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Base Metal Smelters and Refineries and Zinc Plants – Response to Stakeholders' Comments

Theme Number 7: Creation of level playing field

Comments

Comments related to the necessity to create (or not) a level playing field in terms of regulatory requirements for base metals smelters in Canada:

  • Companies should operate on a level playing field of environmental performance requirements and reduce emissions to specified levels measured in unit release per unit production.
  • Competition is distorted by avoiding pollution prevention and control costs, as high emitters can offer more attractive terms to concentrate suppliers.
  • The federal government should adopt targets to facilitate a level playing field.
  • Rejection of arguments that Manitoba smelters should be forced to rapidly reduce emissions to create a level playing field.

Responses

The P2 Planning Notice and Code of Practice provides goals for continual improvements and a "level playing" field of environmental performance based on world class standards, to be achieved by 2015. This balanced approach takes into account scientific, technological, and economic and policy considerations and the initially widely divergent views of stakeholders.

Comments

Some comments noted that the Proposed Notice was not helping the creation of a level-playing field:

  • The Proposed Notice increases sulphur dioxide emissions disparity among competing nickel and copper smelters.
  • Considerable 2008 sulphur dioxide reductions required from low emitters constrain growth, while insignificant reductions are required from major emitters.

Responses

The modified P2 Planning Notice is responsive to these concerns, while achieving a level playing field of environmental performance.

Comments

A comment noted that transboundary air and water impacts should be addressed, as one jurisdiction's willingness or neglect to encourage P2 planning should not come at another's expense.

Responses

The Ambient Air and Water Quality Objectives and Release Guidelines cited in the Code, and the intent to develop release regulations, will help bring uniform environmental quality across the country.

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