Proposed Amendments to the Metro Vancouver Air Quality Management Bylaw

Metro Vancouver Public Involvement Division
4330 Kingsway
Burnaby. BC  V5H 4G8

Via Email: aqbylaw@metrovancouver.org

Dear Sir or Madam:

Re: Proposed Amendments to the Metro Vancouver Air Quality Management Bylaw

The Vancouver Board of Trade is concerned over some of the proposed changes to the Air Quality Management Bylaw. The existing laws continue to be aimed at single point emitters even though they are not the main source of the Green House Gases and other emissions we all seek to mitigate in this region. In fact, evidence indicates that emissions from these sources have been reduced through the last 20-25 years in part due to the closing down of some facilities and in part due to advances in technology adopted by other single point emitters. Moreover, evidence shows that critical air contaminants and Green House Gases have decreased during this period despite the significant increase in population.

It would appear that the forecasted air quality over the next twenty years is based on a worst case scenario and does not take into account advances in technology and replacement of existing emission sources with cleaner elements.

Of even greater concern is the apparent lack of economic analysis around the impact of the proposed fee increases on this group of companies both for those who are to pay said increased fees as well as the comparison with the associated costs of implementing and maintaining these regulations. The unintended consequences of imposing these fees may include but is not limited to loss of industries and jobs and increased costs to the consumer – the ultimate payer of these fees. No fee increases should be implemented unless supported by proper economic analysis.

Should additional fees be required based on economics, consideration must be given to phasing them in over a period of time. This is to allow the respective industries and organizations impacted by this bylaw to replace existing boilers and emitting equipment in the regular course of renewal of these installations. This would minimize the impact during the remaining life of the existing equipment as well as provide the businesses affected an ability to take advantage of advances in technology which would minimize emissions.

A last point for consideration. While it may be appropriate to be a little more stringent in what types of material may be used in biomass-fueled boilers and heaters, this should be done in coordination with changes in the provincial regulations so that all the Lower Mainland air-shed is dealt with equitably. Mention is also made of these proposed new regulations to be economically viable although such analysis does not appear to be readily available for review and consideration. These should be made available for review prior to proposing the changes to the regulations.

Sincerely,
Bernard Magnan
Assistant Managing Director and Chief Economist

/jf

cc: Ms. Anita Patel-Huberman, Surrey Board of Trade
 Mr. Craig Jones, Richmond Chamber of Commerce
 Ms. Jill Cook, Tri-Cities Chamber of Commerce
 Mr. Bruce Rozenhart, Counter Point Communications
 

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