International Air Quality Advisory Board
SPECIAL REPORT ON
November 1998
6. HARMONIZATION AND STANDARD SETTING PROCESSES 6.1 Need for Collaboration on Criteria Documents Currently, Canada and the United States have, and possibly will have into the future, different ambient air quality standards to protect the health of their citizens and environment. In the past, the Board has recommended adoption of identical standards as one approach to "harmonization" that could resolve some of the current difficulties in addressing transboundary air pollution. In 1992, the Commission concurred with this approach and recommended that "a common ozone standard for the reference region" be established for the WindsorDetroit area. Regardless of the specific standards in place, given the significance of transboundary transport, air quality management in both countries would benefit from a comprehensive binational policy to coordinate implementation, attainment, and maintenance of each country's standards in the border region. Currently, each country has policies and mechanisms to address interstate and interprovincial transport of air pollution. The U.S. CAA Amendments of 1990 address these issues directly in sections 126 (interstate pollution abatement), 169B(c) (establishment of visibility transport regions and commissions), and 176A (interstate transport commissions). In Canada, interprovincial transport is addressed through processes established for the implementation of the Canadian Environmental Protection Act. In neither country, however, is there explicit recognition of the need to reflect on the quality of air masses imported or exported between the countries. Indeed, Section 179B of the CAA states that jurisdictions "are free to develop implementation plans for the attainment and maintenance of air quality standards in border regions as if there were no emissions present in the adjacent country." In Section 1 of this report, the Board put forward an approach -- Transboundary Air Pollution Transport Regions -- to foster improved binational coordination in documenting and addressing significant reoccurring instances of transboundary air pollution. Approaches such as this should be focused, to a large degree, on ensuring that similar criteria or bases are used in developing national air quality standards (e.g. standards for tropospheric ozone). Under this approach, the Board recognizes that the two national processes and their outcomes are distinct. Violations of Canadian standards do not give rise to the same capacity for proscribed legal action that can follow exceedances of a standard in the United States. Also, certain economic factors, which must be considered in setting standards, may differ significantly in the two countries. Even with these differences, it would be important to formally include scientists from one country in the preparation of and, more importantly, the process used to review scientific and health data contributing to the development of specific air quality standard in the other country. In the United States, this process is the development of the "criteria document"; there are similar, albeit less accessible processes in Canada. Ideally, these scientists would be involved in analysis and discussion of atmospheric chemistry, meteorology, ecosystem impacts, and human epidemiology or clinical studies. Currently, many Canadians do participate in such discussions in the United States. The formalizing of a collaborative process, however, could result in documents that would be useful in the standard-setting processes in both countries. The preparation of a Staff Paper under the standards development process by the U.S. EPA involves calculating the exposed population at different levels and considering other issues not directly addressed in the criteria document. The Staff Paper also recommends possible upper and lower limits for standards. Although a direct collaborative effort at this stage may not be warranted, Canada should consider the Staff Papers in-depth and place the points raised by the United States in a Canadian context when deriving its own standards. While such steps would not assure the adoption of identical standards by both countries, the reasons for differences would be understood, and the existing scientific database for each pollutant would have been evaluated jointly. Another important area of harmonization would be agreement on the technical aspects of preparing emissions inventories for both stationary and mobile sources. In Section 8, the Board has stressed the importance of ensuring that measurements of pollutants, particularly PM2.5, on both sides of the border are compatible. Recommendation While the merit and possibility of harmonized standards continues to be considered by both governments, the Board recommends that, in addition to establishing the TAPTRs, the Commission advocate appropriate inclusion of experts from both countries in the development of air quality standards and criteria by each country, including joint involvement in elements (e.g. monitoring and emission inventory development) that contribute to such processes. |