Thank you, Mr. Chairman and members of the committee. It's an honour to be with you.
I would remind you that we not only submitted extensive written testimony back in June, but we had two earlier opportunities to provide oral testimony. So we will confine our remarks today to enforcement, public participation, and appropriate tools, which we understand to be your particular concern today.
Most of our remarks will deal with public participation. Generally speaking, we've had a very positive experience with the CEPA public participation process with regard to the implementation, the risk management phase, and a relatively negative experience with public participation with regard to the risk assessment process. Unlike the risk management phase with stakeholder involvement, which invaluably improved the end product and facilitated implementation, the insularity of the assessment process and the agency's refusal to impose rigour on its scientific exercise impaired the result and set back the implementation. It was a distinct misstep.
For example, we were quite disturbed when Environment Canada publicized its findings before they went to the public participation process. They scheduled a news conference we were unable to effectively respond to at the last second and rebut some of the misinformation that was given out. The headlines across the country were all about the warnings that road salts were toxic; and this being a food, it was very unclear and confusing to the public. We think Environment Canada played on that as opposed to trying to understand that's what was going to happen.
The assessors proceeded to ignore that public outcry and went to the second phase, and at that point they understood they were in trouble with their communication with the public. When they announced the second phase they did not use the word “toxic”; they very studiously avoided it. They even counselled the media that they intended not to use it, and yet the headlines were that salt is toxic. Again, the press had been sold this, so they couldn't back off.
At about this time, Environment Canada was trying to tell the world that road salts were toxic, but at the same time they were rolling out the implementation process. So unlike the rather obscure public participation process of gazetting for the assessment, the implementation for the risk management phase was very public, very inclusive. A stakeholders group was set up, and a lot of constructive things were said. So instead of having the situation that under the assessment it was the largest public participation process under CEPA--I believe that's still the case--most of the comments came back negative to what Environment Canada had proposed. Instead of being able to condition the groups that were going to have to comply, which are the provincial and local government agencies that were the target of the assessment, it set us back in terms of mobilizing those people in a constructive way to solve the problem.
It bears mention that the risk management phase involved an entirely new team. The people who did the assessment were in one branch and the people who did the risk management were in another branch. There was no carry-over, and so a whole new set of people were getting up to speed. We're very pleased to report that in contrast to the public participation and risk assessment phase, our experience with public participation on the risk management process and in implementing an excellent code of practice for road salts management has been very positive. It was like night and day to us. Frankly, we'd give Environment Canada failing grades for public participation in the assessment process, but tell them to go to the head of the class in terms of the way they ran the risk management phase.
As is the case with most environmental initiatives, once people understand how to do things better and once they make necessary investments to achieve better environmental management, momentum is achieved by these incentives. In the case of road salts, the agencies now understand that proper management not only can protect the environment but can be accomplished consistent—