In addition to the distribution of the report by the governments of Canada and the United
States, the IJC distributed copies with its requests for comment. Written comments were
requested to be provided by February 28, 2003.
This report contains a synthesis of comments received by the International Joint Commission
on the 2002 Progress Report. A total of 30 written submissions were received, 26 from Canada
and four from the United States. The views expressed at the meetings with non-government
organizations have also been incorporated into the synthesis. The comments received ranged
from general views on the agreement and progress reported to specific comments on aspects
of the Progress Report. In the following text, each comment is attributed to the respondent or
respondents who provided it. The numbers in parentheses correspond to the respondents listed
in the appendix. Every effort has been made to accurately reflect the views of the respondents.
The views expressed are those of the respondents, not the IJC. The full text of all comments
received can be viewed on the Commission’s website at
Respondents were generally supportive of the Agreement and recognize it as a valuable means
for cooperation and coordination of air quality initiatives. They stated the Agreement appears
to have been successful on many levels, not the least of which is keeping the issue of reducing
cross-border pollution out in the open so those interested have the ability to view progress
being made. (3) As one respondent noted “It is a valuable reference and it is comforting to
know that, for some pollutants, some progress is being made”. (4) Five written submissions
came from senior officials in provincial governments who indicated their general support for
the agreement. In addition, some of these officials commented that the report is comprehen-
sive, informative and illustrates the important work being done to address transboundary air
quality. They also suggested the reports are a good means of communicating information to
stakeholders. (6, 15, 18, 19) The Stó:lô Nation expressed concern at how little mention of
participation there was by First Nation communities in this report and on the Agreement. (30)
Several comments were generally critical of the report. They recognized that while it is useful
to describe the progress made to date in emissions reductions, the report lacks analysis and
meaningful conclusions, and does not address gaps, delays and obstacles in both countries to
achieving the goals established in the Agreement. (16, 24) Respondents said the continuing
challenges should also be noted and analyzed. Indeed, it seemed to some to be only “half a
report” because while it says what is happening, it does not say what is not. The report lacks
the scientific rigour of the report Protection of the Waters of the Great Lakes – Three Year
Review. (24) It was suggested that the reports authors are so zealous in their efforts to avoid
political controversy that they risk being accused of deceiving the public. (17) Several believed
that this shortcoming is particularly evident in the context of Ontario achieving compliance
with its electricity sector obligations under the Ozone Annex. Attempts to pretend that all is
well in attaining Ozone Annex compliance, with the public controversy regarding this issue,
constrains the credibility of report. (16, 17) The failure to address these very public concerns
was seen as the most glaring omission of the Report. The description of Ontario’s Anti-Smog
Action Plan on page 15 of the Progress Report makes it sound as though progress is being
made, when in fact there has been no meeting of the steering committee for over a year. (16)