The first main issue is the language. It's weak, and it provides a lot of discretion. I'll give you an example.
In article 20.5 it talks about the protection of the ozone layer. What the chapter does is use words like “recognizing that emissions of certain substances can significantly deplete the ozone layer”, and “recognizing the importance of public participation, but in accordance with the parties' systems of participation already in place”. It commits the parties only to take measures to control the production and consumption of trade in ozone-depleting substances. We need a ban. It's too weak. Saying you should take measures is not well defined enough to control the trade of ozone-depleting substances. There should be a ban on those trades.