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Office of Air and Radiation
Docket and Information Centre (6101)
Docket No A-96-56
United States Environmental Protection Agency
401 M St., SW
Washington, D. C., 20460

Finding of Significant Contribution and Rulemaking for Certain States in the Ozone Transport Assessment Group Region for Purposes of Reducing Regional Transport of Ozone:
Proposed Rule

Submission filed by: Government of Canada


Ottawa, Canada -- March 9, 1998

The Government of Canada is pleased to submit comments in response to the U.S. Environmental Protection Agency (EPA) in the Federal Register notice of

November 7, 1997 Docket No A-96-56 entitled "Finding of Significant Contribution and Rulemaking for Certain States in the Ozone Transport Assessment Group Region for Purposes of Reducing Regional Transport of Ozone: Proposed Rule".

In 1991, Canada and the U.S. signed the Air Quality Agreement (AQA), which codified the principle that countries are responsible for the effects of their air pollution on one another, and confirmed the commitment of Canada and the U.S. to consult and develop the means to deal with any existing transboundary air pollution problems. The original focus of the AQA was reducing emissions causing acid rain; however, the Agreement also provides a forward-looking framework for addressing new transboundary air quality problems, such as ground level ozone and particulate matter in air.

Canada wishes to support and encourage the EPA in moving aggressively forward with tougher clean air requirements generally and with requiring State Implementation Plan (SIP) revisions in 22 States and the District of Columbia to adopt control measures that will mitigate the ozone transport problem by meeting assigned statewide seasonal nitrogen oxide emissions budgets by the year 2007.

Canada applauds the efforts being made by the Environmental Protection Agency to meet the 1-hour U.S. National Ambient Air Quality Standard for ground-level ozone by reducing the summer-time emissions of nitrogen oxides in the 22 States and the District of Columbia by the year 2007. Further, Canada would encourage the Environmental Protection Agency to maintain the reductions of emissions of nitrogen oxides in the region at the specified summer-time levels throughout the entire year to ensure that acidification of the environment from emissions of nitrogen oxides is also reduced. Finally, Canada supports the implementation timeframe being proposed and would encourage the Environmental Protection Agency not to extend the period for implementation of measures, particularly in the major stationary source sector where the majority of emissions of NOx in the 23 jurisdictions are generated.

The Canadian view is based on a science program in Canada that has just completed an assessment of ground-level ozone and acid rain. The science assessments conclude the following:

  • NOx emissions are key contributors to the transport of ground-level ozone.
  • NOx emissions are important contributors to acidification.
  • Wind and weather bind Canada and the United States with respect to ground-level ozone and acid rain. NOx emissions generated in midwest and northeastern U.S. States contribute to central and eastern Canada not meeting its health goals with respect to ground-level ozone and its environmental goals in terms of acid rain.
  • Reductions of NOx emissions in midwest and northeastern U.S. States will directly ameliorate ground-level ozone levels and acid rain damage in Ontario, Quebec, Nova Scotia and New Brunswick.

Specifically, Canada recommends and urges the U.S. EPA to:

  • maintain the aggressive State NOx emission budgets proposed;
  • require State NOx reductions to be maintained annually; and
  • retain the year 2007 as the deadline for implementation of State measures to meet the NOx emission budgets.

Technical information to corroborate the views expressed by the Government of Canada will be submitted in the coming days.


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