Several respondents suggested that the report gives short shift to mercury. The failure of both
Canada and the United States to take action to reduce mercury emissions from fossil-fueled
generators is a glaring gap. (16, 17, 27, 30) The statement “The Air Quality Committee may
be interested in mercury-related analyses as it relates to emissions from power plant genera-
tion...” was pointed out as being extremely vague. There is no active program to reduce power
plant mercury emissions in either country. This failing flies in the face of the Great Lakes Water
Quality Agreement goal of virtual elimination of persistent toxic substances. (17) The Canada-
wide standard process for mercury emissions is stalled and needs to be revitalized and a na-
tional standard for mercury emissions from the electricity generation sector is needed. (20) The
need to scrutinize mercury emissions from the Sumas Energy 2 proposed power plant was also
raised. (30)
Views on United States Legislative and Regulatory Initiatives
Under Emerging Country Issues (page 20), there is a brief summary of the U.S.
Administration’s Clear Skies Initiative that mentions the substantial reductions in sulfur dioxide
and nitrogen oxides that will result if Congress passes the legislation. It was recognized that
, NO  and mercury. (27)
this initiative could significantly reduce power plant emissions of SO
2
x
However, a number of respondents expressed concern about this initiative and the New Source
Review legislation under the Clean Air Act. (3, 7, 23, 26, 31) With respect to the Clear Skies
initiative, based on readings from U.S. government entities (e.g. Congressional Research
Service), there does not appear to be any consensus that the initiative will bring about the
reductions listed in the Progress Report. (3) If the report does comment on future proposals, it
should provide a more complete picture of those proposals, including drawbacks/criticisms. (3)
Several respondents were also critical of the U.S. Administration for the apparent rolling back
of requirements under the Clean Air Act for coal fired power plants. (7) Specifically, the New
Source Review (NSR) legislation and its impact on cross-border air pollution flow. (10) Al-
though there have been assurances from the U.S. EPA that NO  State Implementation Plans
x
(on which the Ozone Annex relies heavily) will not be affected, very little analysis has been
made public. There has been no evaluation of the potential local impact of an NSR rollback on
Canadian border communities that are close to industrialized areas in the United States. (26)
Reconciling these initiatives as they apply to power plants with the prevention of air quality
deterioration and visibility requirements under the Agreement was also questioned and an
explanation requested on their compatibility. (27) It was suggested that filling this information
gap is critical to understanding the quality of our air, impacts on health and the progress made
by Canada and the United States in meeting their commitments under the Agreement. (31)
The Air Quality Agreement plays a valuable role in fostering communication on cross-border
air pollution issues and the sharing of information. Its implementation requires consideration of
the downwind implications of major changes in policy and practice on both sides of the border.
The 2002 Progress Report cannot be considered complete until it evaluates Canada’s and the
United States’ analysis, or lack thereof, of the air quality impacts of anticipated changes to the
U.S. Clean Air Act. (31)
The Georgian Bay Association expressed serious concerns regarding the impact of the New
Source Review (NSR) rollbacks on air quality for the eastern Georgian Bay area. When winds
are from the southwest, they bring transboundary air pollution to Georgian Bay from the Ohio
Valley and the American midwest. They reinforced the call for investigation of the
transboundary impact of U.S. New Source Review legislation. (23)
11