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1999 Report of the Commissioner of the Environment and Sustainable Development

1999 Report—Observations

Appendix A—Environmental and Sustainable Development Work by the Office of the Auditor General, 1998

Reference	Key Conclusions
National Energy Board, Chapter 13	The Board's ability to fully meet its environmental regulatory responsibilities is at risk due to shortfalls in its environmental inspection program - namely, in setting priorities and scheduling inspections and in inspection practices, which are too informal and unstructured. (paragraph 13.3)
The Federal Science and Technology Strategy: A Review of Progress, Chapter 22	In our opinion, the management of climate change science to this point does not reflect fully the intent of the commitments made in the Federal Science and Technology Strategy. The government has recognized that a more concerted approach is needed to optimize resources and co-ordinate research at the federal level and across all sectors, especially in view of its Kyoto commitments. We believe that the proposed approach holds the promise of improved management of this horizontal issue. (Case study - Management of Federal Activities in Climate Change Science)
Transport Canada - Investments in Highways, Chapter 25	Transport Canada should demonstrate due diligence in the management of environmental screenings of projects under highway investment programs, backed by an appropriate management information system that would facilitate compliance with environmental laws. Such a system should include a mechanism for monitoring unanticipated environmental effects in order to improve the screening process in future environmental assessments. (paragraph 25.116)
Follow-up of Recommendations in Previous Reports, Chapter 28
Emergency Preparedness in the Federal Government - Nuclear Emergencies - 1992, Chapter 24	Health Canada is not in a position to effectively co-ordinate and respond to a major nuclear accident affecting Canada. (paragraph 28.2)
Public Works and Government Services Canada - Northumberland Strait Crossing Project - 1995, Chapter 15	Based on our review, we conclude that since the time of our original audit, the government has been managing the project's environmental aspects appropriately. (paragraph 28.67)
The Implementation of Federal Environmental Stewardship - 1996, Chapter 2	It is not clear whether the Code of Environmental Stewardship is still in place for those agencies not required to produce a sustainable development strategy and there is also a need to involve Crown corporations in the government's greening efforts. (paragraph 28.2)
Federal Contaminated Sites - Management Information on Environmental Costs and Liabilities - 1996, Chapter 22	While limited progress has been made in specialized areas, the federal government, the largest landholder in Canada, still does not have a comprehensive view of the potential risks to health, safety and the environment associated with its more than 5,000 contaminated federal sites identified at the time of our November 1996 chapter. Nor does it yet have a complete and accurate view of the related contingent or actual liabilities. (paragraph 28.245)
Canadian Heritage - Parks Canada - Preserving Canada's Natural Heritage - 1996, Chapter 31	While no new parks have been created since 1996, work is continuing toward completing the national parks system. However, it is becoming increasingly clear that the system will not be complete by the year 2000. Although work is also under way to create new marine conservation areas, Parks Canada has not created any new areas since 1990. (paragraph 28.340)

Appendix B

Summary of Petitions Received*

* Petitions 1 to 7 were included in our 1998 Report.

Subject of Petition	Petitioner	Federal Department	Date of Petition	Date Response Received	Response
8. Effects of ozone depletion. The petitioner requested information on the actions government departments would take over the next five years to protect the health and livelihoods of Canadians from the effects of ozone depletion. In particular, the petitioner requested specific budgeted commitments with targets and time frames for conduct of research on the health and environmental impacts of increased UV radiation and on the nature of protective measures to be taken. The petitioner also sought information on Canada's continued commitment to the development of policy and implementation measures under the Montreal Protocol in developing countries. In addition, the petitioner requested information on enforcement of laws prohibiting the import and export of ozone-depleting substances.	Friends of the Earth	Fisheries and Oceans Canada	8 September 1997	19 January 1998	The Minister of Fisheries and Oceans indicated that the Department had commissioned a study to provide baseline information on UV-B radiation and its effects on commercially important crustaceans and fishes. Fisheries and Oceans also collaborates under a Memorandum of Understanding with Environment Canada, Natural Resources Canada and Agriculture and Agri-Food Canada for co-ordination in the use of science and technology for sustainable development.
		Agriculture and Agri-Food Canada		23 March 1998	Agriculture and Agri-Food Canada provided information on research on impacts on crop production of UV-B radiation carried out until the end of Green Plan funding in 1997. The Department was actively investigating alternatives to methyl bromide, the ozone-depleting substance used in a significant way by the agricultural community. These activities would continue until 2005, when methyl bromide is targeted for 100% phase-out of use by developed countries.
		Environment Canada		21 May 1998	The Minister identified a number of departmental activities related to ozone depletion and increased UV radiation, including: stratospheric ozone monitoring, science research, public awareness, negotiations with foreign governments, multilateral funding and the development and administration of federal control measures for ozone-depleting substances.
		Health Canada		1 June 1998	The Minister stated that information on spending trends over the last five years was difficult to obtain and document completely because research and public information initiatives undertaken by the Department in relation to the health effects of UV radiation are included in other program components. Within Health Canada there had been no major recent research or information initiatives dealing specifically with UV radiation, and at this time none were planned. It was not possible to predict the budget commitments for the conduct of research on the health and environmental impacts of UV radiation to be undertaken over the next five years, due to prioritization and the pending renewal of some programs.
		Natural Resources Canada		8 June 1998	The Minister provided a summary of activities and estimated budgets for the mitigation of climate change and ozone-depleting substances. The Department's activities to reduce ozone-depleting substances and to mitigate the effects of global change involve its physical operations, program activities and work with other government departments in the following areas: research on health and environmental impacts of increased UV radiation, development of policy and implementation of measures pursuant to the Montreal Protocol, enforcement of laws and activities to protect Canadians from the cumulative effects of global change.
9. Multilateral Agreement on Investment. The petitioner expressed concerns about the uncertain effects of the Multilateral Agreement on Investment on social equity, environmental protection, public health protection and sustainable development; and asked for clarification of the terms of reference and objectives of the agreement with respect to these issues.	Canadian Association of Physicians for the Environment	Environment Canada	14 January 1998	17 August 1998	The Minister explained that the Minister of Foreign Affairs and International Trade was responsible in the Government of Canada for negotiation of the agreement. Environment Canada officials had been working with officials from the Department of Foreign Affairs and International Trade to ensure that the agreement would not infringe on the right of governments to maintain and enforce strong, effective environmental regulations.
		Department of Foreign Affairs and International Trade		22 May 1998	The Minister stated that Canada stands to benefit from a good and fair set of rules for international investment. Canada has a long history as a champion of the rules-based international trade and investment system. The government was committed to ensuring that an agreement would in no way limit Canada's ability to maintain, promote and enforce our high environmental standards. The government would not sign any agreement unless it advanced and protected our national interests and values.
10. Harmonization Accord. The petitioner requested the Minister of the Environment not to sign the Canada-wide Accord on Environmental Harmonization. The petitioner alleged that the Accord would lead to the devolution of federal roles and responsibilities for the environment to the provinces and hence be inconsistent with sustainable development.	Canadian Environmental Law Association	Environment Canada	22 January 1998	19 May 1998	The Minister informed the petitioner that the federal government had decided to proceed with signing the Accord and related sub-agreements, a decision that the petitioner subsequently challenged in the Federal Court. The concerns raised in the petition were substantially the same as those raised in the legal challenge. The detailed response to the petition was contained in the affidavits filed by the federal government. The Minister also forwarded the government response to the concerns raised by the Standing Committee on Environment and Sustainable Development in its report on harmonization, and indicated that federal, provincial and territorial ministers of the environment had promised to report openly on progress and to review the Accord with the public after two years to ensure it was achieving results.
11. Crown Obligations to First Nations . The petitioners stated that they had been pursuing a claim for the past six years with Indian and Northern Affairs Canada alleging that the Crown was in breach of its common law, statutory, constitutional and fiduciary obligations to the First Nation by enabling and permitting BC Hydro to construct and operate the WAC Bennett Dam in a manner that permanently destroyed the environment of Indian Reserve 201 and a major source of economic opportunity for the First Nation. The petitioners claimed that the Government of Canada and BC Hydro had in effect destroyed their reserve, and in particular the habitat base for the wildlife on which they relied to earn a substantial living from hunting and trapping. The damage to the reserve was continuing without any effort at remediation or compensation by Canada or BC Hydro.	Athabasca Chipewyan First Nation	Indian and Northern Affairs Canada	4 May 1998	10 August 1998	The Minister requested an extension in providing a reply because the petition was the subject of litigation involving the Government of Canada. Officials of the Department would review the file in six months to determine if a more detailed response would be appropriate at that time.
12. Environmental Assessment . The petitioner requested an investigation of environmental issues in the Petitcodiac River Valley of New Brunswick resulting from actions of the federal departments of Environment and Fisheries and Oceans. The petitioner alleged that the federal ministers had acted improperly in obtaining provincial agreement for the trial opening of the Petitcodiac River Gates and that federal public servants had misrepresented information relating to the gate opening experiment and the environmental screening associated with it. The petitioner also requested a full-scale independent environmental assessment of the proposed trial opening and that concerned citizens be able to respond to it.	Lake Petitcodiac Preservation Association	Fisheries and Oceans	15 May 1998	11 December 1998	The Minister responded that both Fisheries and Oceans and Environment Canada were dedicated to the conservation and sustainability of Canadian resources and take appropriate steps to fulfil this responsibility. The Petitcodiac River situation was a good example of an opportunity to restore the productivity of an aquatic system in support of several valuable fisheries resources. The Province had invited both federal departments into this endeavour through a Memorandum of Understanding, and both had participated on terms acceptable to the Province. The Minister indicated that the public servants involved with various aspects of this project had carried out their duties in a responsible and professional manner. They continue to promote open and objective discussions and exchanges with all stakeholders, and to consider all available information in a scientific and objective way. The Minister also stated that the authors of the 19 May 1998 screening report had exercised their duties with the same scientific objectivity that would be expected of any expert assessing a project under the Canadian Environmental Assessment Act (CEAA) process, and that the public, environmental, social, economic, health and safety concerns had been adequately considered.
					The Minister also stated that federal departments had voluntarily undertaken an environmental assessment screening of the trial gate opening, without prejudice to the proceedings in the Federal Court, and had followed the process outlined in the CEAA. Extensive consultations were carried out prior to the preparation of the screening report in 1998; consultations will also take place prior to the preparation of the screening report for the proposed 1999 trial gate opening. The 1999 Environmental Assessment screening report would then be released to the public to allow concerned citizens an opportunity to comment.
13. Environmental Assessment. The petitioner indicated difficulties with the environmental assessment process as administered by Fisheries and Oceans Small Craft Harbours. The petitioner sought assurance that the project's environmental assessment had been conducted properly and in accordance with the Canadian Environmental Assessment Act . In particular, the petitioner was concerned with the construction of breakwalls in Lake Simcoe and their environmental and coastal impacts, that mitigation measures had not been properly implemented and that comments made by him and other opponents of the project had been overlooked.	Scott Williamson	Fisheries and Oceans	29 June 1998	22 July 1998	The Minister replied that the comments made by the petitioner and other opponents of the project had not been overlooked in the Department's review of the project. The Town of Georgina had consulted the public and sought approvals from regulatory agencies. In addition, regional officials referred the issues to expert departments for guidance. It was concluded that significant environmental effects were unlikely, taking into account the mitigation measures proposed. As a result, the Town was authorized to proceed with the project. An environmental screening was completed and is available for viewing along with all related records produced, collected or submitted.
14. Use of Science . The petitioner alleged that the science in the 1998 coho conservation plan was distorted. Specifically, the strategy of designating no-fishing Red Zones and selective-fishing Yellow Zones contradicted advice from Fisheries and Oceans scientists and its sustainable development guiding principles. As a consequence, the coho stocks would be damaged and small-boat salmon fishers would have their salmon allocations redistributed to American fishers and the corporate fleet.	West Coast Sustainability Association	Fisheries and Oceans	15 July 1998	16 November 1998	The Minister responded that scientific input into the management process was transparent. Stock assessments and pre-season forecasts were reviewed through the Pacific Stock Assessment Review Committee and made available to all those consulted. The decision was based on scientific advice from within the Department and on the information collected through public meetings. The Minister indicated that conservation of the resource was placed ahead of allocation requirements among commercial fishing sectors. Fish management plans for 1998 required severe cutbacks in fishing opportunity for all sectors, and that year was identified as the beginning of a serious downturn in the fisheries. As a consequence, the federal government announced funding to rebuild the resource, to restructure the Pacific fishery, and to help people and communities adjust to the changes in it. The federal government also committed resources to assist those who would be affected by the conservation measures being implemented and by the long-term restructuring of the Pacific salmon fishery. The funding would be targeted to programs to assist Aboriginal, commercial, and recreational participants in the fishery.
15. Environmental Assessment. The petitioner requested an investigation of matters relating to the construction of a dam in the headwaters of the Englishman River system on Vancouver Island. The Regional District of Nanaimo, the City of Parksville and the Town of Qualicum Beach were constructing the dam as a joint venture. The petitioner alleged that despite federal jurisdiction, Fisheries and Oceans had issued no approval or permit; and it was essential to have environmental impact studies done on the downstream impacts of the dam.	Society for the Preservation of the Englishman River Estuary	Fisheries and Oceans	22 July 1998	27 November 1998	The Minister acknowledged that no permits or approvals had been issued for this project. The Canadian Coast Guard had determined that the Navigable Waters Protection Act did not apply in this case and thus no permit was required. In the case of the Fisheries Act , authorization would have been appropriate in advance of the completion of the project. However, the Department was satisfied that the proponent took appropriate steps during construction to protect fisheries resources both upstream and downstream. The Department determined that the project would create major benefits to the fisheries resources in the Englishman River, downstream of the dam, by providing increased summer stream flows. Provincial Ministry of Environment, Lands and Parks officials had determined that with mitigation measures implemented during construction, and with habitat compensation, the project would result in significant benefits to non-salmon fish habitat within the Englishman River watershed, both upstream and downstream of the dam. The Department agreed with this assessment.
16. Environmental Assessment. The petitioner alleged that Fisheries and Oceans had conducted an inadequate environmental assessment of the harbour project at Jackson's Point, Lake Simcoe, Ontario.	Lakewatch Society - Lake Simcoe	Fisheries and Oceans	11 August 1998	3 September 1998	The Minister indicated that regional officials in Burlington had responded directly to the petitioner's concerns with respect to the environmental screening conducted for this project. A copy of the reply was attached as reference. The Minister encouraged interest in this project and invited the petitioner to liaise with regional officials in Burlington if he wished to discuss the project further.
17. Environmental Assessment. The petitioner requested that an environmental assessment be conducted to identify problems before additional development of the Farewell and Black creeks watershed proceeded and to assist them with the protection and rehabilitation of the fishery and habitat. The petitioner wanted the health of the watershed and ecosystem to be returned to its former state.	Friends of the Farewell	Fisheries and Oceans	23 July 1998	23 November 1998	The Minister emphasized the Department's commitment to the protection and rehabilitation of fish habitat through the habitat protection provisions of the Fisheries Act , the Policy for the Management of Fish Habitat and the departmental Habitat Conservation and Protection Guidelines. The Minister indicated that harmful alteration, disruption or destruction of fish habitat is prohibited under subsection 35(1) of the Fisheries Act . Official plans and zoning changes do not, in themselves, meet that condition. An offence occurs only after there has been harmful alteration, disruption or destruction of fish habitat that was not authorized by the Minister. The Department was providing input to an updated Provincial Stormwater Management Manual to clarify responsibilities under the Fisheries Act , the Policy and the Guidelines to ensure that they were addressed in new planning and development in Ontario. The Department understood that cumulative impacts of development over the past two decades had resulted in some impacts on fish and fish habitat in Farewell and Black creeks. It believed that participation in fisheries management planning would help to ensure that fisheries interests and responsibilities would be incorporated into the review process, and would in future guide resource managers in identifying areas for habitat rehabilitation and areas for habitat protection.
18. Forestry. The petitioner expressed concern over the Indian and Northern Affairs Canada decision to recommend an allowable timber cut in the Nisutlin Management Area of up to 89,000 cubic metres for the next 400 years. Historically the cut had been 2,000 cubic metres annually. The Petitioners alleged that this decision was made without proper consultation with the citizens of Teslin, and in contravention of the Yukon First Nations Umbrella Final Agreement and the Teslin Final Agreement.	Richard and Brenda Oziewicz	Indian and Northern Affairs Canada	1 September 1998	26 November 1998	The Minister replied that the Department's release of the Timber Supply Analysis for those areas where inventory work had been undertaken was done to establish a starting point for ongoing consultations. Assumptions were made to determine the forested area and volume that could be sustainably harvested in conjunction with an ongoing reforestation program. The purpose of the consultation was to challenge those assumptions, allow for other assumptions based upon local input and ultimately revise the supply volume estimates. The Department needed to know what the maximum annual allowable cut was for each area in order to know the sustainable level. The Minister assured the petitioner that the Department was aware of its obligations to consult all Yukon First Nations, and that it would not promote over-harvesting.
19. Enforcement . The petitioner requested an investigation of the non-enforcement of environmental protection legislation by the federal departments of Fisheries and Oceans and Environment Canada, concerning past and ongoing operations of the Pine Falls Paper Company in Pine Falls, Manitoba.	Alice Chambers	Fisheries and Oceans and Environmen t Canada	30 November 1998	pending

* Petitions 1 to 7 were included in our 1998 Report.

Appendix C

Auditor General Act - Excerpts

An Act respecting the Office of the Auditor General of Canada and sustainable development monitoring and reporting
	INTERPRETATION
Definitions	2. In this Act,
"appropriate Minister"	"appropriate Minister" has the meaning assigned by section 2 of the Financial Administration Act ;
"category I department"	"category I department" means
	(a) any department named in Schedule I to the Financial Administration Act , (b) any department in respect of which a direction has been made under subsection 24(3), and (c) any department, as defined in the Financial Administration Act , set out in the schedule;
"Commissioner"	"Commissioner" means the Commissioner of the Environment and Sustainable Development appointed under subsection 15.1(1);
"sustainable development"	"sustainable development" means development that meets the needs of the present without compromising the ability of future generations to meet their own needs;
"sustainable development strategy"	"sustainable development strategy", with respect to a category I department, means the department's objectives, and plans of action, to further sustainable development.
	DUTIES
Examination	5. The Auditor General is the auditor of the accounts of Canada, including those relating to the Consolidated Revenue Fund and as such shall make such examinations and inquiries as he considers necessary to enable him to report as required by this Act.
Idem	6. The Auditor General shall examine the several financial statements required by section 64 of the Financial Administration Act to be included in the Public Accounts, and any other statement that the President of the Treasury Board or the Minister of Finance may present for audit and shall express his opinion as to whether they present fairly information in accordance with stated accounting policies of the federal government and on a basis consistent with that of the preceding year together with any reservations he may have.
Annual and additional reports to the House of Commons	7. (1) The Auditor General shall report annually to the House of Commons and may make, in addition to any special report made under subsection 8(1) or 19(2) and the Commissioner's report under subsection 23(2), not more than three additional reports in any year to the House of Commons
	(a) on the work of his office; and, (b) on whether, in carrying on the work of his office, he received all the information and explanations he required.
Idem	(2) Each report of the Auditor General under subsection (1) shall call attention to anything that he considers to be of significance and of a nature that should be brought to the attention of the House of Commons, including any cases in which he has observed that
	(a) accounts have not been faithfully and properly maintained or public money has not been fully accounted for or paid, where so required by law, into the Consolidated Revenue Fund;
	(b) essential records have not been maintained or the rules and procedures applied have been insufficient to safeguard and control public property, to secure an effective check on the assessment, collection and proper allocation of the revenue and to ensure that expenditures have been made only as authorized; (c) money has been expended other than for purposes for which it was appropriated by Parliament; (d) money has been expended without due regard to economy or efficiency; (e) satisfactory procedures have not been established to measure and report the effectiveness of programs, where such procedures could appropriately and reasonably be implemented; or (f) money has been expended without due regard to the environmental effects of those expenditures in the context of sustainable development.
	STAFF OF THE AUDITOR GENERAL
Appointment of Commissioner	15.1 (1) The Auditor General shall, in accordance with the Public Service Employment Act , appoint a senior officer to be called the Commissioner of the Environment and Sustainable Development who shall report directly to the Auditor General.
Commissioner's duties	(2) The Commissioner shall assist the Auditor General in performing the duties of the Auditor General set out in this Act that relate to the environment and sustainable development.
	SUSTAINABLE DEVELOPMENT
Purpose	21.1 The purpose of the Commissioner is to provide sustainable development monitoring and reporting on the progress of category I departments towards sustainable development, which is a continually evolving concept based on the integration of social, economic and environmental concerns, and which may be achieved by, among other things,
	(a) the integration of the environment and the economy; (b) protecting the health of Canadians; (c) protecting ecosystems; (d) meeting international obligations; (e) promoting equity; (f) an integrated approach to planning and making decisions that takes into account the environmental and natural resource costs of different economic options and the economic costs of different environmental and natural resource options;
	(g) preventing pollution; and (h) respect for nature and the needs of future generations.
Petitions received	22. (1) Where the Auditor General receives a petition in writing from a resident of Canada about an environmental matter in the context of sustainable development that is the responsibility of a category I department, the Auditor General shall make a record of the petition and forward the petition within fifteen days after the day on which it is received to the appropriate Minister for the department.
Acknowledgement to be sent	(2) Within fifteen days after the day on which the Minister receives the petition from the Auditor General, the Minister shall send to the person who made the petition an acknowledgement of receipt of the petition and shall send a copy of the acknowledgement to the Auditor General.
Minister to respond	(3) The Minister shall consider the petition and send to the person who made it a reply that responds to it, and shall send a copy of the reply to the Auditor General, within
	(a) one hundred and twenty days after the day on which the Minister receives the petition from the Auditor General; or (b) any longer time, where the Minister personally, within those one hundred and twenty days, notifies the person who made the petition that it is not possible to reply within those one hundred and twenty days and sends a copy of that notification to the Auditor General.
Multiple petitioners	(4) Where the petition is from more that one person, it is sufficient for the Minister to send the acknowledgement and reply, and the notification, if any, to one or more of the petitioners rather than to all of them.
Duty to monitor	23. (1) The Commissioner shall make any examinations and inquiries that the Commissioner considers necessary in order to monitor
	(a) the extent to which category I departments have met the objectives, and implemented the plans, set out in their sustainable development strategies laid before the House of Commons under section 24; and (b) the replies by Ministers required by subsection 22(3).
Commissioner's report	(2) The Commissioner shall, on behalf of the Auditor General, report annually to the House of Commons concerning anything that the Commissioner considers should be brought to the attention of that House in relation to environmental and other aspects of sustainable development, including
	(a) the extent to which category I departments have met the objectives, and implemented the plans, set out in their sustainable development strategies laid before that House under section 24; (b) the number of petitions recorded as required by subsection 22(1), the subject-matter of the petitions and their status; and (c) the exercising of the authority of the Governor in Council under any of subsections 24(3)to (5).
Submission and tabling of report	(3) The report required by subsection (2) shall be submitted to the Speaker of the House of Commons and shall be laid before that House by the Speaker on any of the next fifteen days on which that House is sitting after the Speaker receives it.
Strategies to be tabled	24. (1) The appropriate Minister for each category I department shall cause the department to prepare a sustainable development strategy for the department and shall cause the strategy to be laid before the House of Commons
	(a) within two years after this subsection comes into force; or (b) in the case of a department that becomes a category I department on a day after this subsection comes into force, before the earlier of the second anniversary of that day and a day fixed by the Governor in Council pursuant to subsection (4).
Updated strategies to be tabled	(2) The appropriate Minister for the category I department shall cause the department's sustainable development strategy to be updated at least every three years and shall cause each updated strategy to be laid before the House of Commons on any of the next fifteen days on which that House is sitting after the strategy is updated.
Governor in Council direction	(3) The Governor in Council may, on that recommendation of the appropriate Minister for a department not named in Schedule I to the Financial Administration Act , direct that the requirements of subsections (1) and (2) apply in respect of the department.
Date fixed by Governor in Council	(4) On the recommendation of the appropriate Minister for a department that becomes a category I department after this subsection comes into force, the Governor in Council may, for the purpose of subsection (1), fix the day before which the sustainable development strategy of the department shall be laid before the House of Commons.
Regulations	(5) The Governor in Council may, on the recommendation of the Minister of the Environment, make regulations prescribing the form in which sustainable development strategies are to be prepared and the information required to be contained in them.

Appendix D

Panel of Advisors to the Commissioner of the Environment and Sustainable Development

David Barron
Senior Vice President, Environment, Resources and Technology
Canadian Pulp and Paper Association, Montreal, Que.

Randy C. Billing
President
Ernst & Young Environmental Services Inc., Toronto, Ont.

Yves Gauthier
Partner (Environmental Services)
KPMG, Montreal, Que.

Chris Henderson
Chief Executive Officer
The Delphi Group, Ottawa, Ont.

Tony Hodge
Environmental Consultant
Victoria, B.C.

Susan Holtz
Environmental Consultant
Ferguson's Cove, N.S.

Claude-André Lachance
Director, Government Affairs
Dow Chemical Canada Inc., Ottawa, Ont.

Ken Ogilvie
Executive Director
Pollution Probe, Toronto, Ont.

Beatrice Olivastri
Chief Executive Officer
Friends of the Earth Canada, Ottawa, Ont.

Robert Page
Vice President, Sustainable Development
TransAlta Corporation, Calgary, Alta.

Richard Paton
President
The Canadian Chemical Producers' Association, Ottawa, Ont

Glen Toner
Professor, School of Public Administration
Carleton University, Ottawa, Ont.

Peter Victor
Dean, Faculty of Environmental Studies
York University, North York, Ont.