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As the most successful environmental treaty to date, the Montreal Protocol is the prime arena for implementing policy to reduce hydrofluorocarbon (“HFC”) emissions and mitigate the threat of climate change. The Montreal Protocol began phasing out chlorofluorocarbon (“CFC”) production and consumption in 1989 and has since stopped, and even reversed, destruction of the ozone layer. Hydrochlorofluorocarbons (“HCFCs”) were produced to replace the highly ozone-depleting CFCs because of HCFCs’ reduced ozone depleting potential. To completely phase out all ozone depleting substances (“ODSs”), industrial gas producers introduced HFCs to replace HCFCs. Although HFCs have no ozone depleting potential, they have thousands of times the strength of carbon dioxide to warm the earth, known as “global warming potential.”