Summary of comments and responses: addition of precursors to particulate matter, chapter 2
2. Overlap and duplication
The precursor substances are already managed through the Canada-wide Standards (CWS) process and provincial and voluntary standards and agreements. Additional federal regulation is unnecessary and duplicative and could undermine the effectiveness of initiatives such as the Agricultural Policy Framework, emissions trading and international agreements such as the Ozone Annex.
Adding the precursors to PM10 and ozone to Schedule 1 does not, in itself, control the substances in any way. It simply establishes the additional legal authority for the federal government to take the actions under CEPA 1999 that it has already committed to work towards under domestic programs and international agreements.
Canada needs a concerted, cooperative effort by all jurisdictions to achieve the PM and Ozone CWS. The federal, provincial, and territorial governments have committed to further actions under the CWS and it is now incumbent upon all jurisdictions to deliver on these commitments. The federal government has committed to do its part to help achieve the CWS and has outlined its initial actions in its Interim Plan 2001 on PM and Ozone.
In order to deliver on its own commitments under the CWS, it is imperative that the federal government has access to the full range of "CEPA tools". This is only possible when the precursors are listed by name on Schedule 1.
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. Efforts will be made to establish linkages with the programs and initiatives of other federal departments and provincial and territorial jurisdictions in order to promote efficiency and avoid duplication.
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