acidification and indirectly contributing to global warming (Sanz-Lopez et al., 2023). The 2025 *Nature* article underscores these uncertainties, noting that HFOs’ interactions with atmospheric aerosols could influence regional climate patterns, potentially intensifying extreme weather events in vulnerable regions like New Zealand (Nature, 2025).

EEP and Atmospheric Dynamics

Energetic electron precipitation (EEP) events, studied through New Zealand’s AARDDVARK network, add another layer of complexity. EEP generates odd nitrogen (NOx) in the thermosphere and mesosphere, which descends to the stratosphere, destroying ozone through catalytic reactions (Seppälä et al., 2021). “Trimpi” perturbations in very low frequency (VLF) transmissions provide evidence of these impacts (Clilverd et al., 2021). HFOs’ interaction with EEP could amplify their climate effects, particularly in regions like New Zealand, where EEP research is active. For instance, NOx-driven ozone depletion may increase UV radiation, exacerbating environmental stress, while altered atmospheric dynamics could influence weather patterns, potentially intensifying events like Cyclone Gabrielle (Harrington et al., 2023). This intersection of HFOs and EEP underscores the need for integrated atmospheric modeling.

TFA in Water Tables

TFA’s high solubility and resistance to degradation make it a persistent pollutant (Solomon et al., 2016). Global studies have detected rising TFA levels in rainwater and drinking water since HFO adoption surged in the 2010s (Kazil et al., 2014). In New Zealand, where pristine water underpins its “100% Pure” brand, this is a significant risk. While current TFA concentrations are below harmful thresholds, their long-term accumulation could harm aquatic ecosystems and human health, with potential developmental toxicity (Neale et al., 2021). The absence of effective monitoring or removal technologies amplifies this threat, exposing a critical oversight in the HFO transition.

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New Zealand: Research Leader, Vulnerable Player

“New Zealand’s climate narrative intertwines its role as a research hub with its environmental vulnerabilities, offering a microcosm of global challenges.”

Climate Research Hub

Positioned in the Southern Hemisphere, New Zealand drives cutting-edge climate science. Initiatives like the Deep South and Sustainable Seas National Science Challenges explore Southern Ocean dynamics (Revell et al., 2021), while NIWA monitors atmospheric chemistry, including HFCs and HFOs (NIWA, 2023). The THORPEX-IPY project (Nordeng et al., 2007) and contributions to the UN Sendai Framework for Disaster Risk Reduction (SFDRR) cement its global stature (UNDRR, 2022). This research prowess positions New Zealand to influence HFO policies and explore geoengineering options like solar radiation management (SRM) (MacInnis-Ng et al., 2023). Satellites like, PREFIRE, and TROPICS, launched from Mahia Peninsula in 2023, hint at potential atmospheric modification experiments (Rocket Lab, 2023). Yet, this role also makes New Zealand a testing ground for unproven technologies, raising questions about unintended consequences.

“Black Swan” Risks

The Royal Society Te Apārangi warns of “Black Swan” events—unpredictable, high-impact incidents (MacInnis-Ng et al., 2023). Cyclone Gabrielle (February 2023), an “atmospheric river” event, devastated the North Island, highlighting New Zealand’s fragility (Harrington et al., 2023). Judith Lawrence, a lead author for the IPCC AR6 Working Group II, framed the cyclone as a “win” for Dynamic Adaptive Pathways Planning (DAPP), but its impacts—70 homes rendered unlivable and 400 damaged—reveal the nation’s exposure to environmental shocks, potentially worsened by HFO-related pollutants or geoengineering experiments. This vulnerability challenges the “pure” image central to its tourism-driven economy, especially in a post-COVID-19 world where recovery remains fragile.

##### Technocracy and Transparency

New Zealand’s climate policies increasingly reflect technocratic governance, with bodies like NIWA, the Deep South Challenge, and the Climate Change Action Technical Working Group (CCATWG) shaping decisions (Sustainable Seas, 2022). The Open Government Partnership (OGP), joined in 2014, promises transparency, but private forums—workshops, unrecorded meetings, and platforms like Discuto—dominate discourse, often evading public scrutiny (Sustainable Seas, 2022). The Pacific Science Academy’s opaque standard-setting in 2023 (Council.science, 2023) and Official Information Act (OIA) denials fuel skepticism, particularly as technologies like satellite synthetic aperture radar (SAR) and electromagnetic radiation (EMR) exposure raise health concerns (WCRC, 2023). Unproven rumors linking the ICECUBE neutrino telescope to the 2012 Christchurch earthquake further underscore the need for public oversight (WCRC, 2023). This lack of openness risks alienating communities, including Māori, who depend on natural resources.

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Local Councils, RMA Strategies, and Climate Adaptation

Local, regional, and municipal councils in New Zealand play a pivotal role in climate adaptation, guided by the Resource Management Act (RMA) of 1991, which has historically been the country’s core environmental and planning law. However, the RMA’s limitations in addressing climate change have led to significant legislative shifts. In August 2023, the Natural and Built Environment Act (NBA) and Spatial Planning Act (SPA) were enacted, replacing the RMA over a 10-year transition period (Library of Congress, 2023). These laws aim to streamline planning, reducing over 100 RMA planning documents to 16 regional plans, with standardized consent conditions and faster approval times for infrastructure projects. The NBA introduces a National Planning Framework (NPF) to set environmental limits and resolve conflicts, while emphasizing climate adaptation and hazard mitigation.

Councils face a “liability dilemma,” often sued for both action and inaction on climate risks, which has historically inhibited proactive measures (The Conversation, 2021). The RMA’s devolution of climate responsibilities to local government has also hindered national strategic planning, sacrificing productive land for urban development and failing to address growing climate risks. The 2024 Resource Management (Freshwater and Other Matters) Amendment Bill further adjusts RMA provisions, excluding the Te Mana o te Wai hierarchy from resource consent decisions until the National Policy Statement for Freshwater Management (NPS-FM) is updated, a move criticized by Māori groups like Te Ohu Kaimoana for undermining Treaty obligations (New Zealand Parliament, 2024). This shift prioritizes economic exploitation over environmental protection, raising concerns about water contamination and coastal degradation.

Planned Retreats and Civil Defense

The concept of “planned retreats” has gained traction as a climate adaptation strategy, particularly for coastal communities facing sea-level rise. The Climate Adaptation Bill, expected in late 2023, aims to establish mechanisms for managed retreat, including funding to support communities relocating from high-risk areas (Library of Congress, 2023). Private sector consultants like Tonkin + Taylor advocate for such strategies, emphasizing the need for long-term planning and inter-council collaboration (Tonkin + Taylor, 2024). However, the devolution of responsibility to local councils, combined with liability fears, has slowed implementation. Civil defense and hazard responders, critical to managing climate-related disasters, face challenges under the Severe Weather Emergency Legislation Act of March 2023, which amends the RMA to extend timelines for emergency consents but does little to address long-term retreat planning (Tonkin + Taylor, 2024). Water New Zealand, through initiatives like the 2023 Conference & Expo, highlights the need for resilient water infrastructure in retreat scenarios, yet funding and coordination remain barriers (Water New Zealand, 2023).

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#### Private Sector: Climate Financial Disclosure and Industry Impacts

The private sector in New Zealand is increasingly subject to climate financial disclosure requirements under the Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021. Climate Reporting Entities must disclose climate-related financial impacts, enhancing transparency and accountability (Tonkin + Taylor, 2024). This aligns with New Zealand’s five-point climate strategy (July 2024), which emphasizes private investment, nature-based solutions, and competitive markets. However, industries like agriculture, forestry, and tourism—key to New Zealand’s economy—face significant risks. Agriculture, accounting for over half of emissions, is exempt from the Emissions Trading Scheme (ETS) to maintain competitiveness, but a $400 million investment aims to reduce on-farm emissions (Tonkin + Taylor, 2024). Dairy and tourism sectors risk market access as global preferences shift toward low-emission products, challenging New Zealand’s “environmentally friendly” reputation.

Private consultants like Tonkin + Taylor, in their 2025 sustainability predictions, stress the need for innovative solutions balancing resilience and economic viability (Tonkin + Taylor, 2021). Yet, short-term political cycles and inconsistent council approaches complicate long-term planning, leaving industries vulnerable to climate impacts and regulatory shifts.

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Aerosol Standards: A Recent Shift

New Zealand recently adjusted its aerosol standards under the Resource Management (Freshwater and Other Matters) Amendment Bill, passed in 2024. While primarily focused on freshwater and biodiversity, the bill also aligns consent pathways for coal mining with other mineral extraction activities under the NPS-FM and National Environmental Standards for Freshwater (NES-F), indirectly affecting aerosol-related regulations (New Zealand Parliament, 2024). These changes aim to reduce regulatory burdens but raise concerns about environmental oversight, particularly as HFOs and SRM research involve atmospheric aerosols. The 2025 *Nature* article warns that such aerosols, if mismanaged, could exacerbate climate impacts, urging stricter standards and monitoring (Nature, 2025).

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Geoengineering: Ethical and Environmental Frontiers

Geoengineering, notably SRM (e.g., stratospheric aerosol injection [SAI] and marine cloud brightening [MCB]), looms on New Zealand’s research horizon (MacInnis-Ng et al., 2023). While still in modeling phases, SRM could intersect with HFO impacts, as both affect atmospheric aerosols. SAI might alter rainfall patterns, potentially reducing precipitation in New Zealand and threatening agriculture, while MCB could influence regional weather dynamics. The ethical stakes are high: who controls such interventions, and how are vulnerable populations protected? The opacity surrounding SRM discussions amplifies these concerns, echoing broader transparency issues in climate governance. Moreover, claims of climate nudging—e.g., via satellites like SUOMI NPP—lack evidence, with events like the July 22, 2023, “hottest day on Earth” aligning with global warming trends (Copernicus, 2023).

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New Zealand’s Blue Economy Trajectory: Opportunity or Exploitation?

New Zealand’s climate direction is increasingly tied to the Blue Economy 2030, a resource-driven vision that raises both opportunities and concerns. The Marine and Coastal Area Act of 2024, replacing the Seabed and Foreshore Act, opened up ocean resources for initiatives like Seabed 2030, aiming to map the ocean floor by 2030 (Seabed2030.org, 2023). This aligns with the “Net Zero” green emissions scheme but risks regulatory capture, as rare gases, minerals, and marine ecosystems like the Ross Shelf’s silverfish populations—crucial to global food chains—are exploited (SCAR, 2023). The Climate Change Literacy Summit (September 2023) and Pacific Standards Week further entrench technocratic priorities, often sidelining community needs (Standards.govt.nz, 2023). Coastal homeowners, red-stickered by 2022, and small businesses face heightened vulnerability, highlighting the need for inclusive governance.

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Global Climate Finance: Ethical Implications

New Zealand’s contributions to the UN Climate Change Fund, alongside nations like Japan, reflect its commitment to global climate action (UNFCCC, 2023). However, these financial obligations strain national budgets, raising ethical questions about equity. Developing nations like China and India, despite significant emissions, are exempt from mandatory contributions under the UNFCCC, placing disproportionate pressure on smaller developed nations (UNFCCC, 2023). This dynamic, often perceived as coercive, underscores the tension between global solidarity and national interest, particularly in the geopolitically competitive Pacific region. New Zealand’s role as a “first” in global initiatives—whether COVID-19 lockdowns or climate disclosure frameworks—positions it as a potential satellite state, amplifying these concerns.

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A Balanced Verdict: Caution Over Celebration

The Montreal Protocol’s legacy is a paradox—laudable yet incomplete. HFOs mitigate direct climate impacts but introduce indirect warming risks, EEP interactions, and TFA contamination, challenging their sustainability. New Zealand’s research leadership is a strength, yet its vulnerability to “Black Swan” events, technocratic drift, and Blue Economy exploitation complicates its “pure” identity. Local councils’ RMA strategies, while evolving, face implementation challenges, and planned retreats remain underfunded. Private sector disclosures push accountability, but industries like agriculture and tourism are at risk. Recent aerosol standard changes, while pragmatic, may weaken environmental protections, as highlighted by the 2025 *Nature* article. Global climate finance, while necessary, must be equitable to avoid overburdening nations like New Zealand.

Policymakers must prioritize long-term HFO studies, focusing on TFA and EEP impacts, and enhance water quality monitoring. Transparent, inclusive governance is essential to balance innovation with accountability, ensuring climate strategies respect democratic values and protect vulnerable ecosystems and communities. The Blue Economy’s potential must be harnessed without sacrificing environmental integrity or community rights.

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Conclusion: Beyond the Victory Cheer

The Montreal Protocol’s ozone-saving success is a milestone, but its broader environmental triumph remains uncertain. HFOs’ hidden costs, New Zealand’s evolving climate role, and the ethical challenges of geoengineering, local governance, and global finance demand a cautious reassessment. As a critical yet fair skeptic, I see progress worth celebrating—yet shadowed by risks that require vigilance, not complacency. The path forward lies in rigorous research, open dialogue, and a commitment to sustainability that transcends short-term.

Thanks for reading.

Uncertain Shadows

The Montreal Protocol’s Legacy, HFO Risks, and New Zealand’s Role in a Global Climate Experiment

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