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German Environment Agency
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Large (250 or more)
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To whom it may concern,

We would like to point out two aspects:

1. We recommend a consistent strict ban of ozone depleting substances. This becomes apparent e.g. for the refrigerant 1233zd which has an existing ozone depleting potential (0.00034; Scientific Assessment of Ozone Depletion: 2014, World Meteorological Organization, Global Ozone Research and Monitoring Project—Report No. 55, 416 pp., Geneva, Switzerland, 2014). Despite the ODP>0 the substance will be produced and promoted for several new applications in the field of refrigeration.

2. Recent research has shown that halogenated very short-lived substances (VSLS; e.g. dichloromethane) which has atmospheric lifetimes < six months seem to have a stronger impact on stratospheric ozone depletion than previously thought (Leedham Elvidge, E.C. et al.; Atmos. Chem. Phys., 15, 1939-1958, 2015. Hossaini, R. et al.; Nat Commun. 2017 Jun 27;8:15962, 2017.) Based on these findings in our opinion a broader consideration of non-Montreal Protocol compounds and the evaluation of an additional inclusion of halogenated VSLS would be beneficial to improve the protection and regeneration of ozone layer.

Yours faithfully

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