February 19, 1997

The Honourable Lloyd Axworthy, P.C., M.P.
Minister of Foreign Affairs
125 Sussex Drive
Ottawa, Ontario K1A 0G2

Dear Mr. Axworthy:

The March 13, 1991 Canada-United States Air Quality Agreement (Agreement) assigned the International Joint Commission (Commission) a Reference pursuant to Article IX of the Boundary Waters Treaty for the purpose of assisting the Governments of Canada and the United States (Parties) in the implementation of the Agreement. The Commission's responsibilities are:

  1. to invite comments, including through public hearings as appropriate, on each progress report prepared by the Governments' Air Quality Committee;
  2. to submit to the Parties a synthesis of the views presented as well as the record of such views if either Party so requests;
  3. to release the synthesis of views to the public after its submission to the Parties;
  4. to respond to other joint references that the Parties may deliver for the effective management of the Agreement.

This letter presents a synthesis of the comments received on the 1996 Progress Report of the Air Quality Committee. While the report was widely distributed and the notice for comment reached hundreds of people, comments were submitted by only six individuals. When contacted, in connection with providing comments on the Progress Report, several others indicated that there did not appear to be any utility in submitting comments. It was their belief that governments had not substantively addressed many of the key issues raised previously, both in comments provided on the earlier Progress Reports, and in those provided to the Commission for the five-year review of the Agreement.

The Process For Inviting Comment:

As with the previous Progress Report of the Air Quality Committee, a prominent notice requesting comments on the report was included in each copy that was distributed. Following release of the 1996 Progress Report, the Commission published notices requesting comment on the report in the United States Federal Register and the Canada Gazette. A news release was also distributed and a notice was published in the Commission's November/December 1996 issue of its newsletter, Focus. In addition, several telephone calls were made to individuals in Canada to alert them to the call for comments. The Progress Report and the request for comment were also made available via the Internet. A deadline of January 15, 1997 was set for receipt of comments.

Synthesis of Comments Received:

A total of six written submissions were received. Copies of each of the submissions are contained in Annex 1 to this letter.

The comments range from commendation to the authors for providing a useful, up-to-date reference on Canadian and United States programs, to criticism for the lack of progress being made in addressing local air pollution problems in the Saint John, New Brunswick area. One respondent, from Pakistan, transmitted appreciation via the Internet for the work being done on ozone assessment, SO2, SO4 and NO3 deposition and their effects and the importance of maintaining air quality for future generations.

The following specific comments were received on the report.

  1. Two individual submissions were received from the Citizens Coalition For Clean Air, New Brunswick. The concerns raised in these submissions were as follows:

  2. The following comments were offered on the Forest Health Monitoring Section (pages 41-43). The section does not cover the direct and indirect health effects to terrestrial wildlife. There needs to be investigations into understanding the effects of air pollution on animal inhabitants of the forests. This is particularly important for breeding and young animals. Obviously, vertebrates should be the focus of study. Also, the studies on forest soil microbiology (decomposers, mycorrhizae and invertebrates) needs to be mentioned. They are critical to the long-term stability of the forest habitat.

  3. The aquatic effects section makes no mention of the impact of pollution on amphibians and aquatic invertebrates. Many of the invertebrates that are critical components of aquatic food webs may be sensitive to pH or selected ions. In addition, studies show that pollution may affect the parasite load of aquatic vertebrates. This may have an impact on the outcomes of interspecies competition.

  4. The question was raised as to whether it is possible, or necessary, to include the impacts on domesticated animals in urban areas and agricultural areas which show significantly low air quality?

  5. In the Executive Summary, first paragraph under Nitrogen Oxides, it was suggested that governments should also be concerned about other environmental effects related to nitrogen compounds. These include the effects of nitrate particles and nitrogen deposition on visibility and estuarine eutrophication.

  6. A number of statements are made throughout the document that long term monitoring is needed to link emission changes with deposition. There is faltering support for these monitoring and research programs on both sides of the border. Although it may be outside the purview of the U.S./Canada Air Quality Committee responsibility, it would appear that recommendations from the group may help bolster support for research and monitoring that will allow them to produce future progress reports.

  7. Page 22, top of second column: It is not clear if TAF will be continued. Authors should check on the current status of that NAPAP effort.

  8. Ozone has effects, in general, on native vegetation, not just on forests. This should be noted in Section on Page 32.

  9. On page 41, the discussion on needle flecking is ambiguous and misleading. Work on white pine in northeastern U.S. has linked needle flecking and browning with a previously-undescribed fungus. The logic of assuming that ozone is the stressor causing injury in the absence of other information is difficult to accept.

  10. The summary of Canadian domestic programs to reduce ground level ozone in Section IV (page 55) indicates that most of the CCME Phase I initiatives are complete, including reformulation of consumer products. This is incorrect as consultation is still occurring between Environment Canada and industry associations (i.e. CCTFA and CMCS)

Specific editorial comments on the report were as follows:

  1. Page 18, figure caption: Acadia National Park is located in Bar Harbour.
  2. Page 18, end of first paragraph: Should read "(4) minimization of smoke impacts from prescribed fires".
  3. Page 28, figures 5-8: Units and labels for each figure are needed.
  4. Page 39, second paragraph: The (20 kg/ha/yr) should be qualified by adding the word "sulfate".

This letter, containing a synthesis of the comments received on the Air Quality Committee's 1996 Progress Report, is submitted to the Governments of Canada and the United States in fulfilment of the requirements placed upon the International Joint Commission under Article IX of the Canada-United States Air Quality Agreement.

A similar letter has been sent to the United States Department of State by the Secretary of the United States Section of the Commission.

  Yours sincerely,
Murray Clamen
Acting Secretary
Canadian Section



  1. Mrs. Farzana Panhwar, The Sindh Rural Women's Uplift Group, Hyferbad (Sindh) Pakistan
  2. Ms. Paula Tippett, Citizens Coalition For Clean Air, Saint John, New Brunswick
  3. Dr. Brian Shmaefsky, Professor, Biology Coordinator and Director of Biotechnology Education, Kingwood College, Kingwood, Texas
  4. K. Broadbent, Citizens Coalition For Clean Air, Renforth, New Brunswick
  5. Ms. Kathy Tonnessen, Air Resources Division, National Park Service, Denver, Colorado
  6. Alan MacDonald, Lever Ponds, Toronto, Ontario