Home / Climate / Developing Ambient Air Quality Objectives For Canada / Ambient Air – Section 3

Ambient Air – Section 3

 

3 Observations

Previous - Contents - Next Based on its research, the NRTEE observes that the current system for setting national ambient air quality objectives in Canada for PM and ozone, which now incorporates the CWS process, has the potential to provide a solid and thorough basis for setting effective and appropriate objectives in the future. However, the NRTEE research identified that more can be done in the following key areas:

• long-term ambient air quality objectives;
• medium-term air quality standards; and
• the role of governments at all levels.

3.1 Long-term ambient air quality objectives

Long-term objectives should set a national directional goal that the entire country can strive to achieve. Long-term ambient air quality objectives should be the starting point in Canada's efforts to address PM and ozone. Long-term objectives directly shape important decisions around medium-term air quality standards; they put national goals into operation and instigate short-term actions, provincial and territorial implementation plans, and private sector decisions. The sooner these long-term objectives can be set, the sooner more immediate decisions on abatement efforts, including technology deployment, can be positively influenced. Given the uncertainty about the state of the atmosphere by mid-century, the possible innovations in abatement technology, and, above all, the improvements in the understanding of genetics and human health effects of air pollutants, it is unrealistic to attach legally binding numerical targets to long-term objectives. Instead, long-term ambient air quality objectives should be ""directional" — that is, national goals expressed in qualitative terms that the entire country can then work toward. In this way, the objectives can provide a fair and equitable basis for improvements in air quality across the country; they can also serve as the basis for sustained policy commitments that will direct significant improvements in air quality in Canada over the next 30 or 40 years. Long-term objectives can serve, too, as a benchmark, against which to measure future performance and — when paired with reporting obligations — to hold governments accountable. Long-term objectives can take a number of forms, such as "a level equivalent to the natural background" or one tiered to a certain tolerable, acceptable, or desirable level of health risk.8 An objective could involve percentage reductions from current conditions, or aim to match or exceed the best international objectives.  Long-term objectives should be based on the best available science, be focused principally on human health effects, and be updated accordingly. The evidence is overwhelming that chronic, poor air quality adversely affects the health of the entire population. Health effects range from respiratory conditions such as asthma and chronic bronchitis to premature death and increased mortality. From an environmental perspective, ozone has also been linked to reduced plant productivity, resulting in reduced agriculture crop yields and forest growth. This means that long-term objectives are the end point, and need to be science-based, driven primarily by an improved understanding of the effects of air pollutants on human health and, to a lesser extent, on ecosystem health (see Appendix 3). Questions of regional differences, technology, costs, affordability, and pollution sources are factors better addressed in terms of medium-term standards, rather than in terms of the objectives themselves. The process of setting long-term objectives should begin with the definition of a set of principles. Based on Canadian and international experience to date in setting air quality standards, the process of setting long-term national objectives should begin with the definition of a set of clear and common principles to which all jurisdictions must commit to achieving. These principles could include, for example, that:

• all Canadians have the right to be able to breathe clean air wherever they live; and
• jurisdictional accountability should be transparent and unambiguous, with reporting on progress made available to Canadians.

The fact that Canada's air quality is affected by transboundary flows needs to be accounted for when setting objectives. Canada's long-term air quality objectives have an important international dimension. First, meeting a long-term objective in some parts of Canada — notably in southern Ontario and the lower mainland of British Columbia — will depend to a great extent on cooperation with the United States. Second, long-range transport of air pollutants — particularly from the growing economies in Asia — is a continuing concern. These trends increasingly make air pollution a global, as well as a national and regional, problem, while underscoring the importance of national objectives that can protect air quality for Canadians in all regions. Long-term objectives for Canada should therefore account for transboundary effects from these respective regions.

3.2 Medium-term air quality standards

Medium-term standards are needed to put the national long-term objectives into effect. To be credible and effective, long-term objectives need to be supported by explicit medium-term standards. Medium-term standards are tangible targets that industry can understand and achieve through investment decisions and other actions. Standards, implemented through regulations, can establish expectations regarding the current regulatory period and send a signal to industry to expect a further set of reductions in the following regulatory cycle. For many Canadian industries, the medium-term of 2020 aligns with the current economic cycle. Many existing facilities (and sources of pollutants) will be reaching the end of their lifecycle by 2020. By undertaking action now through this current "window of opportunity," industries and governments will be able to plan their capital investments to specifically meet air quality standards. Medium-term air quality standards should be achieved through pollution control programs, which could include a mix of binding regulations and market mechanisms. These should be developed through a regionally-based, participatory consultative process. Whereas long-term objectives are directional and qualitative, medium-term standards should serve as quantitative, enforceable mechanisms for moving toward a specific target over a certain timeframe. As with the long-term objectives, developers of the standards should take into account scientific findings with respect to human health and the ecosystem effects of air pollutants. Other considerations, such as "keeping clean areas clean,"9 will ensure the avoidance of future problems. As well, the developers of standards need to consider regional differences (in geography and meteorology, for example), as well as regional economic factors. Given the need to take these considerations into account, medium-term standards should be developed through a regionally based consultative process. But again, it is critical to work toward a common objective by making the standards more stringent over time — both to balance the transition and to ultimately achieve the end objective. Medium-term standards can be achieved through enforceable pollution control programs, and could include a mix of regulatory measures (including performance-based emission standards) and market-based mechanisms such as emission charges and cap-and-trade systems. Limited exemptions would be needed to account for those areas unable to achieve the standards without severe economic dislocation, or because of transboundary pollution sources. But even in those exempted cases, regions would still have to work toward the standards and report on their progress. In addition, non-legislatively based instruments such as guidelines and codes of practice would have a role to play. 

3.3 The role of the federal government

Public awareness of air quality issues and expectations for government action at all levels have likely never been greater. Indeed, clean air has emerged as a "top shelf" concern of Canadians, and expectations are high for government action. This presents the federal government and, indeed, all governments with an opportunity for undertaking significant action in support of improved air quality in all regions. Past national efforts at improving air quality were apparently hampered by a lack of accountability within the current federal-provincialterritorial framework. In fact, there is a question as to whether the current CCME process, as now constituted, is sufficiently effective to give clean air objectives and standards the profile, or assurance of progress, that Canadians need. As we move forward, accountability has to be clearly established if the national objectives and standards are not only to be set but, more importantly, achieved.  Federal leadership is needed to build a coordinated national approach to improving air quality that is both fair and equitable to all citizens and industry. The federal government should lead the coordination and development of the long-term, national air quality objectives. The federal government is best placed to lead the work on setting long-term objectives via a science-based effort, one that could be undertaken through an independent national panel as set out below. A coordinated national approach, led by the federal government, is necessary to establish appropriate consistency across the country — an important factor in ensuring equity among all citizens and a level playing field for industry. The federal government also can play an important leadership and coordinating role through its jurisdiction over transboundary issues, transportation fuels, and the toxic substances provisions of CEPA. It can bring to the table its scientific expertise, as well as its ability to promote equity among the provinces by assisting with capacity building. Federal leadership on its own is not enough, however. Provincial and territorial governments will have a lead role in setting and enforcing air quality standards in their respective jurisdictions. Furthermore, the provinces and territories will play a key role in engaging the industrial sectors' efforts to achieve air quality standards. Municipal and regional governments, too, will have significant opportunities to influence community-led projects in order to improve air quality and direct infrastructure improvements in transportation, which in turn can lead to reduced fuel use and emissions. An effective national approach should involve all levels of government, resulting in shared responsibility and clear accountability. Communication and consultation will be important tasks for the federal government. The federal government has still another key role: communicating the long-term air quality objectives and medium-term standards to Canadian industry. Industry must be certain that the objectives and standards have the full commitment of the federal government. Policy certainty will signal that emission reductions are required, which in turn will trigger the investment decisions and innovations that lead to lower emission reduction costs and the resulting human health and ecosystem benefits. The federal government must engage the Canadian public regarding the air quality objectives and standards. Citizen involvement and regular reporting to Parliament and Canadians on the progress to date will be key elements in ensuring accountability and in gaining public acceptance of, and support for, air quality initiatives. The same holds true for provincial and territorial governments. One element of this effort will be to build awareness of the importance of, and need for, individual action on reducing air pollution.

3.4 Challenges

The NRTEE research identified a number of challenges to the process of setting long-term objectives and medium-term standards. The key challenges are the following:

• the need for a more comprehensive approach and a more consistent focus than has been seen to date regarding the implementation, abatement, monitoring and refinement of standards;
• the reality that various jurisdictions have different capacities for meeting standards or objectives. More stringent standards could have higher cost implications, which might pose significant challenges for some regions. Furthermore, certain regions might not be able to attain a "national" objective, or standard, based on their current air quality situation (i.e., perhaps their baseline of emissions already exceeds a particular standard or objective). For such situations, the challenge will be how best to deal with these "non-attainment" areas and any potential exemptions needed to address them.
• the need to determine how to apply the highest standard to local areas, given the differing air shed circumstances across the country that must be taken into account; and
• the need to precede the positioning of a PM or ozone standard valuation with a clearer understanding of regional effects and a complex set of epidemiological considerations. As noted earlier, no single agreed policy document identifies an obvious, overarching single standard; that there are several hundred suggests that health impacts may occur in a set of environmental conditions with the common elements of PM and/or ozone exposure.