Honourable Chair and honourable members of the legislative committee that is reviewing Bill C-30, thank you for the opportunity to be able to speak on this important issue.
Before I start the formal part of my presentation, you are probably all looking at your materials and no doubt have found the straw. I would like all the members to please take out the straw, put it in your mouth, pinch your nose, and breathe for about 30 seconds.
The purpose of that, ladies and gentlemen, is to let you know what asthmatics or a person suffering from severe allergies or chronic obstructive pulmonary disease feel like when they are undergoing an exacerbation. The motto of the Lung Association is, “When you can't breathe, nothing else matters”.
If there is nothing else in my brief that you remember at the end of the day, I am starting off with what a patient feels like. You have gone through a small test. I will start and end with the words “When you can't breathe, nothing else matters”, and I hope that will position a picture of what it is like for citizens throughout Canada.
The Lung Association commends the federal government for increasing awareness and promoting action on air pollution through the tabling of the Clean Air Act. We also commend all parties for participating in this committee to develop the very best legislation for reducing air pollution and greenhouse gases.
The Canadian Lung Association is Canada's oldest health charity, representing and assisting Canadians who suffer from lung disease. Every 20 minutes, one Canadian dies from lung disease, 2.5 million Canadians have asthma, and the rate in children is four times higher than it was 20 years ago. By 2020, chronic obstructive pulmonary disease will be the third leading cause of death in Canada.
More people will die this year from lung cancer than from any other type of cancer, including breast, prostate, and colon cancer combined. Approximately six million Canadians suffer from lung disease at an estimated cost to the economy of over $15 billion. This includes the direct cost to the health care system, as well as the estimated cost of lost work time and degraded productivity.
The Lung Association has a particular interest in air quality since air pollution exacerbates many respiratory conditions, causing lost work or school days, emergency room visits, hospital stays, and even mortality. Health Canada has estimated that 5,900 people die each year in the eight Canadian cities involved in a recent study. The Ontario Medical Association estimated that in Ontario alone the total yearly costs of death, pain, suffering, lost work, doctor's office visits, emergency room visits, and hospital stays are a staggering $7.8 billion.
General comments. The Lung Association clearly asserts that the guiding principles of a Clean Air Act component of CEPA should be the protection of human health, especially the health of the vulnerable population, such as the young, the elderly, those with pre-existing diseases that make them more susceptible to environmental toxins, and certainly socially vulnerable groups such as the lower socio-economic group categories and first nations.
The Lung Association recognizes the important connection between climate change and air pollution, from causal, impact, and solutions viewpoints--on the connection between climate change, air pollution, and respiratory health. With respect to the Lung Association mission to improve respiratory health, these connections are particularly important in justifying actions to reduce the use of fossil fuels. Caution must be exercised when replacing fossil fuels with alternative energy sources, and careful consideration should be given to the impact on both air quality and greenhouse gas emissions. For instance, the use of biomass as an energy source is problematic from the perspective of respiratory disease, because combustion of biomass produces high levels of air pollution.
Under our recommended amendments to Bill C-30, in our paragraph 1.1 regarding CEPA's overarching considerations, CEPA 1999 is currently under review, and both the House of Commons and Senate committees have received many recommendations for the improvement of this bill. These recommendations include aspects relevant to clean air and greenhouse gases.
The final recommendations, through Bill C-30 and the CEPA review process, should be amalgamated so as not to lose the excellent recommendations that have already been tabled in that review process.
Although the Lung Association has advocated for many years that we must link actions on air quality and climate change, each topic must have its own and equal priority within the bill. While some of the remedial actions for each problem will dovetail, they should stand distinct within the bill, because air pollution and greenhouse gases are interrelated but distinct problems, each requiring its own set of solutions.
Related legislation and international agreements will be focused on either air quality or climate change, but not necessarily on both problems. Thus it is recommended that the amended bill clearly separate air pollutants from greenhouse gases. However, the actions resulting from the bill must ensure that remedial measures on air pollution do not increase greenhouse gases and vice versa. Co-benefit analyses of proposed actions should be conducted.
In our paragraph 1.2.1, under the title “National Air Quality Objectives”, our recommendation regarding proposed section 103.07 is that the word “objectives” should be changed to “standards” and should mean a legally enforceable level.
In 1.2.3, Canada's air quality standard should be set as equal to or lower than the most health protective standards existing internationally. Recognition must be given to the fact that air quality standards cannot be met only by reducing emissions per vehicle or by an intensity basis from industries and power sources. Emissions must also be reduced by efficiency measures—for example, efforts to support a reduction in kilometres driven by vehicles.
In 1.3.1, regulations to eliminate or reduce emissions should be mandatory for all substances on the CEPA toxic list. Wording to this effect should be explicit in Bill C-30, using words such as “will” instead of “may” when indicating regulation.
In 1.3.2, it is also recommended that the bill explicitly stipulate that regulations should aim to reduce emissions to a level equal to or below the level achieved by the most stringent international examples. For certain emissions, such as vehicle emissions, aligning with the United States is a reasonable initial goal. For other emissions, such as those from coal-fired power plants, aligning with other jurisdictions that are leaders in reducing emissions in this area should be the objective.
In 1.3.3, mandatory timelines should be specified in the bill, such that regulations are in place for substances on the toxic list, within the timelines already advised by many groups through the CEPA review process.
In 1.4, regarding the separation of air pollution and greenhouse gases from the CEPA toxic list, Bill C-30 removes these substances from the list and places them in a separate new designation. There is no substantive rationale or benefit in doing this, and there exists a reasonable risk. The federal government has a well-established jurisdictional and historical authority to regulate substances that cross borders, including provincial borders. If those substances cause identifiable risk to Canadians, removing the word “toxic” from the air pollution and greenhouse gas list may make the regulation of these substances vulnerable to provincial or industrial court challenges.
In 1.4.1, it is strongly recommended that the bill use the CEPA toxic list for air pollutants and greenhouse gases in a manner similar to that existing in CEPA 1999. The Clean Air Act component of CEPA should focus action on the air pollutants and greenhouse gas subset of this list and assign new terminology to the air pollutants, referring to them as “hazardous air pollutants”, thus explicitly designating them as dangerous to human health.
In part 1.5 we list our amendments to greenhouse gas provisions.
First, the most contributory greenhouse gases should be included in the CEPA toxic list, which would thus trigger the duty and authority of the ministers of environment and health.
In the interests of reducing or mitigating the threat to human health, including respiratory health, posed by global climate change, the provisions of Bill C-30 must ensure that Canada achieves early and aggressive reductions in greenhouse gas emissions. From this perspective, the targets and timelines specified by the Kyoto accord should be viewed as a starting point for action.
The Lung Association strongly recommends that the federal government pursue measures that will accomplish actual emission reductions over the use of monitoring mechanisms to meet the Kyoto targets. The rationale for this stance is that emission reductions mitigate both greenhouse gases and air pollutants released locally in Canadian communities. Thus emission reductions will improve the health of Canadians as well as reduce the threat of global climate impacts. Priority should therefore be given to measures that achieve reductions and emissions in Canada, complemented by expenditures that would produce actual greenhouse gas reductions in other areas of the world.
Although Bill C-30 does not specify the targets and timelines for reducing greenhouse gases, action arising from the act must recognize the urgent need to achieve even greater reductions in the near term, in the interest of mitigating potential harmful effects on the respiratory health of Canadians.
With the goal of achieving early actual reductions in air pollution and greenhouse gases, it is recommended that all targets be for fixed caps on emissions rather than intensity-based, and that the timelines be tightened considerably.
Under 1.5.4. we list some actions regarding greenhouse gases that should be triggered by the provisions in Bill C-30.
First, in terms of short-term goals, Canada must make every effort to meet the target of reducing its greenhouse gases to 6% below 1990 levels by 2012. If this is not possible with action emission reductions in Canada, the federal government should complement its domestic efforts through financial expenditures on projects that will achieve reductions elsewhere in the world, and set a target date--for example, of 2015--to meet actual emission reductions to 6% below 1990 levels.
With regard to mid-term goals, stringent mid-term targets could be drawn from other leading jurisdictions or international examples. Canada's continued participation in UNFCCC should provide a guideline for those incremental targets. Once again, with a view to protecting the respiratory health of Canadians, the Lung Association recommends that the federal government embrace aggressive goals that will result in early real reductions in both air pollution and greenhouse gases.
In terms of long-term goals, Canada must develop five-year incremental targets to achieve a reduction to 80% below 1990 levels by 2050.
Moving to indoor air quality, the Lung Association is very supportive of the inclusion of indoor air exposures as being equally important to outdoor air exposures, requiring the attention of government, industry, and the public. Standards related to indoor exposure should be set at a level that's protective of the health of vulnerable populations.
The wording in the bill of proposed section 103.09 should be reassessed to ensure that it covers exposure to such substances as radon, which has natural, not anthropogenic, sources. While radon cannot be regulated, activities such as housing construction can be regulated to reduce exposures.
The government is to be congratulated on its recent action to produce radon guidelines that reduce radon from 800 Bq/m3 to 200 Bq/m3.
With regard to accountability, Bill C-30 mentions briefly that emissions will be monitored and reported. It is essential that the act designate clear responsibility for compliance: specific details of when, where, and how monitoring will be conducted; specific reporting deadlines; and the requirement for active public engagement in this process. Actions arising from the act must specify fiscal support to relevant government departments and to jurisdictions as needed.
Due to the time, I'm going to bypass some of these parts, Mr. Chair, but I think it's important to stress that this brief was done and reviewed in consultation with a wide range of experts, including the following: Dr. Monica Campbell, Toronto Public Health; Dr. Paul Hasselback, medical consultant; Dr. Michael Brauer, professor of medical epidemiology at the University of British Columbia; Mr. Bruce Dudley, vice-president of the Delphi Group; Dr. Scott Giffin, Medical Officer of Health, New Brunswick; Dr. Tom Kosatsky, Santé publique de Montréal; and Dr. Menn Biagtan, British Columbia Lung Association.
As I said at the start, thank you very much. This committee, in my mind, has one of the most important challenges facing Parliament today: to come together and produce something for all Canadians, something that we need, that being action on climate change and action on cleaning up the air.
I will close by simply saying what I started with. Gentlemen, ladies, members of Parliament, when you can't breathe, nothing else matters. Please remember that.
Thank you very much.