Industrial Regulatory Framework on Air Emissions 1. Intensity based emission limits are only likely to result in real reductions if the economy tanks. The economy is unlikely to tank because it is being driven by oil and gas exports. 2. The treatment of new facilities discourages companies from building clean or zero discharge to start with. 3. The baseline year of 2006 penalizes those progressive companies who have in good faith been trying to reduce already. 4. These and other mechanisms, as noted by industry, conspire to create a chill on innovative and new investments which are of an environmentally progressive nature – the exact opposite of the “champions” kind of corporate culture the department has always said it was trying to nurture. 5. The 10% cap on Clean Development investments makes a mockery of the entire worthwhile mechanism for “buying our way out” of GHG limits. Even developing countries will not benefit from this framework. 6. It should be noted that the EU carbon market is now being criticised for NOT supporting innovation. 7. Planting trees is not a method of capturing carbon if the forest is clearcut first and then the new trees are harvested on a 100 year or less rotation. 8. A market in SOx and NOx is a market in death and asthma. It is morally reprehensible. 9. Further this market must not allow trading in SOx and NOx within an affected airshed because it is the ambient air quality which is the health hazard. 10. It is extremely doubtful that Environment Canada has the administrative capacity to deal with this complicated system; furthermore the baroque complications and numerous levels of bureaucratic judgement make the system vulnerable to every “fiddle” under the sun. Delores Broten, Reach for Unbleached, June 15 2007.