Minister's response to notice of objection: NOVA Chemicals - February 2022
President and Chief Executive Officer
1000 7th Avenue S.W.
Calgary AB T2P 5L5
Dear Luis Sierra:
This letter is in response to your Notice of Objection and request to establish a board of review to the publication of the proposed Single-Use Plastics Prohibition Regulations, which was received by Environment and Climate Change Canada on February 22, 2022. The proposed Regulations were published in the Canada Gazette, Part I, on December 25, 2021.
I have carefully considered the issues set out in your Notice of Objection. As the scientific information provided in this notice did not raise sufficient uncertainty or doubt in the scientific considerations underlying the proposed Regulations to warrant the establishment of a board of review, I am denying your request to establish this board. The scientific considerations that underlay the proposed Regulations are related to the prevalence in and harmful effects on the environment of the six categories of single-use plastics subject to these regulations.
I would like to address one argument you raised. In your Notice of Objection, you stated that Environment and Climate Change Canada is asserting that waste resulting from single-use plastics is more harmful to the environment than non-plastic waste, since there are no specific studies assessing the risk associated with single-use plastics in the environment. No such statement is made in the Regulatory Impact Analysis Statement to the proposed Regulations. The Government of Canada is taking action to reduce plastic pollution following recommendations from the Science Assessment of Plastic Pollution. The Science Assessment is a rigorous scientific document that found that plastic pollution is ubiquitous in the environment and that macroplastic pollution poses a threat of harm to environmental receptors.
With regard to the non-scientific points raised in your Notice of Objection, these are being considered alongside other comments received on the proposed Regulations. The Department will summarize these comments and describe how these matters have been addressed in the Regulatory Impact Analysis Statement that will be published with the final Regulations in the Canada Gazette, Part II.
I appreciate your bringing NOVA Chemicals’ concerns to my attention. Please accept my best regards.
The Honourable Steven Guilbeault, P.C., M.P. (il/lui/he/him)
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