Summary of comments and responses: addition of precursors to particulate matter, chapter 4
4. Economic considerations
There is a stigma associated with a declaration of toxicity. The impact on industry and trade from this negative connotation could be significant.
Environment Canada recognizes that careful communication with the public is an important component in the path forward. Both the departments of Environment and Health will continue to develop and implement communication plans to ensure that the public understands the conclusions and ramifications of the addition to Schedule 1.
The listing of precursors on the List of Toxic Substances could lead to a "slippery slope" resulting in unnecessary regulation and a large administrative and economic burden.
The addition of precursors to PM10 and ozone and its precursors to Schedule 1 does not, in itself, control the substances. Therefore, there are no costs or benefits associated with simply adding the precursors to Schedule 1.
If the federal government proposes regulations or other risk management tools for these substances, it will undertake an assessment of the impacts associated with the proposed instruments. The Government's Regulatory Policy requires that the benefits of a regulation must exceed it cost and that the regulation should be designed to maximize gains in relation to costs. Risk management tools will be developed through a consultative approach with stakeholders.
No other Western jurisdiction has listed these substances as toxic. While the US regulates the other precursors, it does not regulate ammonia. Canada should be harmonizing as much as possible with US regulatory frameworks and actions.
Regardless of the process, many western countries have implemented more stringent measures to reduce PM and ozone precursors than are currently required in Canada. In the case of CEPA, the legal authority to use the full range of tools, including pollution prevention plans and environmental emergency plans, are available only when a substance is listed by name on Schedule 1.
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