Summary of comments and responses: addition of precursors to particulate matter, chapter 9
9. Risk management
Comment received
The risk management process should include an accountability protocol to ensure control measures are having the desired effect.
Response
Prior to proposing any regulations or other risk management tools for these substances, the federal government will undertake an assessment of the impacts associated with the proposed instruments. Canadian Environmental Protection Act, 1999 (CEPA 1999) provides for an open and transparent approach when developing regulations, instruments or other risk management tools.
The federal government has already taken some initial steps to put these accountability frameworks in place through improvements to ambient monitoring and emissions inventories. Information obtained through these sources will help in evaluating the success that proposed initiatives will have on PM and ozone levels.
Comment received
The best available technology to control one pollutant often leads to increased emissions of other pollutants (e.g. SCR units).
Response
It is well recognized that certain emission control measures for one given pollutant can cause some increase, usually minor, in another due to energy penalties associated with emission control technologies or phenomenon such as localized ozone scavenging by NOx. Such issues, including the use of multi-pollutant control programs, will be addressed at the risk management stage.
Comment received
The impact emission controls for PM, ozone and the precursors will have on climate change must be considered.
Response
The Government of Canada is committed to analysing the impacts of clean air policies on climate change and vice versa. Studies have been completed and more are underway to give us a better understanding of the potential benefits and cost savings from multi-pollutant strategies as opposed to stand-alone policies for clean air and climate change. Examples include projects on the cost of inaction on climate change, the co-benefits of climate change, and multi-pollutant emissions reduction strategies for various sectors.
Comment received
Costs to the sector for management of these substances should be in proportion to the percentage of emissions generated by each sector.
Response
The impacts of any control measure will be analyzed and considered during the risk management phase. Risk management tools will be developed through a consultative approach with stakeholders.