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Industrial Regulatory Framework on Air Emissions

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					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.

				
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