Environment Committee on Dec. 1st, 2016

[The Chair (Mrs. Deborah Schulte (King—Vaughan, Lib.)), Liberal, Deb Schulte]

I would like to welcome everybody. Today is our monitoring panel. We really appreciate all the witnesses who are with us, and those who are joining us through video conference. I will introduce everyone in a minute.

We are going to be on a fairly tight timeline because we have votes tonight. I just wanted to know how much time everyone thinks they'll need to get back over to the House and be sitting in their seat for votes. Would 20 minutes be enough for everyone to get over there, so we know what we're shooting for here? I'm just trying to get a handle on it. Is 20 minutes reasonable?

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

I think the rule, Madam Chair, is that once the bells go then we have to unanimously decide at that point.

[The Chair, Liberal, Deb Schulte]

I'm just trying to get a sense of what we might be able to do, because it will help me decide on the number of questions I'm going to allow.

[Ed Fast, Conservative, Abbotsford, BC]

I think 20 minutes is more than enough to walk from here to there.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

As long as I get a five-minute head start on Ed.

[The Chair, Liberal, Deb Schulte]

Okay, as you are absolutely correct, we will have to deal with it right as bells start. I just wanted to give everyone a heads-up to be mindful of where I'd like to go.

Let's introduce our guests. We have John Smol, professor and Canada research chair in environmental change at Queen's University. We have from the Forest Products Association of Canada, Robert Larocque, vice-president, climate change, environment, and labour.

We have quite a few today from Alberta's Industrial Heartland Association. I want to mention they have brought quite a lot of information in their package. It's not in both official languages, so we're just going to make it available at the back if you should want it. If you'd like a package, there's one at the back in English.

From the association we have with us, Ed Gibbons, who's chair and councillor for the City of Edmonton. We have Pam Cholak, director of stakeholder relations. Both of them are going to be doing a presentation. On video conference, we have Brenda Gheran, executive director of Northeast Region Community Awareness Emergency Response. We have Iain Bushell, who's chair of Northeast Region Community Awareness Emergency Response and Strathcona County's fire chief. We also have Nadine Blaney, executive director at Fort Air Partnership.

Thank you all for being with us today. We're going to start with the witness statements.

You each have 10 minutes, so there are 30 minutes of witness statements. When you have one minute to go, I'm going to hold up the yellow card, just to give you a warning, so you know where you're at. When we get to the red card, that means you're out of time. Don't just stop, but wrap up your thoughts fairly quickly and concisely. That would be very much appreciated.

We're going to start with John Smol.

John, if you don't mind, the floor is yours.

[Dr. John Smol, Professor and Canada Research Chair in Environmental Change, Queen's University, As an Individual]

Thank you very much, Madam Chair and honourable MPs, for inviting me to join you today. My name is John Smol and I'm a professor at Queen's University, where I also hold the Canada research chair in environmental change.

While I am not an expert on the Canadian Environmental Protection Act, I am someone who has been involved in environmental monitoring and environmental issues in this country for over three decades. I also acknowledge that I seem to be offering more problems than solutions, but recognizing problems is an important first step, I think, to finding solutions to them.

The world has changed a lot since CEPA's inception in 1999 and especially on the environmental front. We have many new challenges, but also new understandings of how ecosystems are being affected by human impacts.

First, I think we have to realize that we have opened a perpetual Pandora's box of new stressors, as we release new problems for the environment to cope with on a daily basis. Many of the new and emerging problems are chemical in nature, which is a major focus of CEPA, but they are also compounded by biological issues, such as exotic species, and physical changes to our environment, such as habitat disturbance and climate change. Many of the effects of these stressors are interactive and additive, or even multiplicative, often resulting in unpredictable interactions leading to even more complex problems. In simple terms, our world is getting more difficult to predict.

I am reminded of the Red Queen's race in Lewis Carroll's Through the Looking-Glass, where the Red Queen and Alice are constantly running but remain in the same spot. In some respects, given the complexity of new environmental issues, standing in the same place might be the most optimistic viewpoint we might have, unfortunately. I feel we are constantly falling behind, despite our efforts. How do we evaluate whether we are falling behind or improving when it comes to the overall environment?

This brings me to my first recommendation. Improve the generally poor state of environmental monitoring in this country. The only way we can know what our baseline conditions are, how our ecosystems are changing, and whether our environmental policies, laws, and regulations are in fact working is to know what is happening in the environment, and that requires effective, evidence-based monitoring.

The situation is complicated when proponents or polluters are authorized to carry out their projects and development on the condition that they self-monitor the effects of their own actions. In my experience, self-monitoring by proponents can often fall well short of the mark because it is typically not subject to peer review, which is the underpinning of legitimacy of all science.

Proponents can turn in thousands of pages of documents without independent and scientific checks, or most importantly, follow-ups to ascertain whether the proponent-based monitoring is effective. In many cases I think it may not be. Of course, I believe in the principle that the polluter pays and that proponents should be paying for the monitoring, but it is the job of independent scientific bodies, like our government, to oversee and scientifically assess these efforts.

I had first-hand experience in investigating one such monitoring program in the oil sands, when I was asked to be part of the six-person oil sands advisory panel back in December of 2010. Yes, monitoring was ongoing and the consultants doing the monitoring were, by and large, doing exactly what they were tasked with, but the scientific underpinnings of what should have been the backbone of the monitoring program had disappeared. A scientific monitoring program needs scientific oversight. The federal government has outstanding scientists who are well prepared for this oversight, perhaps with assistance from universities or other institutes.

Financial considerations are often a quick and easy excuse to cut environmental programs. However, it is well established that it is best, and certainly cheaper, to recognize these environmental problems early. Looking to the past at acid rain, something I was involved in when I was younger, as an example, and since we always worry about how much things cost, it is legitimate to ask whether the acid rain monitoring program was worth it to identify and deal with this problem.

Researchers did such an analysis in 2005 in the United States. They calculated that the cost of monitoring was about one-half a percentage point of compliance costs and less than one-tenth of a percentage point of the estimated health and ecosystem costs. Similarly, the U.S. EPA concluded that the estimated costs of cleaning up industrial groundwater contamination is often 30 to 40 times, and sometimes up to 200 times, greater than the costs associated with simply preventing the contamination from happening in the first place.

It sounds as if monitoring is a bargain. Surely, we can learn from history and realize we should be increasing our environmental monitoring and research. This, however, is not happening.

My second overall point, as I said at the start of this presentation, is that we keep opening new Pandora's boxes, continually developing new stressors and releasing them into the environment before their environmental impacts are sufficiently understood.

CEPA is very chemical-focused and often seeks to control chemicals individually, based on assessing the impacts of individual chemicals in isolation with little regard to their cumulative, interactive, or long-term impacts. Assessing individual chemicals in isolation from other compounds and natural stressors, as well as anthropogenic stressors such as climate change and habitat degradation, is overly simplistic and may create unacceptable environmental risks.

In Europe, the idea of trying to assess and regulate chemicals by considering the environmental mixture and how a new chemical might contribute added toxicity to the chemical soup is emerging as part of their evolving regulatory framework. This might fit well in an updated CEPA.

My third point is that there are certainly more opportunities to improve chemical-based monitoring by bringing in biology, so-called biomonitoring. Biological organisms are excellent indicators of environmental conditions and provide the ability to track not only chemical stressors but the cumulative impacts that have ecological and economic relevance.

It may seem naive for me to recommend increases in the breadth and resources to support enhanced environmental monitoring. But we spend a lot of time talking about how much a new science initiative costs and very little into considering how much inaction costs in the long term if we choose not to avoid or mitigate environmental harm before it occurs.

Universities are not appropriate places to undertake long-term monitoring programs. It is not consistent with our primary research mandates, nor is the tri-council funding structure amenable to supporting long-term monitoring programs. Clearly, monitoring is the domain of our government programs and scientists who can work under national mandates and have access to national networks of environmental laboratories and opportunities to collaborate across departments. In my opinion there are some successful templates of such programs already, perhaps the northern contaminants program, which is celebrating 25 years of activity in 2017.

My fourth point addresses the issue of institutional silos in government. We often hear phrases like “ecosystem management”, which sounds good and makes good press but is not being achieved because it relies on different departments working together, despite having different priorities, different mandates, different legislation, and different programs and budgets.

I want to emphasize that over my career, many of the finest, most dedicated, and hard-working scientists have been in the federal government. This brings me to the last point I have time for; Canada must invest in and support the highly skilled scientists who can actually do the job. To do so effectively will involve continuing with important research programs to fill in gaps in understanding. This new knowledge will allow you legislators to integrate the results of relevant science into the decisions you collectively make in drafting new legislation or amendments or the rigorous science-based decision-making, which is a central premise of this current government.

Canada could and should be leading in both fundamental and applied research. Historically Canada has punched far above its weight in areas such as freshwater and marine science. Not allowing and encouraging government scientists to continue to engage and collaborate in world-class research programs is a waste we cannot afford.

Research gives us options and when it comes to the growing number and importance of major environmental issues we are now facing, we are going to need all the options we can get. In the end, we have to remember the environment does not negotiate. Nature is slow to pardon our mistakes. We need the air, soil, and water. The air, soil, and water does not need us.

Thank you very much.

[The Chair, Liberal, Deb Schulte]

Thank you very much. I really appreciate that testimony.

We will now move to Robert Larocque, and then we'll go to Alberta's Industrial Heartland Association.

[Robert Larocque, Vice-President, Climate Change, Environment and Labour, Forest Products Association of Canada]

Thank you, Madam Chair and members of the committee. Copies of my remarks are available in English for people after the session is over.

My name is Robert Larocque. I'm very pleased to be here to represent the Forest Products Association of Canada as part of your review of the Canadian Environmental Protection Act.

FPAC provides a voice for Canada's wood, pulp and paper producers nationally and internationally in government, trade and in the area we are discussing today—environmental affairs.

Let me give you a quick snapshot of how important the forest products sector is to Canada's economy. It is a $65-billion-a-year industry that represents 2% of Canada's GDP. The industry is one of Canada's largest employers, operating in 200 forest-dependent communities from coast to coast. We directly employ about 230,000 Canadians across Canada.

The sector is also important when it comes to the Canadian environment. As custodians of almost 10% of the world's forests, we take our responsibilities as environmental stewards very seriously. In fact, repeated surveys of international customers have shown that the Canadian forest products industry has the best environmental reputation in the world.

We work very closely with forest communities and take chemical management and public reporting extremely seriously. Our sector is committed to continued environmental improvement. For example, we have eliminated such toxins as nonylphenol and its ethoxylates, as well as PCBs. Both of those were the result of product substitutions. Since 2005 we have also cut water pollutants by 70% and air pollutants by more than 50%. Pulp and paper mills have cut their greenhouse gas emissions by about 60% since 1990.

Canada has the most independently certified forests in the world—about 166 million hectares, or about 43% of all the certified forests across the world. Recently FPAC pledged to remove 30 megatonnes a year of greenhouse gas emissions by 2030. That's about 13% of the government's emissions reduction target There is no question that the Canadian forest products industry is an environmental leader.

As a sector, we feel that the Canadian Environmental Protection Act, or CEPA, largely works well. Except for parts 6 and 9, the rest of CEPA applies to our sector.

For today, I would like to focus my remarks on chemicals management, equivalency agreements and information gathering and sharing.

The Canadian forest products industry supports the chemicals management plan as a leading program globally for the sound management of chemicals. From information-gathering authorities to sound risk assessments to a suite of tools to manage the risks around toxics, CEPA is a sound act that could be improved but should not be overhauled. One of the core principles in the chemicals management plan is the need to balance hazard and risk. Risk assessments under the act are based on scientifically credible information that considers hazards such as carcinogenicity, vulnerable populations such as Canadians with asthma, and exposure in terms of whether Canadians are exposed. This is extremely important.

The flexible risk managements tools of regulations, codes of practice, and guidelines under the act protect against the release of toxic elements into the environment as well as their use in products and processes. Our sector has demonstrated that the flexible risk management instrument can work, and should be maintained. The forest sector wants to make sure that the people who live in our communities and Canadians are well protected.

I will make a few comments on equivalency agreements. In order for our facilities to operate, they all have permits from the provinces that regulate their processes, including air and water emissions. We all know that the environment is an area that crosses federal and provincial jurisdictions, and environmental matters often require intergovernmental co-operation. For example, there are already equivalency agreements between Ottawa and Alberta regarding two CEPA regulations for pulp and paper mills. Maintaining the option of equivalency agreements in CEPA is key to minimizing regulatory duplication and administrative burdens. However, we do feel that equivalency agreements are not used often enough. CEPA should be modified to ensure easier implementation of equivalency agreements between the federal and provincial governments.

The last area I would like to address has to do with information gathering and sharing. The forest sector works hard to provide accurate information to government. As an example, our sector has taken advantage of the flexibility under the section 71 survey notices to provide voluntary information to Environment Canada and Health Canada. After two years of implementation, this flexibility has saved our sector about $1 million a year in reporting requirements.

One area where CEPA could be improved is requiring chemical suppliers to provide more accurate and timely information to the users of those substances. Too often we have seen companies use section 313 of the act to request that all information sent to Environment Canada and Health Canada be considered confidential. It is very difficult, as a sector, to take actions to address potential toxins at our mills if we don't even know which potential toxins our facilities are using.

In conclusion, we think that CEPA is working well as Canada remains a world leader in chemical management. There can always be improvement—for example in ensuring flexibility and taking into account provincial legislation. However, this can be done by minor tweaks; there is no need to overhaul the legislation.

Thank you for your attention and I welcome your questions.

[The Chair, Liberal, Deb Schulte]

Thank you very much. We really appreciate that.

We're going to hear from one more group, and then we'll open the floor to questions.

I'm going to turn it over to Councillor Gibbons and Pam Cholak. I'm not sure if you're going to do five minutes and five minutes, so I'll leave it between the two of you for the 10 minutes.

[Pam Cholak, Director, Stakeholder Relations, Alberta's Industrial Heartland Association]

Thank you.

[Ed Gibbons, Councillor, City of Edmonton, and Chair, Alberta's Industrial Heartland Association]

Thank you, Madam Chair and honourable committee members.

On behalf of the Alberta's Industrial Heartland Association's board of directors, thank you for providing the industrial heartland association and our partners in the industrial heartland region the opportunity to present to you and share our views and our experiences with you during the review of the Canadian Environmental Protection Act.

My name is Ed Gibbons. As mentioned, as a municipal councillor for the City of Edmonton, I'm also the chair of the industrial heartland association. Joining me today in Ottawa is Pam Cholak, director of stakeholder relations for Alberta's Industrial Heartland Association.

We are appreciative to the committee for including via videoconference in Edmonton representatives from two of our five partner organizations in Alberta's Industrial Heartland Association.

I will turn it over to Pam, and I would like to thank those on the video for coming in as well.

Thank you.

[Pam Cholak]

Thank you, Ed, and thank you, Madam Chair, and honourable members.

I'm going to continue the remarks by saying the Northeast Region Community Awareness Emergency Response— a mouthful, but it's also known as NRCAER for those of us who know it well—is a mutual aid, emergency response association with a 25-year history of collaborating for safe, informed, and prepared communities. Their members include 30 local industries and eight municipalities, which form a best-practice network of emergency management professionals. They are the organization that coordinates and executes emergency planning and protocols in Alberta's industrial heartland. The organization is represented today by the chair, and Strathcona County fire chief, Iain Bushell, and by executive director, Brenda Gheran, both of whom should be considered Canadian experts in emergency preparedness.

Thank you for coming here today.

Also participating today, as you know, via video is our Fort Air Partnership executive director, Nadine Blaney. The Fort Air Partnership, or FAP to those of us who know it well, is an independent, multistakeholder, air monitoring organization, or airshed, that monitors air quality in and around Alberta's industrial heartland. This organization is a collaborative effort between provincial, federal, and municipal governments, industry, and communities. It is a model to emulate.

Fort Air Partnership collects the air quality data required to calculate the air quality health index. This data is also used to compare provincial and federal air quality standards, including the recently implemented Canadian ambient air quality standards. Fort Air Partnership works closely with the Alberta provincial government and other airsheds in Alberta to implement regional monitoring to inform cumulative effects management of air quality. We should be proud of it as Canadians.

Directly related to the Canadian Environmental Protection Act, the Fort Air Partnership completed a volatile organic compounds monitoring project in collaboration with Environment Canada in 2006. The Fort Air Partnership has also initiated a volatile organic compounds speciation study in a community within our heartland and will be initiating a fine particulate matter speciation study in 2017, both of which are expected to be completed, and results shared with the government and public, in the next three years. The details of these studies can be provided to this committee as a follow-up to this presentation.

Both Northeast Region Community Awareness Emergency Response—and I'm going to refer to that as NRCAER—and our FAP activities are impacted by the Canadian Environmental Protection Act, making their inclusion today beneficial to your deliberations. It is our hope that you will engage them directly in the questions after our overview remarks.

Environmental stewardship, emergency preparedness, air quality monitoring, municipal co-operation, and direct communication with residents regarding their health and safety as it relates to industrial development in our region, are all vital activities through the Alberta industrial heartland and its communities.

Let me tell you a little bit more about who we are, how environmental legislation, including this act and the processes it outlines, impact collaboration in our region, and how changes to the legislation that are intended to improve the health of Canadians can have unintended consequences.

Alberta's Industrial Heartland Association is a municipal not-for-profit organization focused on attracting and retaining sustainable industrial development in a specialized industrial region encompassing eight municipalities and covering over 582 square kilometres of land. This region is known as Alberta's industrial heartland. Membership is comprised of five regional municipalities: the City of Edmonton, the City of Fort Saskatchewan, Strathcona County, Sturgeon County, and Lamont County.

In addition, Alberta's Industrial Heartland Association has three associate municipal members, including the Town of Redwater, the Town of Bruderheim, and the Town of Gibbons. Collectively, our membership represents over 1.2 million residents. It is not insignificant.

For the past 18 years, our association has taken a proactive and co-operative approach to planning for industrial developments in the region. A leading principle of our association is promoting responsible, sustainable development within the region. This requires collaborative regional planning for infrastructure, services, emergency preparedness, and land use that is guided by the principles of environmental stewardship, sustainable community growth, and economic prosperity.

Our association is a model of collaboration, partnership, and synergistic operations that balance protection of our environment with sustainable resource and community development. We encourage public policy frameworks, like this act, that contribute to attainment of these goals.

Alberta's industrial heartland is Canada's largest hydrocarbon processing region and western Canada's energy hub. It is home to a synergistic industrial cluster encompassing over 40 companies that represent investment worth over $30 billion in energy and petrochemical processing facilities. Companies operating in the industrial heartland representing mid- and downstream sectors provide 6,500 full-time jobs and an additional 23,000 indirect jobs, and account for $1.5 billion annually in local spending, with additional monies in charitable giving directly benefiting our communities. These companies are also engaged directly in air quality monitoring with heartland partners, which is important to our residents and the sustainability of our communities.

In a 2015 poll of 400 residents in the area, nearly three-quarters of the residents in our region said they follow industrial activity closely or somewhat closely. It is important to residents to be informed about the industry and the environment. We do have a not-for-profit initiative called “Life in the Heartland”, which provides information and improves communication with residents about industrial operations and development in Alberta's industrial heartland. It is a partnership of five organizations, including those represented here today, plus the heartland industry association, the Northeast Capital Industry Association.

Industry, municipalities, our air monitoring agency, and emergency response recognize the value of keeping the local community informed. This collaborative effort, formed without regulatory requirement, serves as a best practice model for other regions.

It's also important to residents that the environment is being properly managed to allow for responsible and sustainable industrial growth that does not impede their health or quality of life. When asked to rate the air quality in the region in which they live, almost 60% of the respondents ranked it as excellent or good, while 29% ranked it as average. This means that only 13% ranked air quality below average, which is an indicator of success, given the 40 companies operating. It means that innovation and environmental practices in the region are working.

Today we want to highlight the importance of clarity and certainty of regulation as critical for future investment that helps to build the sustainable thriving communities in which we live and operate. Business investment will be attracted to Canada and regions like ours if regulatory processes, such as those currently outlined by the Canadian Environmental Protection Act, remain clearly defined and consistent in application across jurisdictions and are not at risk of continual change. Due process is important to investors, to our companies, and to our region, and this act provides a fair, effective public policy framework for environmental oversight.

Definitions within the act do need to be clear so that expectations and outcomes of regulatory processes can be clear both to the capital investor and to the public. We also believe that regulation language should take into account—as well as foster—multi-agency collaboration and co-operation. In the case of emergency response, for example, it would be helpful to have clarity and language consistency when defining exercise types and schedules in the act.

While regulation is critical to risk management through the establishment of standards, not all positive actions necessarily result from regulatory requirements. Our heartland is a world-class example of successful collaboration and co-operation among many stakeholders who are motivated by a collective issue: mitigating risk to our environment for the protection of public health. While the act serves a critical function, it should be noted that it has not prescribed all of the efforts spent on environmental monitoring and innovation. If this act becomes too prescriptive and cumbersome because of unnecessary reporting, resources can be stretched, and we risk stifling the innovation and multi-agency collaboration that will move us to improvement.

We also need to consider the unintended consequences of regulatory change. Lack of timely decisions and the threat of changing regulatory frameworks result in an investment community that is tentative to engage in our Albertan and Canadian markets. Regulation change can be well intentioned, but if there's not some certainty on process and timelines and a recognition of that, the reliability of our regulatory framework is jeopardized.

To be clear, we are not advocating for a reduction in appropriate environmental regulations that establish important standards for the protection of our communities and the health of people who reside within them. We need to be clear, however, in the requirements we ask for, the manner in which the data is utilized, and the timeliness of change.

We appreciate the opportunity to be here today, and we look forward to the questions to come.

[The Chair, Liberal, Deb Schulte]

Thank you very much. I'm sorry for rushing you at the end. It's all good testimony.

First, before questions, I want to introduce MP Robert Morrissey. Thank you very much for standing in for Mike Bossio. Welcome, Garnett Genuis. Who else is here? I think Jonathan just stepped out, but he's here as well.

We'll get into questions, starting with Mr. Gerretsen.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

Thank you very much, Madam Chair.

Welcome to the witnesses who have come forward today, in particular Professor Smol. It's always nice to see people here from the best riding in the country.

Professor, I'm curious if you were involved in either of the other two reviews that were done for CEPA in the late nineties or early 2000s.

[Dr. John Smol]

No, I wasn't.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

Okay.

You did talk a little about your involvement in the acid rain movement.

[Dr. John Smol]

Yes, sir.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

Can you provide a bit of your experience on that, and if you see any relationship between that and CEPA?

[Dr. John Smol]

Yes.

I cut my teeth on acid rain; I was quite young when I was doing that work. I see many similarities between acid rain.... I think it's useful to go back in history and see how things change. Acid rain was an example where the first phase was, there is no problem. The second phase was, there is a problem but it's not our fault. The third phase was, it is a problem, it's our fault, there's nothing much we can do about it.

That's the danger in a lot of environmental work. Often you can go past a certain threshold and then getting the solution is very difficult. That's why I stress the monitoring. I think acid rain in many ways was a relative success story but not a 100% success story. With monitoring, with the proper research, we were able to find a solution and deal with the problem.

I think there are lessons to be learned from acid rain that we can use in many of the other things that CEPA is involved in.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

You talk about monitoring and self-monitoring. I'm curious if you can provide a little more insight into that. For instance, to what extent do you see people who would be self-monitoring versus your more traditional regulatory monitoring?

[Dr. John Smol]

To some extent I might bring my work when I was on the six-person panel to look at the monitoring going on in the oil sands, for example, which Liz Dowdeswell reported in 2010.

There are issues. A monitoring program requires a scientific base to be totally transparent, and also to be flexible, because science changes as it goes forward. What we saw in a monitoring program such as that is that consultants and so forth were doing pretty well what they were tasked to do, but there wasn't sufficient scientific oversight to determine if we were getting worthwhile answers. A lot of money is being wasted in some of these monitoring programs.

Many people get these results. They talk about getting binders and binders of data but they're never analyzed and they're never critically assessed. The effort is not put into seeing what the monitoring has done.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

I think I understand correctly, but do you think that self-monitoring would be more compliant?

[Dr. John Smol]

My argument would be that I believe in polluter pays but not necessarily that the polluter does the monitoring. I think independent oversight is often critical to assess what is happening in the environment.

[Mark Gerretsen, Liberal, Kingston and the Islands, ON]

Okay. I think I understand you a little better.

CEPA currently takes the risk-based approach. We've heard a lot of discussion about moving to a hazard-based approach. Can you provide your input into that?