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:
- to invite comments, including through public hearings as appropriate, on each progress
report prepared by the Governments' Air Quality Committee;
- to submit to the Parties a synthesis of the views presented as well as the record of such
views if either Party so requests;
- to release the synthesis of views to the public after its submission to the Parties;
- 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.
- Two individual submissions were received from the Citizens Coalition For Clean Air, New
Brunswick. The concerns raised in these submissions were as follows:
- Disappointment was expressed that ozone levels in Saint John still exceed the standard
at times. It was suggested that this is because New Brunswick has still not implemented
all the Stage I and Stage II controls it promised in the original NOx-VOC agreement. It is
encouraging to see that the Lower Fraser Valley has reached attainment status. The
Government of B.C. has been more diligent in complying with the NOx-VOC agreement
than the Government of N.B.
- It was pointed out that New Brunswick's Fundy Coast is still suffering from the effects
of acid rain and acid fog. The Coleson Cove oil-fired generating station belonging to the
provincial power utility, NB Power, was blamed. In 1980, prior to the Canada-U.S. Air
Quality Agreement, people in Saint John were suffering health effects from air pollution.
That year the Coleson Cove generating station emitted 54.5 kilotonnes of sulphur dioxide.
In 1980, the Coleson Cove generating station emitted 58.5 kilotonnes. People in Saint
John are still complaining of health effects of air pollution, acid deposition is still well
above 8 kg/ha/yr, and sulphur dioxide emissions from Coleson Cove were only reduced
to 50.5 kilotonnes by 1993, the last year for which they have data.
- It was suggested that there should be some means to penalize governments that continue
to allow damaging levels of emissions in sensitive areas. Many governments and
industrial polluters in other parts of Canada and the U.S. have made serious efforts at
considerable expense to clean up the environment and stop pollutants that cause acid rain.
New Brunswick has not made serious efforts to reduce air pollution in Saint John, and
last year allowed the Irving Refinery in Saint John to increase emissions of sulphur
- The possibility exists for Coleson Cove to convert to natural gas when the gas pipeline
is completed, but pressure needs to be applied to the New Brunswick government to force
N.B. Power to switch from oil to natural gas.
- It was suggested that the Government of Canada and the United States should consider
sanctions in non-attainment areas for governments and industries responsible for
- The N.B. Power Commission, as a result of the fuel they use at Coleson Cove and
Courtney Bay power plants, are responsible for a vast amount of pollution in Saint John
and southern New Brunswick. They should be forced to switch to low sulphur content
crude oil to reduce the 60 kilotonnes of SO2 they spew out each year. The managers of
this entity are guilty of dereliction of public duty and should be legislated to change their
ways, or themselves be fired.
- 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.
- 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
- 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
- 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.
- 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.
- 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.
- Ozone has effects, in general, on native vegetation, not just on forests. This should be noted
in Section on Page 32.
- 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.
- 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:
- Page 18, figure caption: Acadia National Park is located in Bar Harbour.
- Page 18, end of first paragraph: Should read "(4) minimization of smoke impacts from
- Page 28, figures 5-8: Units and labels for each figure are needed.
- Page 39, second paragraph: The (20 kg/ha/yr) should be qualified by adding the word
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.
ANNEX 1 - COMMENTS RECEIVED ON THE 1996 PROGRESS REPORT OF THE
AIR QUALITY COMMITTEE
- Mrs. Farzana Panhwar, The Sindh Rural Women's Uplift Group, Hyferbad (Sindh) Pakistan
- Ms. Paula Tippett, Citizens Coalition For Clean Air, Saint John, New Brunswick
- Dr. Brian Shmaefsky, Professor, Biology Coordinator and Director of Biotechnology
Education, Kingwood College, Kingwood, Texas
- K. Broadbent, Citizens Coalition For Clean Air, Renforth, New Brunswick
- Ms. Kathy Tonnessen, Air Resources Division, National Park Service, Denver, Colorado
- Alan MacDonald, Lever Ponds, Toronto, Ontario