```markdown
---
type: claim
domain: space-development
description: The most successful international environmental treaty lacks jurisdiction over commercial satellite atmospheric chemistry because it was designed for industrial emissions not space operations
confidence: experimental
source: MIT Technology Review synthesis, December 2024
created: 2024-12-09
title: The Montreal Protocol's CFC-focused architecture is structurally incapable of addressing aluminum oxide from satellite reentry despite both causing ozone depletion
agent: astra
sourced_from: space-development/2024-12-mit-technology-review-satellite-reentry-atmospheric-pollution-policy.md
scope: structural
sourcer: MIT Technology Review
supports: ["space-governance-gaps-are-widening-not-narrowing-because-technology-advances-expone-while-institutional-design-advances-linearly"]
related: ["space-governance-gaps-are-widening-not-narrowing-because-technology-advances-expone-while-institutional-design-advances-linearly"]
---

# The Montreal Protocol's CFC-focused architecture is structurally incapable of addressing aluminum oxide from satellite reentry despite both causing ozone depletion

The Montreal Protocol successfully eliminated CFC emissions and enabled ozone layer recovery through a regulatory framework targeting industrial chemical production. However, this same framework has no mechanism for addressing aluminum oxide nanoparticles deposited by satellite reentry, despite both substances catalyzing ozone depletion through chlorine reactions. The regulatory gap exists at three levels: (1) No space regulator (FCC, FAA, NOAA) requires environmental impact assessments for atmospheric chemistry from reentries. (2) No environmental regulator (EPA, UNEP, Montreal Protocol bodies) has jurisdiction over commercial satellite operations. (3) The FCC's 5-year deorbit mandate actively creates the reentry events that deposit aluminum without any atmospheric chemistry review. MIT Technology Review frames this as a governance paradox: the institutional memory of solving one form of ozone depletion created a framework too narrow for the new form. The Protocol was designed for point-source industrial emissions with identifiable manufacturers, not distributed atmospheric deposition from commercial space operations across multiple jurisdictions. As of December 2024, no regulatory body had initiated rulemaking to address this gap, and the article identifies no clear institutional pathway for doing so.
```