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The policy cycle of polychlorinated biphenyls (PCBs) in Canada Lee, Michael L. 1992

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THE POLICY CYCLE OF POLYCHLORINATED BIPHENYLS (PCBS) IN CANADA by MICHAEL L. LEE B.Sc, The University of British Columbia, 1986 B.A. (Hons.), The University of British Columbia, 1989 A THESIS SUBMITTED IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF ARTS in THE FACULTY OF GRADUATE STUDIES (Department of Political Science)  We accept this thesis as conforming to the required standard  THE UNIVERSITY OF BRITISH COLUMBIA August 1992 © Michael L Lee, 1992  In presenting this thesis  in  partial fulfilment  of  the  requirements for an advanced  degree at the University of British Columbia, I agree that the Library shall make it freely available for reference and study. I further agree that permission for extensive copying of this thesis for scholarly purposes may be granted by the head of department  or  by  his  or  her  representatives.  It  is  understood  that  copying  my or  publication of this thesis for financial gain shall not be allowed without my written permission.  Department of  POLITICAL SCIBMCF  The University of British Columbia Vancouver, Canada  Date AUGUST 10, 1992-  DE-6 (2/88)  ii  Abstract  This paper uses the case of Polychlorinated Biphenyls (PCBs) to examine the dynamics of the public policy cycle in Canada. A process approach is applied to examine the principal stages of the cycle: problem identification, agenda-setting, decision-making, and implementation. In examining these stages, the factors that drive the policy cycle and those that impede its progress are identified. The regulatory history of PCBs is traced to demonstrate some of the complexities of the policy cycle. As one of the better known hazardous wastes in Canada, PCBs have been the catalyst for the introduction of new toxic chemical regulations throughout the 1970s and 1980s. Since the late 1970s, regulatory policies have been developed and implemented for PCB use and handling. After major PCB accidents occurred during the second half of the 1980s, regulations were introduced for their transport, storage and disposal. This case study provides seven major conclusions: (1) before the right policy solution is found and implemented, several stages in the cycle may need to be repeated; (2) public perception is a key determinant of the policy problem; (3) focussing  iii  events are a critical factor in setting the agenda; (4) decision-making often takes an incremental approach due to incomplete information and divided policy jurisdictions; (5) successful implementation, particularly in divided jurisdictions, requires sympathetic officials who are supportive of the enabling legislation; (6) constituency group support is a necessary condition for policy implementation; and (7) to deal with public concerns which may impede the implementation process, officials need political and managerial skills.  iv Table of Contents Page Abstract  ii-iii  Introduction  1-4  Chapter I:  Policy Problem  A. B. C. D.  Actual Hazards Effects on Humans Policy Alternatives Actors and their Stakes 1. NIMBY 2. Environment 3. Labour 4. Industry 5. Bureaucracy 6. Opposition Parties 7. Media 8. Provincial Governments E Regulatory Framework  Chapter II:  Agenda-Setting  A. Chronology 1. Initial PCB Regulations 2. Evaluation of PCB Regulatory Policies 3. The Kenora Highway PCB Spill 4. The St. Basille-le-Grand PCB Fire B. Process Streams 1. Policy 2. Problem 3. Politics Chapter III:  Decision-Making  A. Uncertainty over the Hazards B. Costs and Benefits C. Jurisdiction  5-26 6-9 9-12 13-15 15 16 17-18 18-19 19-20 20-21 21 21-22 22-23 23-26 27-40 28-36 29 30-31 31-32 32-35 35-40 37 37-38 38-40 41-47 42-43 43-45 45-47  V  Page Chapter IV:  Implementation Process  A. CEPA: Equivalency Provisions B. Enforcement C. Siting Process 1. Consultation and Accountability 2. Understanding the Costs and Benefits  48-72 52-58 58-61 61-72 65-68 68-72  Conclusion  73-76  Endnotes  77-94  Bibliography  95-103  1  Introduction  The study of the public policy-making process by Canadian analysts has focussed primarily on the policy formulation and decision-making stages.1 Policy-making is more than just solving the problem. Many factors influence how a problem is defined and brought to the attention of government. The policy-making process must contend with conflicting interests which shape the problem and the alternative solutions. Also, difficulties may be encountered in the implementation of a policy, requiring policy reformulation. With these considerations in mind, the entire policy cycle must be studied from how an issue is selected by government for action, to how a policy is implemented after it has been formulated. This paper will examine the regulation of PCBs as a case study for investigating the dynamics of the public policy cycle. As with other chemicals, PCBs were found, many years after they had been in commercial use, to have hazardous effects on the environment and humans. In part, due to coverage in the media, PCBs have become one of the better known hazardous and industrial chemicals. They have heightened public awareness of the environmental and health problems created by the chemical industry. Indeed, PCBs were the catalyst behind the new toxic chemicals legislation enacted in Canada during the mid-1970s. This type of impact in the political arena has been seen with other chemicals, as demonstrated in Liora Salter's recent study of "political chemicals".2 Salter defines a political chemical as one which "acts as a lodestone for a broad debate  2 about chemical regulations".3 She goes on to contend that "once it becomes 'political' a chemical can no longer be assessed dispassionately, either in a court of law or by scientists."4 In this way, the controversy accompanying a political chemical may interfere with its assessment and subsequent policy resolution.5 As we will see with PCBs, this controversy can prod governments into action, but it can also impede their progress in dealing with the problem. This paper will examine the entire policy cycle of PCBs as a political chemical, from the initial identification of its hazards, to the implementation and evaluation of the regulations to deal with the problem. Of particular interest will be the factors that drive the policy cycle, and those that impede its progress. We will take a process approach to studying the policy cycle and focus on the strategies and tactics of the participants as influenced by events and institutions. This will enable us to gain better insight into the difficulties of governments in dealing with environmental problems, particularly ones which have raised so much public concern. Charles O. Jones provides an excellent outline for studying the policy-making process which will serve as a framework for our discussion. He breaks down the process as follows:6 Problem identification Proposal development Decision-making process Program results Implementation Evaluation  3  In the first stage of the policy cycle, a problem is identified and defined as requiring government intervention. This process also identifies the political gains to be made. To move the issue onto the government's agenda, a number of factors come into play including interest group actions, elections, events, and shifts in public opinion. Once the problem is placed on the government's agenda, policy-makers identify and develop viable alternatives or policy solutions. The next stage of the policy process is to select the best policy option. There are several models of decision-making. Comprehensive and rational decision-making views the policy process as proceeding in an orderly, logical, and efficient fashion. An analytical approach is taken by this model, identifying the problem, defining the suitable alternative solutions, and then selecting and implementing the best solution.7 This model assumes that the goals can be identified, and that all the necessary information is available to make a sound policy decision. In contrast, incrementalism, as laid out by Charles Lindblom in "The Science of Muddling Through", views the policy process as consisting of small marginal adjustments in policy.8 This decision-making model operates in a gradual fashion, step-by-step. As a result, the policy framework does not need to be redefined because reliance is placed on past policies. From the reconstruction of the decision-making process, we will examine the basis on which policy alternatives were evaluated and decisions made. The policy process does not end at the decision-making stage. The policy must still be implemented. During the process of implementation, numerous problems may occur and require policy reformulation. We will apply the conditions identified by Mazmanian and Sabatier for successful  4 policy implementation. In particular, we will review problems the federal government has encountered in its efforts to lay down national standards. As one of the first applications of the Canadian Environmental Protection Act (CEPA). enacted in 1988, we will examine whether its opting out provisions undermine the establishment of national standards for PCB storage. We will also discuss the importance of support from local residents for the siting of disposal facilities in their communities. In addition, we will examine the skills required of implementing officials to deal with the public and their concerns over these proposed sitings. These three implementation problems are further indications of the need to study the entire policy cycle since formulating policy does not necessarily address the potential difficulties in its implementation. Following implementation, the effectiveness of the policy outcomes is evaluated, which may lead to policy reformulation and return the cycle to the proposal development stage. In tracing the policy cycle for PCBs, we will see how these policies, intended as solutions to certain problems, were themselves the causes of new problems that required policy adjustments. Consequently, while devising long-term solutions to PCB wastes, new regulations for PCB use, transportation, storage, and disposal were also enacted. As suggested by some analysts, the public policy process cannot be viewed in strictly linear terms. Hogwood and Peters assert that much of policy-making is policy succession or "the replacement of an existing policy, program or organization by another" which is aimed at the same problem and/or subject group.9 While we will examine the entire regulatory history, our focus will be on the policies of the late 1980s and how well they have met the objectives identified in the late 1970s.  5 Chapter I:  Policy Problem  PCBs share many of the same potential problems as other chemicals prevalent in our homes, businesses, and industries. While most of these chemicals pose little danger to the environment or to human health, some have been found to be harmful. At present, of the over 60,000 chemicals in use around the world, approximately 30,000 are utilized in Canada. The Canadian Environmental Advisory Council (CEAC) identified about 1,500 of these chemicals to be of particular concern.10 Public concern over toxic substances has reached heightened levels in recent years. In an Environics poll conducted in July 1989, 93% of survey respondents expressed fear of poisoning by toxins yet to be identified.11 In defining the policy problem of PCBs, both the actual and perceived hazards must be outlined. To determine the actual hazards, we must first review the scientific research on PCBs and the uncertainty over its potential health risks. Alternative solutions to dealing with the PCB problem will also be examined, with a particular focus on the associated policy problems. Following this discussion, we will examine the perceived hazards of PCBs through a discussion on how the problem is defined by the various policy actors. Some of these perceptions have exaggerated the potential risks of PCBs. An overview will then be provided of the regulatory framework within which the federal government must work to resolve the PCB problem.  6  A.  Actual Hazards First synthesized out of chlorine, carbon and hydrogen in 1881, PCBs are  fire-resistant, very stable, and excellent non-conductors of electricity.12 Before their manufacture, mineral oil was used as a dielectric fluid (a non-conductor of electricity). However, it was discovered that power surges in the electrical equipment could lead to the ignition of mineral oil and cause transformer fires. In the 1930s, askarel, made up of 40% to 70% PCBs, was manufactured and used as a replacement for mineral oil. 1 3 Due to their low volatility at normal temperatures (below 40°C), PCBs were primarily used as safe cooling and insulating fluids to prevent the overheating of industrial transformers and capacitors.14 Many federal, provincial, and local codes required the installation of PCB equipment in buildings, underground mines or other areas where fire protection was needed. 15 Consequently, PCB electrical equipment is still used in some schools, hospitals, food and feed facilities, and office buildings.16 Also, millions of lamp ballasts, manufactured before 1977 and containing small PCB-filled capacitors, remain in use. 17 In the 1950s and 1960s, PCBs were used in consumer products ranging from plastics, resins, paints, and cutting oils, to printing inks, lacquers, and varnishes.1** The very properties that make PCBs desirable industrially, are also the cause of undesirable health and environmental effects. Due to their widespread use and stable characteristics, PCBs have persisted as an environmental problem. Between the years of 1929, when they were first manufactured industrially, and 1975, when a ban was placed on their manufacture, a large proportion of PCBs was released into the environment at dump sites, moved through the atmosphere, or transported with sediment  7 down rivers and into oceans. As a result, PCBs have been detected in the atmosphere, water, sediment, animal tissues, and human milk and fat tissue. In 1981, it was estimated that nearly 100% of the United States population had detectable levels of PCBs. 19 Moreover, in 1985, an Environment Canada report indicated that PCBs have been detected in all foods available in Ontario.20 There are four principal ways by which PCBs enter the environment. First, a relatively small amount is released through accidental spills and leaks. Second, PCBs enter the environment through vapourization from paints, coatings and plastics.21 Third, PCBs may be released through open-burning or incomplete incineration.22 Fourth, they may be released through improper dumping in the ocean, in non-secure landfill sites, and in municipal disposal facilities. These four types of PCB release have created an extensive environmental problem outlined in a 1989 report prepared for Environment Canada: Of the total world-wide production of PCBs between approximately 1929 and 1977 estimated at 1,200,000 metric tonnes, some 783,000 tonnes is still in use in electrical equipment or deposited in landfills and dumps. Approximately 374,000 tonnes is free in the environment. But a surprising 61 per cent of this amount (230,000 tonnes) is present in open ocean seawater and 35 per cent (130,000 tonnes) in terrestrial and coastal sediments. Of the approximately 40,000 tonnes imported into Canada, just over 24,000 tonnes can be accounted for today. The remaining 16,000 tonnes is assumed to have been dispersed into the environment and is also contributing to the global PCB loading.23 Within Canada, a great deal of attention has been focussed on PCB loading in the Great Lakes. A report to the Council of Great Lakes Research  8 Managers provides a stern warning about the PCB problem: "At present, these compounds appear to be deposited at a rate that the Great Lakes and global ecosystems simply cannot assimilate or remove them into relatively terminal sinks such as deep lake and ocean sediments."24 The global loading of PCBs may be explained by examining their biochemical interaction with fatty tissue and water. Once released into the environment, PCBs enter the food chain and are eventually deposited in the fatty tissue of most organisms, including humans. Due to the hydrophobic nature of PCBs, their concentrations in water samples are generally low.25 However, significant concentrations of PCBs are found in freshwater and marine organisms because of the lipophilic nature and biological stability of PCBs.26 Consequently, PCBs are transferred up the food chain from phytoplankton to invertebrates, and to fish and mammals. Due to their tendency to be stored in fatty tissues, this transfer results in an amplification of much greater concentrations of PCBs known as bioconcentration.27 Many studies indicate a very high concentration of PCBs in marine mammals, including whales, porpoises, and seals.28 These mammals contain much higher levels than terrestrial birds and mammals, despite living in oceans distant from the land-based PCB sources of pollution.29 Severe damage has also been found in the seal population in the Baltic Sea where Finnish researchers found these mammals to suffer from hormonal imbalances, suppressed immune systems, and reproductive problems.30 While PCBs are not acutely toxic to most organisms, their chronic or long-term toxicity may be quite harmful. One of the most critical toxic effects of PCBs is on bird reproduction. PCBs have been associated with the reproductive failures of merlins and prairie falcons in western  9 Canada, and of herring gulls, terns, cormorants, and bald eagles in the Great Lakes region.31 Studies also indicate that animals with low enzyme activities are vulnerable to the toxicological effects of PCBs and related compounds.32 Serious toxic and biological effects, such as weight loss and thymic atrophy, were discovered in laboratory guinea pigs exposed to PCBs.33 As to their carcinogenic effects, increased liver lesions including nodules and carcinomas were found in long-term exposure studies on rats and mice fed PCBs over a 32-week period.34  B.  Effects on Humans While the hazardous effects of PCBs on animals have been demonstrated,  those on humans are disputed.35 This is due, in part, to the few documented instances of direct PCB exposure in humans. Scientists are generally in agreement about the short-term effects of PCB exposure in causing chloracne and gastro-intestinal disturbances. However, they are less certain about the long-term effects, particularly the carcinogenic potential of PCBs. Also, the effects of PCBs on human reproduction have not yet been determined.36 With this uncertainty, the hazardous effects of PCBs are often exaggerated. Recent studies on the harmful effects to humans of the accumulation of PCBs in ecosystems such as the Great Lakes, indicate a strong link between the environmental damage evidenced in the wildlife and ecosystems of the Lakes, and human health risks. In August 1991, a study released by the Science Advisory Board of the International Joint Commission suggested that the 37 million people in the Great Lakes Basin are not immune to health problems, including the birth defects and reproductive problems found in the area's wildlife.37  10 In another study, a survey of Inuit women living on the east coast of Hudson Bay reported an average of 3.6 ppm in breast milk-one of the highest levels ever found in humans.38 These high levels of PCB residues are further indications that bioconcentration through the food chain and the environment can ultimately lead to human exposure through the lungs, gastro-intestinal tract and the skin.39 Humphrey's study of Great Lakes residents found that the principal source of PCB exposure is through the consumption of fish from this polluted water system.40 The study also found that PCB exposure from the water and atmosphere is far less significant than that from fish consumption.41 While there is much evidence of PCB concentration in the environment, few cases have been documented of direct exposure to humans. The most commonly cited case is the Yusho, Japan incident. In 1968,1,200 people consumed rice oil contaminated with PCBs over periods varying from 20 to 190 days. Reactions to this exposure included reproductive dysfunction, severe cases of chloracne, eye discharges, headaches, vomiting, visual disturbances, and respiratory problems.42 There were also adverse effects on the fat metabolisms, blood enzyme levels, and the immune systems of affected persons.43 In addition, retarded growth was found in young children exposed to PCBs.44 The long-term effects of this incident on offspring included small birth size, lowered I.Q., and impaired motor development.45 Canadian policy-makers remain uncertain about the carcinogenic nature of PCBs to humans, primarily because of the lack of evidence on the effects of direct exposure to PCBs. An environmental assessment report on the hazards of PCBs, commissioned by the Toxic Chemicals Steering Committee (TCSC) of the Canadian Council of Resource and Environment Ministers  11 (CCREM), reviewed the studies on the toxic effects of PCBs. Referring to a number of studies with conflicting findings, this report found little evidence to indicate that PCBs are carcinogenic.46 To date, the best supporting evidence of the effects is from laboratory studies on animals. However, extrapolating from these results is highly suspect, because humans are not subjected to the same high levels of PCB exposure as are animals in a laboratory setting, or aquatic animals in the environment. Typically, humans are exposed to approximately 1.0 ppm to 1.5 ppm. 47 In contrast, PCB levels as high as 800 ppm have been found in the body fat of aquatic animals.48 Also, while the Yusho incident demonstrates the health hazards of PCBs, this level of exposure is atypical, except in accidents such as high-temperature fires causing the breakdown of PCBs. Health and Welfare Canada sets the acceptable daily intake (ADI) of PCBs at one microgram per kilogram of body weight per day.49 It is estimated that the average person absorbs about 51 micrograms of PCBs a day in food, which translates into a level slightly more than the ADI for a 50 kilogram person.50 In contrast, a person weighing 70 kilograms absorbs 73% of the recommended daily limit, remaining below the ADI level for his or her body weight.51 Standards such as ADIs have inherent difficulties because they are based on the assumption that the results of the animal studies can be translated into reasonable estimates of the effects on humans. ADI is only a best estimate of a safe level of PCB consumption. It is based on toxicological studies on laboratory animals given different daily doses of PCBs over extended periods of time, to determine the safest level of exposure at which no detrimental health effects are apparent. Based on this  12 "no effect" dose level and a "safety factor" which may be as high as 1,000, scientists calculate the level of PCBs that will not cause any ill-effects on humans. Another method of risk assessment of environmental PCB exposure is from epidemiological studies of workers who are occupationally-exposed. From their review of these studies, Safe et. al. assert that the potential harmful health effects to humans from PCB exposure are very low, based on studies of workers in electrical equipment manufacturing plants exposed, over many years, to high levels of PCBs.52 In their study of 2,600 electrical industry workers, Brown and Jones found a slight increase in deaths from rectal and liver cancers.53 However, the statistical significance of this link between increased cancer rates and occupational exposure to PCBs has been questioned.54 In addition to the studies on the harmful effects of direct exposure to PCBs, recent research on by-products of PCBs released from accidental burning suggests that toxic chemical by-products called polychlorinated dibenzofurans (PCDFs) and polychlorinated dibenzo-p-dioxins (PCDDs) are even more harmful to humans than PCBs.55 The 1968 poisoning incidents in Japan and Taiwan have been directly linked to high concentrations of toxic PCDFs released from the burning of PCB-contaminated rice oil. 56 In his work on forecasting future hazards with these PCB by-products, Shinsuke Tanabe suggests that non-chlorine substituted coplanar PCBs, especially 3, 3', 4,4', 5 - P5BC, are an even greater toxic threat to humans and wildlife than are dioxins and furans.57 These more recent findings have increased the concerns of policy-makers over the hazards of accidental fires at PCB storage facilities.  13 C.  Policy Alternatives The preceding discussion identifies the primary hazards of PCBs as: (1)  the effects of PCB accumulation in the food chains and the environment; (2) direct exposure to PCBs in the workplace; and (3) the potential breakdown of PCBs into more toxic by-products from accidental fires. To address these problems, there are several policy alternatives. The most immediate step would be the restriction of certain types of equipment within permitted concentration levels. This alternative depends upon the safety of the equipment designed to contain PCBs. PCB-filled equipment would be permitted to remain in service until their normal retirement or within twenty to forty years. Known as natural attrition, this policy takes a minimal approach, allowing time for replacement fluids to be developed. To date, the most successful replacement material is silicon oil, which does not pose a health threat because it is biodegradable to silica, a main component of sand.58 In keeping the PCBs in the equipment designed to contain them, a natural attrition policy does not place immediate strains on storage facilities and is the least costly to industry in the short-term. However, this policy is not the most desirable because of the potential for accidental fires in buildings with PCB-filled equipment. An alternative to the natural attrition option is a mandatory and accelerated phase-out program to replace PCB-filled equipment as quickly as possible. This policy reduces the potential for accidental releases from substandard equipment by removing PCBs from use before their normal retirement time. Removal requires replacement equipment and materials to be developed quickly, and additional safe storage and disposal facilities to be sited. Once the PCB-filled equipment is removed from service, it must be disposed of on-site, or transported to either a storage or disposal facility.  14 In many cases, requiring the transport of PCBs to these facilities can lead to further policy complications, such as accidental spills. To reduce the distance of transport, facilities need to be sited nearby. Following removal, the preferred policy alternative is the immediate disposal of PCBs on-site, versus off-site. However, the siting of disposal facilities may raise public concerns over the hazards of potential PCB releases. These concerns can be addressed, in part, by the employment of safe disposal methods including the high-temperature incineration of concentrated wastes and solids, and the chemical treatment of contaminated oils. The incineration method is preferred because it destroys close to 99.9999% of PCB waste material. It is also efficient to use mobile PCB incinerators in different regions for short periods of time, reducing the fixed costs of a permanent facility and minimizing the distance in transporting PCBs for disposal. The public may prefer the temporary nature of such mobile facilities. However, these units do not have the same provisions for emergency teams and response plans, as do permanent facilities. In addition, the advantage of permanent waste incinerators is their ability to handle all types of chemicals in an integrated facility with proper site management.59 If not enough disposal facilities are available domestically, PCBs may be exported for disposal outside the country. However, this policy option is dependent on the willingness of other countries to accept these wastes. An important component to any phase-out program is the siting of facilities to safely store PCBs indefinitely, or pending the availability of a disposal facility. Storage of PCBs is only a temporary solution, as there is always a potential for accidents such as fires. Until proper disposal units are sited, the removal of PCBs from service increases the reliance on  15 adequate storage facilities. There may be greater potential danger from PCBs in unsafe storage facilities, than from the continued use of electrical equipment designed to contain PCBs. Thus, policy alternatives proposed to resolve the PCB policy problem may themselves cause other problems which policy-makers must address. In Chapter Three, we will examine how policy-makers have analyzed these alternatives.  D. Actors and their Stakes To gain a better understanding of the PCB policy problem, we must move beyond a discussion of the actual hazards of PCBs. How the different policy actors play out their interests helps to define the dimensions of the policy problem. Although scientific research has not proven any long-term, severe hazards of PCB exposure, some actors have exaggerated the potential risks, making the policy process more difficult. Other actors have worked as policy entrepreneurs, heightening the level of public awareness over the issue and promoting a particular policy alternative. Kingdon defines these participants as including politicians, bureaucrats, media, interest groups, and the general public.60 In defining the PCB problem, policy-makers must deal not only with the real costs, but also the perceived ones, shaped in part by these actors, particularly the media and politicians. Each of these actors define the PCB problem in their own way, depending on their particular interests. In Chapter Two, we will examine further the roles that these actors play in moving the PCB issue on to the agenda and through the policy cycle, but at this point, our discussion will only outline their interests.  16 1.  NIMBY The Not In My Backyard Syndrome (NIMBY) is based on the concerns of the  local public over property and health. Poor information on the hazards of PCB storage and disposal facilities undermine public confidence in the siting of a PCB storage or disposal facility in their community. In a Great Lakes study of PCBs, it is shown that public anxiety likely stems from the lack of confidence in the effectiveness of the laws and regulations in place to protect public health and the environment.61 Due to this distrust and the differing scientific reports over PCB hazards, local residents do not differentiate between unsafe and safe facilities. Consequently, their concerns and fears often thwart the siting process.62 Desmond Connor analyzes the components of the NIMBY Syndrome in terms of its psychological, sociological, and economic dimensions. The psychological factors are defined as selective perception, perceived risk, and perceived inequity.63 The basic theme of these factors is that "perception is reality". It is not what is true that is important; rather, it is what people perceive.64 Consequently, they are quite sensitive to any suggestion of the dangerous health risks of PCBs, despite the absence of supporting scientific evidence. The sociological factors are loss of community identity, involvement and control, and lack of regional affiliation.65 Local residents want to be involved in decisions that affect their community. They do not want a siting decision to be imposed on them due to technical suitability. NIMBY is also rooted in economic concerns over the decrease of property values and lack of compensation.66 The problem that NIMBY poses to the implementation process will be considered in Chapter Four.  17 2.  Environment To the extent that NIMBY and environmental groups are concerned about  the safety of storage and disposal facilities, their interests are complementary. However, depending on how these interests are defined, they may also be at odds with each other. Environmental groups place a greater emphasis on the protection of the environment as a whole. In contrast to the local NIMBY groups, their stakes are not self-oriented. However, they also do not necessarily have to deal directly with the potential economic downsides in their own community. NIMBY groups are interested in the health and economic well-being of their communities. They are concerned with the economic downsides including the potential decline in property values accompanying the location of a storage or disposal facility. Environmental groups promote greater awareness of the dangers of PCBs, and advocate the protection of the environment. A main concern of environmental groups is the need for more public consultation. This is a position shared by NIMBY groups, who often complain about the lack of openness in decision-making processes. Environmental groups also advocate programs for safe PCB management. At a 1989 national stakeholder workshop on the Federal PCB Destruction Program, they put forward a joint statement stressing the following: "If PCB disposal technologies are to operate in Canada, there must be thorough and complete environmental assessment, public notice and hearing requirements, and intervenor funding."67 In terms of PCB disposal, Pollution Probe is particularly supportive of high-temperature incineration.68 In contrast, Greenpeace is critical of this method, advocating a 0% emission level which is currently unattainable.69  18 In focussing on the failure of disposal facilities to attain this zero level of emission, environmental groups may unintentionally raise the fears of the public, particularly those of NIMBY groups, which may lead to longer delays in siting more facilities and, in turn, increase the potential for accidents since a greater reliance is placed on storage facilities.  3.  Labour Labour groups are primarily concerned with health issues and the  improvement of work conditions. These concerns have led to the development of safety procedures and guidelines for the proper handling of PCBs.70 Employees may be exposed to PCBs while servicing and maintaining electrical equipment, cleaning-up spills or leaks of PCB fluids, or working in scrap metal, salvage, and waste collection companies. Incidents of poor handling of PCBs at the workplace include the Prince Rupert, British Columbia grain elevator, where it was reported that PCBs were stored in buckets in a plywood box in the lunchroom.71 Concerned about the harmful effects of PCB exposure due to improper storage or disposal, unions, like the Canadian Paperworkers Union, have taken positions which are often-times more cautious than those of industry, and more in line with environmental groups. For example, the Union has pressured for a full ban on the use of PCBs.72 The position of labour groups is that a worker whose health has been affected by PCB contact should receive comprehensive medical treatment and compensation.73 Labour groups are also strong advocates of stricter standards in the workplace. The Ontario Workers' Health Centre has complained about the Ontario Labour Ministry's guidelines for PCBs on factory surfaces as being much too high. This safe exposure guideline of 1,000 micrograms per 100  19 square centimetres is considerably higher than the levels set by the United States Environmental Protection Agency.74 In 1985, workers at Westinghouse Canada's transformer factory in Hamilton were exposed to PCBs above the Ministry's guidelines.75 The Ontario Labour Ministry's response of advising the firm to ensure that workers avoid contact with the PCB residue in the men's change room was criticized for being far too lenient.76  4.  Industry The stakes to industry are primarily economic. It must find the most  cost-effective means to replace PCBs with alternative insulating and cooling fluids, and to remove PCB-filled equipment. In view of these costs, industry seeks a moderate approach by which the regulations do not place undue burdens on industry. To justify this, industry representatives have attempted to differentiate between the levels of PCB exposure from accidental spills or fires, and those with which employees normally come in contact in the workplace. In doing so, they attempt to correct public misperceptions about the hazards of PCBs. Concerned with their public image, industry has made efforts to address the occupational health and safety issues raised by workers and the public. The electrical industry cooperated with the federal government initiatives to list all PCB-filled equipment, to apply special labelling, and to replace equipment in particularly hazardous applications. Also, it implemented proper handling procedures, trained maintenance staff, built special storage facilities, and instituted a phase-out program for older PCB-contaminated  20 equipment.77 Although implementing these measures required additional costs, they are minor compared to the liability costs in the event of spills, fires, and prosecutions.  5.  Bureaucracy Environment Canada, and to a lesser extent the Department of Fisheries  and Oceans, are the federal government departments involved in PCB regulation. Within Environment Canada, hazardous wastes are managed under Conservation and Protection by the Waste Management Division. There is also a special group assigned to manage PCBs under the Federal PCB Destruction Program. In addition, at the regional offices of Environment Canada, local inspectors and engineers monitor hazardous wastes. Environment Canada facilitates dialogue between the various policy actors by organizing stakeholder meetings, and providing technical advice and financial support to the provinces and local communities. It also acts as a central resource for information and shares its research with provincial environment ministries. While much of this paper focusses on decisions made by politicians, it is important to note the different incentives and timetables of elected officials and bureaucrats. Although bureaucrats may share the same long-term goals as elected officials, the constraints placed on the two types of actors differ. Unlike elected officials who are more susceptible to short-term problems, bureaucrats have a longer-term approach, working through electoral changes in government and any resulting shifts in policy direction. Moreover, in being held publicly accountable, politicians often make decisions and set policies with primarily short-term political  21 considerations. Kingdon suggests that while bureaucrats may define the alternatives, it is elected officials who are the critical determinants of policy.78  6.  Opposition Parties Apart from the bureaucrats, another important group of actors in the  policy process is the opposition parties, specifically the New Democrats and the Liberals. These political actors provide a focus for public demands for policy change. Following the St. Basille-le-Grand PCB Fire, the Liberals and New Democrats criticized the government for poorly protecting the environment and public from PCBs. Liberal environment critic, Charles Caccia, urged "that a co-ordinated national system of (PCB) destruction must be quickly put in place, involving a mix of fixed and mobile facilities."79 New Democrat Cyril Keeper questioned, "Why didn't the federal government assume its responsibility and give leadership and set up this technology, invest in it, to protect the Canadian public against such disasters?"80 Opposition parties are also sources of alternative policy solutions, including the use of the Criminal Code to enforce proper storage and disposal of PCBs.81 The Liberal Party has put forward a ten-point plan for the federal government to assume a stronger lead role in PCB regulation.82  7.  Media An influential determinant of the political impact of the PCB issue is  the media and their ability to raise public awareness about the hazards of PCBs. As consumers of the news, the public, to some degree, helps to identify issues covered by the media. Marshall McLulan suggests that, "it is  22  the audience that 'manages the news' by maintaining or losing interest in a given subject." 8 3 However, another part of this relationship is the reliance of the public on the media for information. Media plays an important role in drawing attention to the PCB problem by reporting on accidents and new research. They also provide forums for other policy actors to communicate their interests. Some critics have called media coverage of PCBs sensationalistic: For the media, PCBs make great stories. Lazy reporters can use monster-movie cliches (Ports Refuse to Accept Soviet Ship of Death's PCB Cargo!) and the stories practically write themselves. Of 285 PCB articles printed in the Globe and Mail and the Toronto Star in the past two years, only six described the hazards accurately. In the rest, PCBs were usually described as "deadly", "cancer-causing", or "causing infant mortality". No wonder the public is terrified.84 Media coverage of the PCB problem shapes public perception and, in some cases, misperceptions of the hazards of PCBs. Environmental groups like Pollution Probe are also critical of the media for their often superficial coverage of environmental issues.85 Instead of reporting on the actual hazards of PCBs, the media has sometimes exaggerated them. This type of coverage merely exploits the PCB issue and fuels public concerns.86  8.  Provincial Governments The decentralized authority over environmental policy in Canada  between the federal and provincial governments poses difficulties for the formulation and enforcement of PCB regulations. While the provincial governments have the bulk of the jurisdiction for environmental protection,  23  as tied to their property rights over resources, the federal government only has jurisdiction over fisheries and oceans. Thus, there is no strong hierarchy over environmental policy in the federal system. It was not until environmental issues came to the forefront as a major public concern that either level of government finally seized these issues. Traditionally, these issues were viewed as primarily affecting rural areas, and wilderness preservation and resource management.87 However, with hazardous wastes like PCBs, the environmental agenda has become increasingly driven by urban centres. Within the federal framework, governments determine which issues are in their best political interests. Harrison contends that, depending on the impact of the regulations, governments would not want the job of regulation.88 For instance, she suggests that provincial governments have a vested interest in ensuring a favourable climate for investment.89 It is not in the interest of a provincial government to enact highly stringent regulations and risk losing an industry to another province. For this reason, federal government intervention may be required to ensure minimum acceptable standards nation-wide. Nevertheless, provincial governments are as concerned about their political interests as is the federal government, and want to be seen as responsible managers effective at protecting the environment and in dealing with PCBs.  E  Regulatory Framework As mentioned, the authority over the regulation of PCBs in Canada is  divided between the federal and provincial governments. The federal government is responsible for the interprovincial and international transport of PCBs, establishing and enforcing national standards for the use  24  of, and release into, the environment of PCBs and for protecting Canada's boundary waters.90 The provincial government is responsible for PCB storage, clean-up of spills, and disposal within provincial borders.91 In addition, provincial legislation and regulations are required to meet the minimum national environmental standards set down in federal statutes. While the storage and disposal of PCBs is within provincial jurisdiction, the federal government has attempted to lay down national standards under CEPA. Currently, PCBs are regulated under CEPA. Enacted in 1988 as the major federal environmental protection statute, CEPA incorporates new regulations on toxic materials, and builds on earlier authorities including the Environmental Contaminants Act, the Clean Air Act, the Canada Water Act, and the Ocean Dumping Control Act.92 CEAC describes CEPA a s : " . . . one of the most powerful environment instruments that Canada has ever had."93 The Act provides the regulatory authority for dealing with pollution problems on land, in water, and through all layers of the atmosphere. It also regulates toxic substances through their life cycle from development and manufacture, transport, distribution, use and storage, to safe disposal as waste.94 With the authority granted under CEPA. in September 1988, federal Environment Minister Tom McMillan suggested that "he does not have to seek permission from any province to apply federal standards and enforcement procedures anywhere in the country."95 Under section 35 of CEPA. the Minister of the Environment has the authority to bring in an interim order when the Minister, in conjunction with the Minister of National Health and Welfare, believes that: "(a) a substance specified on the List of Toxic Substances is not adequately regulated; and (b) immediate action is required  25  to deal with a significant danger to the environment or to human life or health."96 The Storage of PCB Wastes Interim Order was among the first regulatory changes by a federal environment minister using the authority of CEPA. A key determinant of the federal government's ability under CEPA to lay down national standards for PCB regulations is the provision under section 34(6), which allows for exemptions for provincial governments with equivalent regulations: Where the Minister and the government of a province agree in writing that there are in force by or under the laws of the province (a) provisions that are equivalent to the provisions of a regulation made under subsection (1), and b) provisions that are similar to sections 108 to 110 for the investigation of alleged offences under provincial environmental legislation, the Governor in Council may, on the recommendation of the Minister, make an order declaring that the provisions of the regulation do not apply in the province.97 Under section 34 (7), these equivalency agreements must be made public by the Minister of the Environment.98 Furthermore, under section 34 (10) and as required by section 138 of CEPA. a report on the administration of the subsections relating to these exemptions must be included in the Minister's annual report on the administration and enforcement of the Act to Parliament.99 While it is clear from CEPA that regulations must allow for equivalency agreements, interim orders, viewed as emergency and temporary measures, are an exception to the rule. Consequently, an equivalency agreement is not required for a province to be exempted from the order.100 Divided regulatory authorities have necessitated negotiations between the federal and provincial governments to establish national and uniform standards for PCB storage and disposal. There is a provision under CEPA for  26  the formation by the Minister of the Environment of a federal-provincial advisory committee to establish a "framework for national action".101 This provision reinforces the practice of federal-provincial negotiations to coordinate joint efforts in the absence of institutional channels. In the past, much of this mediation has taken place in forums such as CCREM, which was formed in 1962.102 Prior to the introduction of CEPA. the federal government's chlorobiphenyl regulations in cross-boundary affairs were under the Environmental Contaminants Act (ECAV the Fisheries Act, the Ocean Dumping Control Act, and the Transportation of Dangerous Goods Act. 103 The ECA was administered by the Commercial Chemicals Branch of Environment Canada, in cooperation with the Bureau of Chemical Hazards and Health and Welfare Canada.104 The Act provided the regulatory authority to protect the environment from the harmful effects of hazardous wastes.105 The ECA also laid out an appeal process which called for the Environment Minister to publish the proposed order and regulation in the Canada Gazette (section 5(2)).106 In addition, the Fisheries Act, subsection 33(2) prohibits the release of hazardous materials into waters inhabited by fish, except as permitted by regulation.107 The Ocean Dumping Control Act regulates the disposal of PCBs at sea (including incineration), through permits and regulations specifying environmental operating requirements.108 The Transportation of Dangerous Goods Act (1985) regulates the documentation, handling, and control of dangerous goods for all interprovincial and international modes of transport.109 Having outlined the framework in which the PCB problem is defined and regulated, we will now turn our discussion to how the problem reaches the government's agenda.  27  Chapter II:  Agenda-Setting  Given their limited resources, governments must be selective of the issues they try to resolve. In theory, by a rational model of agenda-setting, issues would be selected based on highest priority. Criteria including preventing harm and securing benefits would be utilized to determine the importance of the issue and the need for government intervention. In practice, however, other factors influence how governments set their agendas. The agenda-setting process for PCBs has been less rational. As our examination of the regulatory history of PCBs will demonstrate, there have been certain periods when the PCB issue has come on and off the government's agenda. Of interest to our analysis are the causes of these shifts. In their model of agenda-setting, Cobb and Elder differentiate between what they term the systemic and institutional agendas of government. They define the systemic agenda as "all issues that are commonly perceived by members of the political community as meriting public attention and as involving matters within the legitimate jurisdiction of existing government authority."110 The institutional agenda is defined as "that set of items explicitly up for active and serious consideration of authoritative decision-makers."111 To frame our discussion of the PCB case, we will use a finer definition of the institutional agenda provided by Harrison and Hoberg. They define the regulatory agenda as a subset of the institutional agenda.112 As the agenda of those agencies responsible for regulating health, safety and environmental risks, the regulatory agenda is composed of the research and  28 decision agendas.113 The research agenda refers to issues on which data is gathered and analyzed; the decision agenda refers to those issues on which an agency is "seriously considering or actually taking action".114 In applying these definitions, we are able to more accurately separate the elements of the agenda-setting process. In the following chronology, we will determine when the PCB issue was on the systemic, research and decision agendas.  A.  Chronology In this chronology, the record of PCB regulation may be viewed in four  periods: (1) the introduction of the initial PCB regulatory policies in the 1970s following the UNESCO recommendations; (2) the evaluation of these policies in the early 1980s; (3) the policy formulation period following the Kenora Highway Spill; and (4) the policy initiatives undertaken in PCB storage and disposal after the St. Basille-le-Grand Fire. In tracing this chronology, it is important to examine how the agenda was set for the federal government to intervene. Given the many policy demands on government, why did the federal government encroach on provincial jurisdiction to take control of the issue? We will see that the shift to the systemic and decision agendas occurred in 1985, following the Kenora Highway PCB Spill, and again in 1988, after the St. Basille-le-Grand PCB Fire. We are primarily interested in what occurred during the fourth period after the 1988 fire, as the first three periods basically witnessed a compounding of the PCB problem. This last period also triggered the most public attention and, consequently, the most policy change.  29 1.  The Initial PCB Regulations Although PCBs were first manufactured commercially in 1929, concerns  over their toxic effects were not raised until 1966, with the discovery of PCBs in the fatty tissue of birds in Sweden. These early indications of problems with PCBs put the issue on the research agenda of Environment Canada. After the PCB poisoning incident in Yusho, Japan, the Organization for Economic Cooperation and Development (OECD) recommended to its member nations, in 1973, to limit PCB use to enclosed systems, and to develop phase-out strategies to eliminate the release of PCBs into the environment. Increasing concern over PCBs prompted the federal government to introduce the ECA in 1976. PCBs were the first class of substances to be regulated under this Act.115 As an addition to the schedule of the ECA. Chlorobiphenyl Regulations, No. 1 were enacted in 1977 to restrict the use and prohibit the importation, manufacture, and processing of PCBs. These regulations outlined: the development of a comprehensive inventory of PCBs currently in use or in storage in Canada; the implementation of remedial action for those identified as unsafe; and the establishment of an ongoing monitoring program.116 In effect, the regulations laid down an attrition policy allowing the continued use of PCB-filled equipment until retirement or within twenty to forty years. For the most part, during this period, the PCB issue remained on a steady course of moderate management, shifting between the research and decision agendas.  30  2.  Evaluation of PCB Regulatory Policies In 1978, as a result of objections to a proposed amendment to  Chlorobiphenyl Regulations, No. 1 that would stop the manufacture of PCBs in Canada, an Environmental Contaminants Board of Review (ECB) was established.117 Section 5(3) of the ECA provided that: "Any person having any interest therein may, within sixty days of publication in the Canada Gazette . . . file a notice of objection with the Minister."118 Furthermore, section 6(1) stated that upon receipt of such a notice of objection, the Ministers had to establish an ECB.119 After conducting public hearings, the ECB, recognizing that the government's attrition policy would not result in an early solution to the problem, made the following recommendations: a PCB disposal site should be found; uniform PCB regulations should be established and administered by the provinces; and the phase-out of PCBs should begin when a practical system for destruction becomes operational.120 Throughout the early 1980s, to follow-up on the recommendations made by the ECB, the PCB issue remained on the regulatory agenda. In 1980, the definitive Canadian policy on the use of PCBs was established with Chlorobiphenyl Regulations, No. 1 Amendment (1), which restricted PCB use to a few applications in electrical and mechanical equipment, and prohibited the use of PCBs as filling fluid in these types of equipment.121 In addition, a Federal/Provincial/Territorial Committee on Hazardous Wastes was established under the CCREM.122 In 1981, Environment Canada developed a code of good practice for the handling, storage and disposal of PCB-filled electrical equipment, and introduced it in training workshops in utilities across Canada.123 On the recommendation of the ECB to shift away from the attrition policy,  31 Environment Canada, in 1982, also began a study on how to implement a staged, accelerated phase-out of PCB use. 124 This study was later incorporated into the PCB Action Plan announced in 1985.125  3.  The Kenora Highway PCB Spill In April 1985, a shipment of PCB-filled transformers enroute from  Quebec to a storage facility in Alberta developed a leak.126 When the transport trailer was finally stopped, more than 400 litres of transformer oil containing 56% PCBs had spilled over 100 kilometres of the Trans-Canada Highway in northern Ontario.127 Known as the Kenora Highway Spill, this accident gained substantial media attention and brought the PCB issue onto the systemic agenda for the first time. The spill also became a campaign issue leading up to the Ontario provincial elections on 2 May 1985. During the campaign, the Liberal Party promised to enact a tough pollution clean-up law, the Spills Bill, to provide immediate compensation to victims of spills, and to discourage companies from careless handling of environmentally hazardous materials.128 Under the Bill, the polluter would be held responsible for pollution spills, regardless of cause, and responsible for clean-up. Owners, shippers, and handlers of hazardous materials would be liable to pay as much as $1 million to clean-up spills.129 Following their election, the new Liberal Government enacted this Bill on 29 November 1985.130 The Kenora Highway Spill also shifted the issue from the research to the decision agenda. The CCREM announced a PCB Action Plan in May 1985, calling for the establishment of PCB destruction facilities, the introduction of national standards for the transportation, storage, and destruction of PCBs, and the development of a PCB phase-out strategy by the end of  32 1986.131 A major achievement of the Plan was the development of the Transportation and Dangerous Goods Act. This Act was amended in May 1986 to: control all road and rail PCB transportation activities; include special exemptions for equipment in service; and set standards for the handling and packaging of PCBs.132 Also, the movement of specific wastes now had to be manifested and transported to approved disposal facilities.133 The Action Plan also enacted additional regulations over PCB use. Chlorobiphenyl Regulations, No. 2 (Product) set the maximum PCB concentration at 50 ppm by weight, as the permitted level for certain electrical and mechanical equipment designed to use PCBs and that are imported, manufactured or sold. 134 Chlorobiphenyl Regulations, No. 3 (Release) established the maximum allowable concentrations and quantities of PCBs that can be wilfully released into the environment in the course of a commercial, manufacturing, processing, or storage activity at: 50 ppm in general cases; 5 ppm for road oiling; and 1 gram per day per piece or package of equipment.135 Following the spill and the subsequent policy announcements, the issue came back off the systemic agenda, but remained on the regulatory agenda. To follow-up on the development of a phase-out strategy, negotiations between the federal and provincial governments were accelerated. Although an agreement was nearly reached on several occasions, the negotiations were not successful in meeting the 1986 deadline.136  4.  The St. Basille-le-Grand PCB Fire The second major accident in the 1980s was a fire at a PCB storage site  in St. Basille-le-Grand, Quebec, in August 1988. This was the largest PCB fire in Canadian history, leading to a 17-day evacuation of about 3,500 area  33 residents.137 The storage facility was a two-storey wooden building and contained 1,500 barrels of PCB wastes. It did not have proper signage, security, or fire protection systems.138 The accident moved the PCB issue onto the systemic agenda for the second time, and also resulted in a shift of the issue from the research to the decision agenda. Following the fire, the federal Environment Minister brought in the Storage of PCB Wastes Interim Order in September 1988, to lay down legal requirements for controlled access, method of storage (segregation, exhaust systems, types of containers), fire protection and emergency procedures, maintenance and inspection, labelling and signage, and record-keeping.139 Also, fines of up to $1 million per day and jail terms of up to three years were set for failure to comply with the Order.140 In September 1988, after several years of negotiations, the federal and provincial environment ministers agreed to a national PCB program which called for the phase-out of PCB use over the next five years, and the strict enforcement of safety and security guidelines.141 The federal government also announced that it would dispose of all PCBs stored in federal facilities within one year. 142 In March 1989, the federal Environment Minister made amendments to the Order to strengthen guidelines for storage and emergency procedures.143 Two months later, the Environment Minister made another amendment to the Interim Order to exempt all provinces, except Prince Edward Island, "by virtue of these provinces having put in place legally enforceable requirements with effect comparable to the Order."144 With the introduction of this Order, in the aftermath of the fire, the PCB issue went off the systemic agenda, but remained on the regulatory agenda.  34 Under section 35(8) of CEPA. an interim order expires two years after it is made or when a regulation is brought in to replace it. 145 To meet this provision, an Interim Storage Order was reintroduced in September 1990. 146 In June 1992, a proposed PCB waste storage regulation to replace the Order was made public in the Canada Gazette. Part I. 147 These regulations are the same as the Interim Order, and therefore would not result in any substantive changes.148 Also, the negotiations between the federal and provincial governments are still ongoing over the equivalency agreements.149 Both the regulation and the agreements are expected to be in place by 17 September 1992, at the same time that the Interim Order expires.150 Proposed PCB Regulations are also expected to be introduced by January 1993 to replace the existing Chlorobiphenyl Regulations and to clarify the prohibitions and exemptions of PCBs in any product manufactured in, or imported into, Canada.151 In August 1989, the Environment Minister announced Federal Mobile PCB Treatment and Destruction Regulations to set standards for operating and testing PCB disposal facilities.152 These regulations apply to disposal systems on federal lands or those contracted by the federal government, and establish PCB limits for air, water, and solid waste discharges.153 After the announcement of the Federal PCB Destruction Program, the Environment Minister requested CEAC to identify a site for a transportable PCB incinerator on federal lands. In October 1989, partly in response to CEAC's recommendations, the Minister announced an enhanced Federal PCB Destruction Program which called for the siting of federally-sponsored, mobile PCB incinerators in regions across Canada, as opposed to the use of only one transportable incinerator.154  35  Despite the shortage of disposal facilities within Canada, federal Environment Minister Robert de Cotret announced on 1 August 1990, a ban on all overseas exports of PCB wastes.155 Under CEPA. the PCB Waste Export Regulation prohibits the overseas export, and the offer for export, of any PCB waste to any country except the United States.156 This regulation puts into practice the federal government's commitment, as a result of protests at British ports to turn back ships carrying PCBs, to manage, domestically, all PCB wastes.157 Currently, the only permanent disposal facility in Canada is located at Swan Hills, Alberta. Two mobile facilities have been sited, one by the Ontario provincial government at Smithville, Ontario, and the other by the federal government on federal land at Goose Bay, Newfoundland.158 Public consultation processes are being conducted to site additional facilites in Central Canada. At this time, in the absence of more disposal facilities, the federal government's policies are reliant upon the long-term storage of PCBs. The federal government's Green Plan, released in December 1990, provided an update of the progress of the national PCB disposal program, reporting that 40% of the federal PCBs have been safely destroyed since 1989.159 Also announced as part of the Plan, was the extension until 1996 of deadlines for the disposal of all federal PCBs, and the establishment of mobile incinerators in Atlantic Canada, Quebec, and Ontario.160  B.  The Process Streams To examine the dynamics of the agenda-setting process, John Kingdon's  model will be applied. In his paper, "Agenda, Alternatives and Public Policies", Kingdon builds an analytical approach to agenda-setting based on  36 the Cohen-March-Olsen "Garbage Can Model of Organizational Choice".161 Kingdon outlines this model as follows: Conceive of three process streams flowing through the system - streams of problems, policies, and politics. They are largely independent of one another, and each develops according to its own dynamics and rules. But at some critical junctures the three streams are joined, and the greatest policy changes grow out of that coupling of problems, policy proposals, and politics.162 With the first stream, Kingdon focusses on why one set of problems is selected out of the numerous problems that may come to the attention of the public and the government.163 A problem may be brought to the government's attention by systematic indicators, feedback from existing programs, or events attracting substantial media coverage and raising public concerns. The second stream refers to the many policy proposals generated by what Kingdon terms "a policy community of specialists".164 These policy alternatives are circulated, some of them incorporated into policy programs, and others are discarded. The third stream refers to the political dynamics at work.165 Policy actors, as well as events such as elections and changes in public opinion, often influence the choice of items placed on the government's agenda. For the most part, these three streams work independently of one another. Kingdon suggests that agenda and policy change take place when these streams come together at a "policy window".166 When this occurs, the problem is defined, a policy alternative developed, and the right timing for policy change is provided by the politics stream. In conceptualizing the ideas and events in the cycle as not flowing systematically, Kingdon's model emphasizes the dynamic nature of the policy cycle. The course of these three process streams cannot always be  37  predicted. For instance, it is not clear that a policy solution must be identified before a policy issue can be moved through the cycle. In the case of PCBs, we will assert that the problem and politics streams are the key considerations over the policy stream.  1.  Policy For the most part, the policy stream for PCBs has been a steady one.  Since the PCB problem was first identified and placed on the research agenda, the federal government has been developing regulatory policies for the use, handling, phase-out, storage and disposal of PCBs. These policies, however, have not led to a resolution of the issue, primarily because of intervening considerations such as the costs to industry, and public opposition. For example, although the alternative technologies for the disposal of PCBs were developed early on, they were not implemented. Certain policies have led to a compounding of the problem. The initial focus on the minimal policies of natural attrition has placed an increased reliance on the transport and storage of PCBs. Consequently, numerous policy adjustments have been formulated in the policy stream in response to this problem of compounding. After the ECB review, other policies and programs were developed for an active phase-out of PCB-filled equipment.  2.  Problem Early in the regulatory history of PCBs, while the issue was on the  research agenda, many of the parameters of the PCB problem were defined. While some uncertainty about the harmful effects on humans remain, the hazardous effects on the environment have been well-studied. Apart from  38 these systematic indicators, the ECB's review in 1980 identified additional problems with the natural attrition program that had been put in place. Perhaps the most critical determinants in the policy stream were the two accidents in the 1980s which focussed public attention on PCBs. The Kenora Highway Spill brought to the public's attention the need for stricter regulations on the transport of PCBs. The St. Basille-le-Grand PCB Fire, which received national media coverage over several weeks, again focussed public attention on the problem and moved it back onto the systemic and decision agendas. This focussing event drew the attention of the Canadian public to the storage facilities located in their own communities. This fire increased public scrutiny of these facilities and concerns of future such accidents. Attention was also drawn to how PCB storage was being managed and monitored, leading to calls for stricter regulations. The event also brought attention to the lack of disposal facilities, which has resulted in a greater reliance on PCB storage sites. The challenge to the federal government was to immediately improve on the regulations for PCB storage, and increase the amount of PCB disposal over the long-term.  3.  Politics With the heightened public attention following the St. Basille-le-Grand  Fire, the PCB politics stream may be viewed as driven by the federal government's desire to take advantage of an electoral issue. The coupling of this focussing event with the impending federal election in November 1988 provided the opening and right political timing to move the PCB problem back onto the systemic and decision agendas. Clearly, both the problem and the politics streams contributed to the opening of a policy window for the government's agenda to be set.167  39 Environment Minister Tom McMillan played a key policy entrepreneurial role in bringing the PCB policy proposals to the policy window. In order to appear determined and decisive, McMillan used the political momentum from the focussing event of the PCB fire to put in place national standards for PCB storage. Consequently, quick policy pronouncements were made without proper consultation with provincial counterparts, and before the department bureaucrats could determine whether they could meet the goals.168 As traced in the chronology, in the months immediately following the fire, policies that had been on the regulatory agenda for years were announced. In the next chapter we will examine how these proposals were evaluated in order to select the best policy solution. A key consideration for the politics stream is the public's attention-span which, in this case, helped to keep the PCB problem on the systemic agenda. Anthony Downs suggests in his "Issue Attention Cycle Model" that "each of these problems suddenly leaps into prominence, remains there for a short time, and then-though still largely unresolved-gradually fades from the center of public attention."169 After the initial discovery of the problem, the "euphoric enthusiasm" gradually fades as the policy-makers and the public realize that quick solutions may not be readily available nor desirable if they address only short-term concerns.170 In the case of PCBs, it seemed that public attention waned when they assumed that the problem would be resolved by the proposed programs. After the fire was cleaned-up and the residents returned to their homes, the media no longer had the attention-grabbing photo opportunities. The federal election campaign kept the issue on the systemic agenda, providing the opportunity for new policies to be introduced. However, as the issue moved  40 through the next stages of the policy cycle, public attention declined and the issue moved off the systemic agenda but remained on the regulatory agenda. Downs suggests that after the problem has been dealt with, the issue falls back onto a level of public interest which is still higher on average than the level of attention it previously received.171 This holds true, to a large extent, with PCBs, which continue to be regarded as a major hazardous waste threat. A survey conducted approximately eighteen months after the St. Basille-le-Grand Fire found the majority of Canadians as concerned now about PCBs, as they were during the six-month period following the fire. 172 Also, the Canadian public remains divided over whether any progress has been made in solving the PCB problem.173 As we will see in Chapter Four, this heightened public awareness causes some problems in the implementation process. This discussion of agenda-setting demonstrates that the problem and politics streams provided the opportunity for policy change. The focussing event of the 1988 fire brought national attention to the regulation of PCB storage facilities. In placing the PCB issue on the systemic agenda, this event, along with the impending federal election, provided the impetus to move the issue from the research agenda to the decision agenda.  41  Chapter III:  Decision-Making  Once an issue is moved onto the decision agenda, policy-makers must evaluate the alternative policy solutions and select the best course of action. Ideally, governments would follow a rational and comprehensive model of decision-making. By this logical and analytical approach, decision-makers first define the problem and then set objectives for the policy. They then identify policy alternatives to meet these objectives and evaluate their costs and benefits. An alternative that best achieves their goals of maximizing benefits while minimizing costs is eventually selected and implemented. This model may look ideal in theory, but is hard to follow in practice. Policy-makers have a limited ability to gather and process all the necessary information. Often-times the information needed is not available, requiring assumptions to be made. Also, with the different policy actors and interests at play, it is difficult to gain full agreement on the best policy solution. As we will see in the natural attrition policy agreed upon by industry and government, the end result may only be the best political compromise and not the optimal solution. Furthermore, policy-makers cannot control or predict all the factors involved. As we have seen in the chronology, the decision-making approach has been quite reactive, introducing new regulations or amendments to existing ones in response to accidents. A better model to frame our discussion of decision-making is the incremental model, as developed by Charles Lindblom.174 Rather than start from the beginning of the process, decision-makers work with the existing programs and make small, marginal adjustments. Consequently, time and  42  effort is not spent on redefining problems or goals, enabling a quicker response in crisis situations. This model appropriately describes the numerous adjustments made by policy-makers in addressing problems with past PCB regulatory policies. When some policy goals proved more difficult to attain, and some of the assumptions found invalid, incremental adjustments were made. In this chapter, the key elements of the incremental decision-making processes dealing with the PCB problem will be examined. The PCB case demonstrates some of the difficulties governments encounter in rational decision-making.  A.  Uncertainty Over the Hazards In formulating policies for the regulation of PCBs, policy-makers are in  an area of scientific uncertainty because of the lack of definitive studies on the direct effects of PCBs on humans. Although they are in fair agreement about the short-term effects of PCB exposure, scientists are less certain about the long-term effects. Policy-makers find that this uncertainty hinders rational and comprehensive decision-making. Nonetheless, they make value judgements that determine how scientific data are utilized to set standards. Policy decisions are made under substantial uncertainty regarding the risks associated with varying levels of exposure to PCBs. Estimates are relied on, usually in the form of probability statements, to predict the magnitude of toxic effects to humans from PCBs. The uncertainty surrounding the hazards of PCBs allows policy-makers greater leeway in determining the parameters of the policy problem, and of setting acceptable exposure levels. Since there are no definitive estimates on the carcinogenic effects of PCBs, policy-makers are able to take a  43  moderate and incremental approach to decision-making. As a result, policies formulated manage the PCB problem through control of their use. However, this uncertainty also forces policy-makers to rely upon their best estimates of the costs and benefits of various policy alternatives. For this reason, this decision-making approach is dependent on their ability to accurately assess the costs and the benefits, and to make appropriate assumptions when doing so.  B.  Costs and Benefits In developing a regulatory program, Canadian policy-makers were faced  with many policy issues including: alternative replacements for PCBs; acceptable levels of PCB use; availability of facilities to store and dispose of PCBs after their removal; and technical problems of removal, storage, and disposal. Through a discussion of these issues, the types of costs and benefits at the base of the policy decisions will be examined. Given the informal Canadian regulatory process, it is difficult to reconstruct decisions made along the way. However, the review by the ECB, established under the ECA. provides an opportunity to examine the initial PCB policies formulated in the late 1970s. A major tenet in Canadian PCB policy has been phase-out through natural attrition. This policy approach is evident in Chlorobiphenyl Regulations, No.1 and in subsequent amendments which prohibit any new use of PCBs and provide for the replacement of PCBs with alternative fluids that are relatively non-toxic. With the retirement of old PCB-containing equipment, PCBs are removed, stored and destroyed. An attrition policy is generally considered to exact less costs on industry than would a mandatory phase-out of PCB-filled equipment. In a  44 presentation to the ECB, the federal government explained that the basis of its attrition policy was to address the economic and technical concerns including the insufficient manufacturing capacity for the production of replacement fluids and equipment, and the shortage of storage and disposal facilities.175 A gradual phase-out program would provide the needed time to develop the replacement materials and site the required facilities. The Ontario Mining Association expressed support to the ECB of the "orderly retirement" of PCB equipment, and of the federal government's cooperative approach with industry: "It is essential that the financial burden which the industry is currently carrying not be increased."176 The regulatory approach of natural attrition has been somewhat lenient in allowing industry to continue using PCB-filled equipment in closed systems. The ECB suggested that "the important complementary assumption must be that there will be in place adequate and safe storage facilities as well as effective technical facilities for the current and continuing disposal of PCBs."177 This is the very basis of the federal government's attrition policy. Without the establishment of disposal facilities, this initial policy approach placed a greater reliance on PCB storage in facilities which may be unsafe. In their report, the ECB also contended that the uncertain time factor surrounding the attrition policy undermined the credibility of PCB regulations.178 These comments provide some preview of the policy changes that were to follow in the 1980s. The problems of increased reliance on PCB storage were illustrated by the fire at St. Basille-le-Grand. The costs of the attrition policy in terms of cleaning-up accidental fires at the storage facilities, outweighed the benefits. The financial costs of the fire were high and included clean-up,  45 property damage, reduced real estate values, destruction of crops, and lost businesses. The Quebec government provided more than $3 million in compensation to farmers whose land and crops were contaminated by PCBs.179 Two years following the fire, about one-third of the area's cattle meat were found to contain unacceptable levels of PCBs and had to be destroyed.180 The Quebec government also spent over $4 million on temporary lodging and restaurant meals for the 3,500 residents evacuated from their homes.181 In addition, there were negative effects on human health including the accident's psychological impact on children. A study conducted almost two years after the fire showed that a study of some of the 87 children who developed emotional problems due to the fire also exhibited above-average levels of anxiety and agoraphobia (a fear of open spaces).182 This fire demonstrated problems with the natural attrition policy approach, and gave an indication of the financial and psychological costs that communities must bear when there are accidents at poorly maintained PCB storage facilities. It also drew more attention to the severe hazards of toxic by-products released from high-temperature PCB fires. Consequently, the federal government realized that, in the absence of disposal facilities, the existing PCB regulations were not sufficient. National standards had to be put in place to ensure safe storage, and deadlines had to be set for the phase-out and destruction of PCB-filled equipment.  C.  Jurisdiction It is difficult to take a comprehensive and rational approach to  decision-making, when the decisions that policy-makers can make are restricted by the divided jurisdictions over PCB regulation. In responding to  46 the Kenora Highway Spill, the federal government made only incremental policy changes, bringing in the Transportation and Dangerous Goods Act and making amendments to the Chlorobiphenyl Regulations. Although the spill demonstrated the need for PCB disposal policies, the federal government restricted its decisions to the regulatory areas over which it had jurisdiction. The St. Basille-le-Grand accident prompted the federal government to develop national standards for PCB storage and disposal. The rationale for these incremental policy decisions was to reduce the potential for accidents through transportation or storage. To effect these decisions, the federal government expanded its regulatory activities into areas traditionally under provincial jurisdiction. The federal government had grown impatient with the restrictions on their ability to formulate policies. Environment Minister Tom McMillan used the fire at St. Basille-le-Grand as an indication of the ineffectiveness of the shared jurisdiction over PCBs: We are now dealing, with a situation . . . that is so serious that the full authority of the Minister of the Environment at the federal level should be exercised. Despite the best efforts of the two levels of government, the job is not being done sufficiently183well to meet the legitimate expectations of the public. McMillan put in place an interim order under CEPA to give the federal government the authority to ensure proper PCB storage. Under section 35 of CEPA. he suggested that the federal government has the power to move into provincial jurisdiction if it determines the province is not adequately protecting the public from hazardous materials.184 In particular, McMillan committed that". . . the federal government would move in any province where PCBs are stored to ensure their safe storage where in our judgement the province is not doing the job." 185 Under these circumstances, the  47  federal Environment Minister would seek an interim order which would have the full effect of regulation.186 However, in recognizing the provincial jurisdiction over PCB storage, the degree to which the federal government is able to exert this authority may be undermined by the provisions for opting out under CEPA. This will be examined as an implementation problem in the next chapter. To accompany the interim order, the federal and provincial environment ministers developed a national PCB program, setting the deadline for phase-out of PCB use by the year 1993.187 This placed a tighter time limit on the natural attrition policy. Recognizing that storage is only a temporary policy solution, the federal government also brought in a national PCB disposal plan. 188 However, this plan is limited to PCBs stored at federal facilities, and does not have a wider scope due to provincial jurisdiction over PCB disposal. For three years, the federal government had been trying to work out a national disposal plan with the provinces.189 Without jurisdiction, the federal government could only apply political pressure on the provinces. On several occasions, an agreement was nearly reached, particularly at a 1987 meeting of the Canadian Council of Ministers of the Environment (CCME, formerly known as CCREM).190 But negotiations between the federal and provincial governments continued to be long and unproductive, demonstrating the difficulty of establishing a national PCB strategy.191 In summary, three factors favour incremental decision-making in PCB policy formulation: uncertainty over the dangers of PCBs; the difficulty of estimating costs and benefits that change quickly; and jurisdictional constraints on policy-making. These factors have made it difficult for policy-makers to engage in rational and comprehensive decision-making.  48  Chapter IV:  The Implementation Process  Having examined the agenda-setting and decision-making stages of the PCB policy cycle, we can now turn to the implementation process. This stage is perhaps the most critical and, certainly in the case of PCBs, the most problematic. As previously suggested, the cycle is currently stalled in the implementation stage due to difficulties in siting additional PCB disposal facilities. In this chapter, we will use the Mazmanian and Sabatier model as a framework for our examination of the implementation process. The principal questions for analyzing the implementation process are as follows: (1) how consistent are the policy outputs with the policy objectives?; (2) how were these objectives modified?; and (3) what are the key conditions for successful implementation?192 By examining difficulties in the implementation process, we will also identify necessary considerations for future policy-making. As a starting point for our discussion, some comment must be made as to how well the policy outputs from the implementation process match-up with the policy objectives.193 In the PCB case, the policy outcomes in the federal government's jurisdiction~the regulatory areas of PCB use and transport-have been consistent with stated policy objectives. However, in policy areas, (such as PCB storage and disposal), which fall under provincial jurisdiction, the policy outputs do not match-up well with the objectives. We will later examine why this is the case. To determine how well the objectives have been met through the implementation process, an important measure is tractability.194 As defined by Mazmanian and Sabatier, a key requirement for tractability is the availability of inexpensive performance indicators.195 For PCBs,  49  tractability is measured by the following indicators: the concentration levels of PCBs in the environment; the number of PCB-filled equipment in use; and the number of safe storage sites. Recent reports suggest that PCB levels in the environment have gradually declined. For example, a monitoring program for the Fraser River Estuary indicated that in 1988, there were lower PCB concentrations in fish muscle tissue as compared to 1972/73 and 1980 records.196 Declines in PCB concentrations in localized areas, such as this one, indicate the positive effect of regulations on PCB use. 197 An important measure of the successful implementation of PCB storage policies is the federal inventory of storage sites. Compiled by Environment Canada, this national inventory provides a central registry of the PCB-filled equipment in use and in storage. Provincial environment departments regularly update the registry by sharing their monitoring reports on PCB storage sites. This inventory provides a good report on the progress of the regulations and the monitoring of PCB-filled equipment over their lifetime from manufacture to disposal. To evaluate policy implementation, it is crucial to have measures available to determine the location of PCB sites and the maintenance levels of storage facilities. Another important question, as outlined by Mazmanian and Sabatier, is the extent to which the original objectives and strategies were modified during the implementation process.198 In the policy areas involving provincial jurisdiction, the federal government encountered difficulties in implementing some of its objectives and strategies regarding PCB storage and disposal. For example, the implementation of a national standard for PCB storage has been put in doubt due to the majority of provinces opting out of the federal Interim Order. In addition, after a national inventory was  50 conducted, Environment Canada officials determined that the 1993 deadline for the PCB disposal plan was impractical and had to be pushed back to 1996.199 This extension was also due to the difficulties in the siting of disposal facilities. In the following discussion we will examine these two implementation problems of PCB storage and disposal policies. As mentioned, these policy areas are traditionally under provincial jurisdiction, hence the federal government's policy objectives may be undermined, requiring modification of its strategies. In fact, the most critical implementation problems in PCB regulatory history were encountered when the federal government attempted to lay down policies over regulatory areas under provincial jurisdiction. Mazmanian and Sabatier outline six conditions for successful implementation which may offer some explanation for the problems encountered in the implementation of PCB policies: (1)  the enabling legislation provides substantive criteria for problem resolution;  (2)  the enabling legislation incorporates a sound causal theory and provides officials with sufficient jurisdiction;  (3)  the enabling legislation structures the implementation process to maximize the probability that implementing officials and target groups will perform as required;  (4)  the leaders of implementing agencies possess substantial management and political skill, and are committed to statutory goals;  (5)  the program is actively supported by organized constituency groups and by a few key legislators, with courts being neutral; and  (6)  the relative priority of statutory objectives are not undermined over time by the emergence of conflicting public policies or by changes in relevant socio-economic conditions.200  51 From the regulatory history of PCBs, we find that several of the conditions are not so critical. For the most part, the first, second, and sixth conditions were met in the implementation process. In condition one, the stated objectives in the regulations are clear and consistent. Under condition two, policy formulation was based on a sound rationale to directly address the problems of unsafe storage facilities and the shortage of disposal facilities. With condition six, no significant socio-economic changes or conflicting public policies have emerged to undermine the policy objectives. The conditions most critical to the PCB case are the third, fourth, and fifth ones. By the third condition, the enabling legislation, structured under CEPA as a federal Interim Order for PCB storage, may undermine the probability that the provinces will meet the national standards. The primary concern is that the equivalency provisions prevent federal officials from exerting direct control over the regulation of PCB storage. As most of the provinces have opted out of the Order, the federal government must rely upon the cooperation and support of individual provinces to implement equivalent regulations for PCB storage. We will examine the provincial regulations to determine how closely they conform to the Interim Order. Following this discussion, we will review how the federal government has ensured that the provinces are maintaining and enforcing the standards outlined in the federal Interim Order. In the third part of this chapter, to demonstrate the importance of the fourth and fifth conditions, we will examine the problems that implementing agencies have encountered in the siting process. The focus will be on the importance of constituency support from local residents who, in many cases thwarted, and in a few cases helped, the process of siting a  52 disposal facility in their communities. We will also identify the skills that implementing officials require in dealing with these groups to successfully site a facility.  A.  CEPA: Equivalency Provisions Under CEPA. the opting out provisions enable the provinces to exempt  themselves from the federal interim order on PCB storage provided that they establish regulations which meet federal standards. When a province chooses to opt out, the federal government loses control over the regulation of PCB storage in that particular province. In this way, some critics have suggested that rather than helping to form a national standard, the opt out provisions weaken the interim order. Addressing this concern, a spokesperson for Environment Canada referred to the requirement that the opting out provinces establish regulations which meet federal standards: "The interim order is quite specific in terms of requiring access restrictions, fire protection restrictions, etc., so there would have to be those kinds of requirements under any provincial legal instruments for them to qualify."201 Provincial representatives have denied using the opt out provision to circumvent new and highly stringent standards. A provincial spokesperson for the Manitoba Environment Ministry stated, "The main advantage is there is only one jurisdiction that industry has to deal with. . . . We see PCB disposal and storage as a provincial responsibility and we do deal with local industry ourselves."202 Nine of the provinces, claiming that they have met equivalency with the federal guidelines, opted out of the Storage of PCB Wastes Interim Order.20 Only Prince Edward Island, along with the Yukon and the Northwest  53 Territories, continue to be regulated federally. Without their own regulations, they are under direct federal supervision in the implementation and enforcement of the requirements for PCB storage. A review of the provincial regulations indicates that Saskatchewan, Newfoundland, New Brunswick, and Nova Scotia have put in place similar, specific guidelines to those under the federal Interim Order. In contrast, Quebec, Alberta, British Columbia, Manitoba, and Ontario only have general guidelines for the management of hazardous material, under which it has specific guidelines for PCBs. In Alberta, British Columbia, and Manitoba, amendments were enacted to bring the provincial regulations up to equivalency to the Order. Immediately following the fire and before the introduction of the Order, Quebec made amendments to its provincial regulations which, in effect, provide equivalency to the Order. Ontario's regulations are written in such broad terms that the Order is applied in practice. Saskatchewan, Newfoundland, New Brunswick, and Nova Scotia brought in new PCB storage regulations in response to the federal Interim Order. They introduced regulations specifically written for PCB storage, making the same requirements as the Order in areas including: controlled access; method of storage; fire protection and emergency procedures; maintenance and inspection; labelling and signage; and record-keeping.204 In Saskatchewan, The PCB Waste Storage Regulations were introduced in April 1989, under the Environmental Management and Protection Act.205 Under these regulations PCBs can only be stored for periods exceeding six months with the approval of the Saskatchewan Environment Ministry. This requirement facilitates the consolidation of PCBs in one secure storage site set up by Saskatchewan Power near Estevan, Saskatchewan.206  54  Under the Waste Material (Disposal) Act of 1973, Newfoundland, in September 1988 introduced the Storage of PCB Waste Regulations.207 Newfoundland Environment Minister Jim Russell stated that,"... these regulations will strengthen our hand in this area of provincial jurisdiction and reassure the public that adequate attention is being devoted to this situation."208 After the federal Interim Order was introduced, New Brunswick brought in new PCB Storage Standards in November 1988 under the Clean Environment Act.209 Similarly, the PCB fire and the Order had a measured response in Nova Scotia, where the debate over the need for more stringent storage regulations had been ongoing for several years. Shortly after the Quebec fire, Nova Scotia's Environment Minister Don Mclnnis announced the government's approval of all the recommendations in a provincial task force report submitted in April 1987, on hazardous waste management.210 On 15 November 1988, Nova Scotia enacted the Dangerous Goods and Hazardous Wastes Management Act.211 Under this Act, the province's first regulations on PCB storage were introduced in July 1989.212 In the case of Quebec, as would be expected, there was an immediate response to the PCB fire, but independent of the federal interim order. Quebec was the only province to act before the federal order was introduced, largely due to its desire to be regarded in a positive and responsible light in its handling of the PCB problem.213 PCBs are listed in the province's Liquid Waste Regulations and the Solid Waste Regulation of the Environmental Quality Act, and in the Transport of Waste Regulation of the Transport Act.214  55 Under the Environmental Quality Act. Quebec introduced the Hazardous Waste Regulation in May 1985, which required approval certificates and operating permits for storage facilities.215 Following the PCB fire, these regulations were amended in August 1988 to set new standards for controlled access, fire control and emergency procedures, and record-keeping.216 Some of these amendments provide more stringent regulations than the federal interim order, such as the requirement for 24-hour security surveillance. The fines for violating these regulations were increased with the minimum changing from $5,000 to $30,000, and the maximum from $50,000 to $1 million.217 In addition, immediately following the fire, a comprehensive inspection was conducted of the more than 500 PCB storage sites throughout the province.218 This inspection was followed by another detailed one six months later. In Alberta, the storage guidelines under the Hazardous Waste Regulation set standards for storage facilities: controlled access, method of storage, labelling and signs, and fire protection and emergency response plans.219 These guidelines are general in nature, applying to different types of hazardous wastes, including PCBs. Under this regulation, the storage of PCB wastes for more than one year, or in an amount greater than ten tonnes, is permitted only with a licensed approval under the Clean Water Act.220 Shortly after the federal interim order was introduced, in March 1989, Alberta Environment Minister Ian Reid brought in Ministerial Order #04/89, as an amendment to section 4(4)(a) of the Hazardous Chemicals Act.221 Under the Order, specific guidelines were introduced, requiring all new PCB storage sites to register with the Alberta Environment Ministry within 30 days of being established. As in the federal Order, operators must provide, twice a year (January 1st and July 1st), detailed information as to the  56 storage location and the types of equipment being stored. This Order brings the Alberta regulations up to equivalency with the federal Order.224 Enacted in 1984, British Columbia's Waste Management Act does not specifically apply to PCBs. In April 1988, British Columbia introduced a Special Waste Regulation under the Act. 223 After the federal Interim Order came into effect, the province amended this regulation in April 1989, with section 17.1, "Additional requirements for short-term storage of PCB wastes", to bring the provincial regulations up to equivalency.224 Some of these amendments provide for PCB regulations which are more stringent than the federal Order.225 For example, weekly on-site inspections are required, as opposed to monthly ones in the federal Order.226 Manitoba's Dangerous Goods Handling and Transportation Act, enacted in August 1984, sets licensing guidelines for the handling, transport and disposal of PCBs, as well as defines operational standards for disposal facilities.227 Under this Act, PCBs are designated as hazardous substances. On 14 November 1988, Manitoba introduced the PCB Storage Site Regulation to set requirements equivalent to the federal Order.228 However, in terms of storage specifications, Manitoba has devised more comprehensive regulations than the Interim Order. Federal guidelines classify storage on one level, requiring the construction of concrete floors and curbing. Manitoba categorizes PCB storage into three levels based on weight and volume.229 The first level applies to storage sites containing PCB wastes with an aggregate volume or weight of less than 100 litres or 100 kilograms, respectively. These sites store the out-of-service PCB light ballasts found mostly in school districts.230 The second level applies to "medium storage sites" which contain PCB wastes with an aggregate volume or weight exceeding, respectively, 100 litres or kilograms. The third level  57  applies to "large storage sites" containing PCB wastes with an aggregate volume or weight of 10,000 litres or kilograms, respectively. At this level, the storage site must be equipped with a continuously monitored fire alarm system and flood-type fire extinguishers. The second and third levels mainly apply to the storage of transformers, capacitors and liquid forms. Under Ontario's Environment Protection Act. Waste Management, there are provisions for regulating the handling, storage and disposal of PCBs.230 In September 1984, amendments to these regulations were enacted, setting standards for storage and disposal facilities with specifications for operation, environmental controls, and record-keeping.232 Section 8 of the regulations stipulates that PCB waste must be stored under written instructions, or bear a certificate of approval from the Environment Ministry.233 These regulations give the Ministry the discretion to determine the requirements for PCB storage. The Ministry has been using the federal Interim Order as the basis for its instructions to storage site operators. As a result, in practice, the Ontario regulations should be equivalent.234 However, the application of the federal PCB storage standards are only at the discretion of the Ontario Environment Ministry. Hence, of all the provinces, the federal government has the least control over PCB storage in Ontario. Unlike the other provinces, there were no changes to the Ontario regulations in response to the introduction of the Interim Order. From the preceding examination of equivalency provisions, it appears that the nine provinces which opted out of the federal Order are meeting the standards set for PCB storage. This equivalency is largely due to sympathetic provincial officials, both elected and non-elected, who are willing to: (1) bring in new provincial regulations which provide the same  58  standards as the interim order; or (2) amend their current regulations to bring them up to the level of the order; or (3) apply the federal order in practice. As a result, while the federal government does not have direct control over the regulation of PCB storage in the majority of provinces, the cooperation of sympathetic officials helped to ensure that the guidelines and objectives of the federal PCB storage policy were implemented. As Mazmanian and Sabatier suggest in their definition of condition three, these sympathetic officials supported the federal order's objectives and placed a high priority on meeting the federal standards.235 With ten different provincial environment ministries, there could have been a wide and varied response to the Interim Order. To a large degree, the reason behind the support is the political incentives for provinces to deal with the issue of PCBs responsibly and decisively. Another reason is simply the potential reduction of similar accidents. Thus, the opting out clause of CEPA appears to be a useful mechanism for the federal government to set national standards in a regulatory area under provincial jurisdiction. However, consideration must also be given to how the federal government monitors and enforces the equivalency agreements. It is not sufficient to just bring in equivalent regulations. They must also be consistently enforced.  B.  Enforcement As another implementation problem, inconsistent enforcement may lead  to varied economic benefits across the regions. The federal government needs to work with the provinces to ensure that there is the same level of enforcement across Canada. As set out in Environment Canada's Enforcement and Compliance Policy, the Environment Minister must provide  59 an annual review of the administration of the federal-provincial agreements for the implementation of CEPA. including those covering the enforcement of equivalent provincial requirements.236 The criteria used to determine equivalency include the following:237 equal level of control as sanctioned by law; comparable compliance measurement techniques; comparable penalties; comparable enforcement policies and procedures that are consistent with this Enforcement and Compliance Policy; and comparable rights of individuals, resident in Canada, to request investigation of a suspected offence and to receive a report of the findings.  As the negotiations are still ongoing, there are no equivalency agreements in place between the federal and provincial governments.241 Since the majority of provinces have opted out, it is a difficult task for the federal government to maintain and monitor the national standards for PCB storage. In laying out procedures for measuring performance to ensure that provinces are enforcing their equivalent provisions, equivalency agreements are vital to the maintenance of national standards. Proper monitoring of equivalency cannot occur without these agreements, thereby undermining the confidence in how national standards are upheld by individual provinces. Despite the absence of the equivalency agreements, we can examine how the federal government monitors PCB storage across Canada by reviewing the enforcement activities of Environment Canada. Given that PCB storage is a provincial responsibility, provincial environment ministries monitor commercial and industrial storage sites. Environment Canada officials  60  should only be inspecting federal facilities such as airports and military bases. We find, however, from the records of Environment Canada, that they have not restricted their inspections to only federal facilities. As stated by an official, "We inspect everything in society that has PCBs."239 Working with the Storage of PCB Waste Interim Order, Environment Canada officials conduct investigations and inspections where warranted.240 The decision is made at the regional level as to how to proceed through the stages of inspection and investigation, as laid out in the Enforcement and Compliance Policy for CEPA.241 Generally, where there is a PCB spill and Environment Canada suspects negligence, an emergency crew will be dispatched to conduct a full investigation. The enforcement measures under CEPA provide for the legal prosecution of violators, with penalties ranging from fines of $200,000 and six months' jail, to fines of $1 million and three to five years' jail. 242 For offences involving criminal negligence, the penalty could be life imprisonment.243 These provisions place the onus on the officers and directors of the company to prove reasonable conduct; not on the prosecutor to prove negligence. In effect, a great responsibility is placed on any officer, director, or agent of the corporation, as they are liable for offences committed by the corporation.244 The Minister of the Environment's Report to Parliament on CEPA reports that, from 1988-1990, of the 1,017 inspections conducted under CEPA for the Interim Order, there were 104 enforcement actions.245 The report for the 1990-1991 period indicates that of the 392 inspections conducted, there were only 57 enforcement actions.248 Over this three-year period only one of these cases was actually prosecuted. In August 1989, West Isle Forest Products Ltd. of Victoria, British Columbia was charged with four  61 counts of violating the Interim Order. The company was found guilty and fined a total of $20,000 in April 1990.247 All the other cases of noncompliance were resolved with corrective action resulting from warnings or directives from Environment Canada.248 This overview suggests that there has been compliance with PCB storage regulations across Canada. The enforcement of the federal PCB storage regulation, scheduled to come into effect along with the equivalency agreements in September 1992, will be an important future determinant of how well Mazmanian and Sabatier's third condition for implementation is met in maximizing the probability of desired performance from implementing officials and target groups.  C.  Siting Process As a hazardous waste, PCBs pose difficult policy problems. We have  seen in our discussion of the parameters of the problem and the concerns of policy actors such as NIMBY groups, that a key to managing the problem through policy implementation is in dealing effectively with the public and their interests. In order to meet the policy objectives of the phase-out of PCBs, policy implementation requires the siting of PCB disposal facilities. We will examine the difficulties of these siting processes to demonstrate the importance of Mazmanian and Sabatier's fourth and fifth conditions for successful implementation. Much of this discussion will focus on the importance of gaining the support of local residents, and on how implementing officials can secure this constituency support through the use of various managerial and political skills.  62 In a society marked by incidents such as Three Mile Island and Love Canal, the public reacts negatively to the locating of nuclear reactors, landfill sites, or highway interchanges in their neighbourhoods. PCB storage and disposal sites strike at these fears. Although the federal government recognized public concerns over PCBs, it underestimated the problems that would be encountered in the siting process. The public wanted these PCBs removed, however, they didn't want PCB storage or disposal facilities in their own communities. As we have suggested, the public's fears centre more on the perceived harms of PCBs, than on their real dangers. These public concerns can be divided into two main considerations. First, the public want, and often demand, to be consulted. They desire some control over decisions that affect their communities. Without input and accountability, there will not likely be any constituency support, and the implementation process would come to a stop. An example of this type of reaction is that of the failed siting of a PCB disposal facility in Prescott, Ontario. Throughout the process, the public did not have any confidence in the handling of the siting. Public meetings over the proposed facility were emotional and confrontational, as many citizens felt their elected officials were not addressing their concerns.249 Consequently, in the ensuing municipal election, the entire town council was defeated.250 A second consideration is that local constituency groups need to understand the costs and benefits of the siting of a disposal facility in their community. Their perceptions of the risks of PCBs are often inflated, overshadowing any recognition of the benefits. As a result, their concerns lie with the potential negative effects on their health and economic welfare. In NIMBY fashion, these groups are not supportive, because they resent having to deal with a problem that they did not create.  63  An example of this problem is another failed siting attempt, this time in Senneterre, Quebec. Located 550 kilometres north of Montreal, the community of Senneterre opposed a proposal by a toxic waste disposal company, Sannivan, to build an incinerator for disposing all of Quebec's PCBs. A common front of environment and farm groups, unions and local residents formed to oppose the construction.251 A spokesperson for the group argued that if the disposal process is safe, the PCBs should be disposed of in Montreal where larger volumes of PCBs are stored. Thus, their stand was, "Destroy your own wastes."252 The Mayor of Senneterre, Denis Sawyer, recognizing the economic benefits of the incinerator to the community, supported the Sannivan plan and, consequently, received a lot of public criticism.253 In July 1988, the community coalition succeeded in blocking the plan through court action.254 These two examples give some indication of the potentially contentious nature of siting. Public fears, when coupled with a distrust of politicians, are a damaging combination to the implementation process. Any suggestion that decision-makers are shielding the public from information will exacerbate fears. In many cases, constituency groups may actively campaign against the siting of a disposal facility. While these groups are typically low on resources, they will use a wide variety of tactics including public protests and court actions, as seen in the Prescott and Senneterre examples. Bearing these problems in mind, governments must handle these situations carefully and fairly. The importance of dealing with the public's concerns, and of gaining their support, has been recognized throughout the regulatory history of PCBs. In their 1989 report on siting, CEAC concluded that "the siting of hazardous waste destruction facilities, such as PCB incinerators, is  64 primarily a social process, rather than solely a technological process."255 This view is similar to an earlier conclusion by the Environmental Contaminants Board of Review made in 1980 that". . . the placing of higher priority on storage and disposal is not a technical problem but a socio-political one." 256 Despite these conclusions, the federal government responded to the public's concerns by introducing policies and action plans, instead of correcting their misperceptions about the hazards of PCBs. In this way, the government's handling of the PCB issue has, whether intentionally or not, contributed to the blurring of the true hazards of PCBs. To address public concerns, implementing officials need political and managerial skills, as outlined in Mazmanian and Sabatier's fourth condition. Stephanie Hunt, Director of the Federal PCB Destruction Program, points out that Environment Canada is largely a natural science-based organization whose expertise is technical research.257 These officials have the scientific and technical skills, but not necessarily the communication and tactical skills, to manage public concerns. As Hunt states, "It [defining public choice] is challenging us to move away from our traditional modus operandi."258 Officials need the skills to effectively communicate to the public and media, Environment Canada's program for dealing with PCBs. They must be able to convince the local communities of the benefits and needs for disposal facilities. Implementing officials must also have the tactical ability to deal with crises, should they occur. These assertions underline the importance of Mazmanian and Sabatier's fourth condition that the implementing officials be equipped with the skills to gain the public's confidence.  65 In the following discussion, we will further examine the problems of gaining constituency group support and the skills required from implementing officials. We will demonstrate that if constituency support is secured, the siting process is likely to be successful.  1.  Consultation and Accountability One approach implementing officials should use in the siting process is  to make it as open and accountable as possible. In her analysis of the dynamics with which political leaders are faced in the siting process, Judy Wilson asserts that the difficulty lies in part with a political body that must make apolitical and objective decisions to assess the dangers to the environment.259 In attempting to determine the impact of a disposal facility on the environment, the public is highly sensitive to any perception of a closed process. The process must be open and stand the test of public scrutiny. There must not be any perceived conflict of interest; politicians must put the interests of the local community first in order to gain their support. Wilson contends that the best way to deal with this difficult situation is to ensure that the politician understands the requirements of the environmental assessment process, and the parameters within which he or she may exercise discretion.260 As Wilson points out, the incorporation of more public consultation into the siting process, while helping to diffuse the NIMBY problems, may place the politician in a tight spot by undermining his or her ability to make decisions on behalf of the community.261 Thus, although it is critical to open up the process as much as possible, precautions should be taken to ensure that the decision-making responsibilities of politicians are not undermined.  66  Another important consideration for implementing officials are the roles they play. In analyzing the implementation of the PCB disposal policy, the roles of proponent, regulator, and facility operator should be clearly distinguished. The mixing of the proponent and regulator roles undermines public confidence. It is rather difficult for a government to publicly defend a position as a proponent who is also self-regulating and self-monitoring. This position amounts to a conflict of interest. The public must have assurances that the regulator will perform its role without bias. CEAC is critical of how Environment Canada will carry out its duties under CEPA without a clear separation of the regulator and proponent functions.262 In the case of Goose Bay, the federal government divided up the responsibilities, with the Department of National Defence acting as the proponent, the Department of Supply and Services as the contractual agent, and Environment Canada as the regulator.263 In some provinces, crown corporations are responsible for PCB disposal, leaving provincial ministries to regulate. For example, Manitoba set up a public corporation named the Manitoba Hazardous Waste Management Corporation to dispose of hazardous wastes, while the Manitoba Ministry of Environment acts as the enforcing agent. This approach, also adopted in British Columbia, has not been successful in facility-siting. It appears that through non-involvement, politicians generate even greater public distrust of the process. The public needs to have confidence in the process through some means of accountability. In order to give the public a greater sense of control over the decisions made within their community, the public must be given every opportunity to assure themselves of the safety of the proposed facility. In their report, "PCBs: A Burning Issue", CEAC makes similar conclusions to those found by  67 Environment Canada during the first year of its PCB disposal program.268 Recognizing the social constraints, CEAC identifies a major principle: "that the federal siting initiative respects the rights of citizens to participate in and influence decisions which affect their interests."265 The best example of a successful siting process conducted by federal officials was the temporary facility at Goose Bay to dispose of federal PCBs. The process adopted by Environment Canada demonstrated many of the skills of consultation and communication required of implementing officials. This example also illustrates the importance of constituency support, particularly in the event of accidents during the implementation process. At Saglek, Cartwright, and the Canadian Forces Base in Goose Bay, the Department of National Defence (DND) stored approximately 3,500 tonnes of PCB-contaminated material in drums and vaults.266 Most of this material was contaminated soil from the clean-up of transformer spills at abandoned radar sites in Labrador during the 1970s and 1980s.267 In 1986, DND began a consultative process with the residents of the Happy Valley-Goose Bay area. A project committee, named the "Concerned Citizens Group on PCBs", was formed in November 1986 and composed of representatives from Environment Canada, Newfoundland Environment, and the Town of Happy Valley-Goose Bay.268 Involving the local community in the siting process right from the beginning proved to be quite successful. As a remote community whose local economy is largely dependent on the army base, there was little opposition in Goose Bay to the siting, due to the anticipation of the economic benefits. The open and consultative approach taken by Environment Canada was instrumental in enabling it to handle accidents effectively and responsibly.  68  Two incidents at the facility tested the skills of the implementing officials, and illustrated the importance of constituency support. Within the first three months of operation in February and April 1990, there were two shutdowns of the incinerator.269 In both cases, the shutdowns were due to power failures and malfunctions of the back-up exhaust systems. In the first incident, smoke and gases contaminated with PCBs escaped into the building. In the second incident, while no contaminants escaped, there was considerable damage to the system. The media and the Citizens Group was informed immediately of the shutdowns. After a full investigation of the incidents, further public meetings were held. In each case, the decision to resume operation was made with the agreement of the Town Council and the Citizens Group.270  2.  Understanding the Costs and Benefits Another important consideration for implementing officials is how to  deal with the public's motives and interests. Most people do not understand the benefits of siting a PCB storage or disposal facility. Instead, they only see the costs. From James Q. Wilson's model of the distribution of costs and benefits, we can see that people do not want to bear costs, perceived or real, unless they are outweighed by tangible benefits.271 In his approach to public policy analysis, Wilson defines a cost as "any burden, monetary or nonmonetary, that some people must bear, or think they must bear if the policy is adopted", and a benefit as "any satisfaction, monetary or nonmonetary, that people believe they will enjoy if the policy is adopted."272  69 On this distribution scheme of costs and benefits, the PCB disposal problem can be defined as having concentrated costs and distributed benefits. Concentrated costs in terms of perceived dangers to a local community, and distributed benefits to the larger population through the elimination of PCBs. Wilson terms this distribution as entrepreneurial politics: "Society as a whole or some large part of it benefits from a policy that imposes substantial costs on some small identifiable segment of society."273 In successful sitings of PCB disposal facilities, implementing officials worked with local residents to encourage them to take ownership and responsibility for the PCBs stored in their community. Wilson contends that if you can change the public's perceptions, you can alter the nature and balance of the cost-benefit situation.274 One way to do this is to help the public understand that making sacrifices now, will lead to greater benefits in the future. An example of a successful siting is the case of Smithville, Ontario, where the local community realized the costs and need for a disposal facility. The Smithville site, with an estimated 180,000 litres, contained the largest stockpile of PCBs in Canada.275 (In comparison, the St. Basille-le-Grand site contained 117,000 litres.276) Originally, the site was to serve as a transfer depot for PCBs from across the country enroute to disposal facilities in the United States.277 However, when the United States closed its borders to PCBs in January 1979, the transfer site became a privately-run storage facility under provincial regulation.278 In 1985, PCBs were discovered leaking from oil drums and electrical transformers into the soil at the abandoned waste site. 279 To contain the problem, the Ontario provincial government spent about $25 million to place the contaminated material in containers, secure the site, and pipe drinking  70 water into the community.280 With the agreement of the local community, a high-temperature rotary kiln was installed on the site to destroy 6,000 cubic metres of contaminated soil from January 1991 to March 1992.281 The experience of London, Ontario also provides a good example of a siting process in which the local community voluntarily chose to pursue the siting of a PCB disposal facility. In this case, the community was interested in siting a disposal facility because of the economic benefits to be derived, as opposed to the avoidance of further costs (as in the case of Smithville). The local MP for London-Middlesex, Terry Clifford, an environmental advocate, contacted Environment Canada to investigate the potential for siting a disposal facility in his riding.282 He initiated the discussions between Environment Canada and local politicians and officials, electrical utility representatives, and local environmental groups. A coalition of citizens called "Operation Londoners for the Elimination of All PCBs" (Operation LEAP) was subsequently formed.283 In this case, Environment Canada officials took the initiative, taking members of this group to tour the Goose Bay facility and view the testing of the VESTA mobile incinerator at Swan Hills. Following this tour, Operation LEAP formally asked the Environment Minister for assistance. Environment Canada has since committed to the funding of a community involvement program and the technology selection and siting program.284 Currently, Operation LEAP is working with Environment Canada towards an implementation plan by 1992. In order for successful sitings to take place, as in the approach with Operation LEAP, implementing officials should take an active promotional approach with local residents. As a politician with the necessary communication and tactical skills, Clifford helped to guide this approach.  71 By far, the most successful siting process has been in Alberta. In its siting of a toxic waste treatment plant, the Alberta provincial government involved the local communities by inviting them to submit proposals.285 Out of the seventy communities that responded, Swan Hills was selected for the $50 million plant. Like other communities, Swan Hills recognized the tremendous economic benefits of the disposal plant. The open-bidding process avoided any prolonged debates that may have occurred if Alberta had forced a facility on a community on the basis of technical suitability. From this successful siting process, Connor identifies five instructive principles for implementing officials: (1) understand your community; (2) educate your community; (3) involve your community; (4) ensure your proposals are equitable; and (5) encourage your supporters, not your adversaries.286 These principles are key to gaining the support of local residents. From the two more successful siting processes in Swan Hills and Goose Bay, Environment Canada officials have learned important elements to incorporate in their own approaches to site mobile incinerators in the Atlantic and Ontario, under the Enhanced Federal PCB Destruction Program. These elements have been incorporated in Environment Canada's reformulation of its approach to siting and new policy initiatives. On 22 August 1990, a "Memorandum of Understanding Concerning the Siting of a Mobile PCB Incineration Unit in Atlantic Canada" was signed by the federal Environment Minister together with the four environment ministers of the Atlantic provinces.287 The objective of this agreement is to find a site in the Atlantic provinces to destroy high-level PCB wastes in the region within three to four years. At the signing, all Ministers made commitments to ensure a public consultation would be conducted to select the temporary  72 site. Two key principles of this consultation are "self-selection of communities", and "community veto".288 In summary, our discussion of several siting attempts demonstrates that constituency group support is a necessary condition for the implementation of PCB disposal policies. If local groups are not supportive, they may block the siting process. In contrast, if they are supportive, they may voluntarily seek to have the disposal facility sited in their community. Implementing officials play a key role in gaining constituency group support. It is important that they possess the managerial and political skills to address the concerns of the public in an open process and promote the benefits of disposal facilities.  73 Conclusion  The PCB case leads to seven major conclusions about the dynamics of the public policy cycle. First, policy problems are not simply solved by the formulation of policies. It is not enough to identify the problem and develop a solution, because the policy must still be implemented. In the process of implementation, policy-makers may discover that the problem has not been properly defined, or the correct policy has not been developed, requiring policy reformulation. Consequently, several agenda-setting, decision-making, and implementation stages may be needed before the right policy solution is found and implemented. As demonstrated in this study, in each period of the regulatory history of PCBs, policies were evaluated and reformulated in an effort to resolve problems from the previous period. Second, a major cause of the complexities of the policy process is the problem itself. The problem that PCBs pose to policy-makers involves not only its actual hazards, but also its perceived ones. The scientific uncertainty surrounding the dangers of hazardous wastes, such as PCBs, leads to a greater potential for policy actors, particularly the media and politicians, to fuel public concerns. This uncertainty also contributes to difficulties in making rational and comprehensive policy decisions. Third, an important factor in the policy cycle is the focussing event. In 1988, the St. Basille-le-Grand Fire was a focussing event that brought nation-wide attention to the PCB issue and increased public concern over similar accidents occurring in their communities. This event moved the PCB issue up the regulatory agenda from the research to the decision agenda, prompting the federal government to focus on the problem. Together with  74 the impending federal election, this event provided a policy window for the government's agenda to be set, and for policy change to take place. The fourth major conclusion is that as a result of factors including invalid assumptions and jurisdictional constraints, policy-makers often engage in incremental decision-making. The PCB case demonstrates that policy-making is not a rational and comprehensive exercise in which all the needed information is available, nor are all the variables controlled and anticipated. Accidents in the mid- to late 1980s proved some of the initial policy assumptions to be invalid, necessitating policy reformulations. They also caused a recalculation of the costs and benefits of the policies. Furthermore, divided jurisdictions restrict the ability of policy-makers to effect comprehensive policy changes. Fifth, an examination of the provincial regulations for PCB storage confirms that successful implementation requires sympathetic officials who are supportive of the enabling legislation. Despite the exemptions under CEPA from the Interim Order on PCB storage, the federal government has succeeded in effecting national standards in a policy area not under federal jurisdiction. This is largely due to sympathetic officials who supported the federal Order and gave a high priority to matching provincial regulations to it. This finding may be extended to other policy-making challenges to the federal system, as an example of how the opt out clause does not necessarily lead to a weakening of national standards. Sixth, constituency group support is a necessary condition for policy implementation. Local residents may hinder the implementation process through public protests, court actions, or other means. They want to be involved in the policy decisions that affect their community. In the PCB case, if a community understands the benefits and the actual costs of a  75  proposed disposal facility, then it may voluntarily seek the siting of one. Also, the support of local residents is important once a facility is sited, to deal with any accidents which may occur. Seventh, in implementing policies which deal with an issue of great public concern, officials must address not only the technical aspects of the solution, but also the political ones. The rise of the environmental agenda in the 1980s has resulted in higher public expectations for the protection of the environment. As demonstrated by the implementation problems encountered in the PCB disposal program, this heightened public interest in the environment places difficult demands on the federal government. Consequently, officials with managerial and political skills are required to implement the policies. Once the problem is defined and the right technical solutions are developed, implementing officials must give the public some sense of confidence in the process by emphasizing its accountability and openness. They must also make better efforts to educate the public about the benefits and the true costs involved in the implementation of a particular policy. In conclusion, policy problems are seldom solved the first time through the cycle, thus requiring policy reformulations. In identifying the policy problem, a crucial determinant is how the problem is perceived by the public. This case study also confirms the importance of focussing events in the agenda-setting process. The analysis of the policy cycle of PCBs demonstrates that decision-making for Canadian policy-makers is often incremental, particularly in policy areas under divided jurisdictions. The exaggerated risks and inflated public concerns of political chemicals, such as PCBs, make it difficult to gain constituency group support, which is  76  necessary for policy implementation. In order to deal with these challenges and jurisdictional constraints, implementing officials need to be both skilled and sympathetic to the policy.  77  Endnotes 1  Kathryn Harrison and George Hoberg, "Setting the Environmental Agenda in Canada and the United States: The Cases of Dioxin and Radon," Canadian Journal of Political Science XXIV. 1 (1991): 1-27.; Richard Simeon, "Studying Public Policy," Canadian Journal of Political Science IX.4 (1976): 548-580.; and Bruce Doern and Richard W. Phidd, Canadian Public Policy (Toronto: Methuen, 1983). 2  Liora Salter, "Political Chemicals Case Study 3: The Toronto Lead Controversy," Mandated Science (Dordrecht: Kluwer Academic Publishers, 1988)98-122. 3  Salter 122.  4  Salter 123.  5  Salter 125.  6  Charles o. Jones, An Introduction to the Study of Public Policy, 3rd ed.  (Monterey: Brooks/Cole, 1984) 36. 7  Jones 30.  8  Charles E. Lindblom, "The Science of Muddling Through," Public Administration Review 14 (1959): 79-88. 9  Brian W. Hogwood and B. Guy Peters, "The Dynamics of Policy Change and Policy Succession," Policy Sciences 14 (1982): 226. Hogwood and Peters assert that while both policy succession and policy innovation can be analyzed in terms of its stages, policy succession is constrained by the existing policies which the proposed succession is designed to replace (234). They argue that past decisions, good or bad, limit the range of future policy-making (234). This model is attuned to the recycling (or evolution?) of policies, and in turn, the perspective that the policy-making process does not necessarily follow a rational and systematic pathway (234). 10  Environment Canada, Canadian Environmental Advisory Council,  Listing Toxics Under CEPA--ls the Chemistry Right? (Ottawa: C E A C , 1988) 3. 11  Environics, Environmental Monitor (Toronto: Environics Research Group Ltd., July 1989). 12  Environment Canada, Canadian Council of Resource and Environment Ministers, The PCB Story (Toronto: CCREM, 1986) 2. 13  CCREM.PCBStory4.  14  CCREM,£CB_Sjoiy2.  15  Douglas M. Wilson, The PCB Imbroglio: 1989 (West Vancouver: Environment Canada, 1989) 2.  78 16  An inventory report by Environment Canada has identified 15 major industrial sectors and 22 other sectors using PCB equipment. 17  D. Wilson, lmJacogJlQ 2.  18  The brand names for PCBs include Arochlor, Hyvol, Pyranol, and Inerteen. Although they were originally designed to be mixed with oil for use as fire retardants, PCBs have many other commercial uses. They have been used in carbonless copy paper, printing inks, plasticizers, special adhesives and lubricating additives. In smaller quantities, PCBs have been used in electrical capacitors to correct the electrical power factor which results in greater efficiency. They also have been used as hydraulic and heat transfer fluids in heavy equipment and heat exchangers, and to improve the waterproofing properties OT surface coatings. 1  9CCREM,E£B_3ioiy.9.  20  Christie McLaren, "No Escape from PCBs, Scientist Says," Globe and Mail 30 Nov. 1985: A21. Health and Welfare Canada and Agriculture Canada have disputed these figures and questioned these findings, suggesting that their own random samples of food plants and the fat of beef, swine, and poultry have shown no problems with PCBs. 21  Prior to 1978, PCBs were commonly used in road oil.  22  PCBs are completely destroyed at temperatures exceeding 1,100°C.  23  D. Wilson, Imbroglio 4.  24  Douglas Hallett, "Human Exposure," PCBs: A Case Study. Report to the Council of Great Lakes Research Managers, Proceedings of a Workshop on Great Lakes Research Coordination held in Windsor, 20-22 Nov. 1985 (Windsor: Council of Great Lakes Research Managers, 1985) 15. 25  Shinsuke Tanabe, "PCB Problems in the Future: Foresight from Current Knowledge," Environmental Pollution 50 (1988): 11. 26  Tanabe 11.  27  Tanabe 14. The primary method of transfer is through lactation to offspring. 28  Douglas Wilson, Control of PCBs: A Historical Perspective (West Vancouver: Environment Canada, 1989) 4. 29  D. Wilson, lmbjEflJio. 5.  30  D. Wilson, Imbroglio 4-5.  31  P. Wilson. Imbroglio 4.  32  Tanabe 13.  79 33  Tanabe 16.  34  N. Ito, H. Nagasaki, S. Makiura, and M. Arai, "Histopathological Studies on Liver Tumorigenesis in Rats Treated with Polychlorinated Biphenyls," Gann Monographs on Cancer Research 65 (1974): 545-547. See afso R.H. Weltman and P. H. Norback, "Hepatic Ultrastructural Changes in Rats Exposed to Polychlorinated Biphenyl Isomers: Hexachlorobiphenyl-lnduced Neoplastic Nodules." Toxicology and Applied Pharmacology 48 (1979^: A181. 35  An important consideration in examining the PCB problem is the role of science itself. It is commonly perceived that in cases in which human life is potentially threatened, science is relied on to guide policy outcomes. However, as will be seen in our discussion of policy actors, this is seldom the case, in part due to the disputes among the actors over the hazardous effects of PCBs. 36  CCREM.PCBStory14.  37  Martin Mittelstaedt, "PCB Levels Called Risk to Babies-Safety of Mothers' Milk Uncertain, Great Lakes Advisory Board Declares," Globe and Mail 31 Aug. 1991. 38  Mittelstaedt, Globe and Mail 31 Aug. 1991.  39  B.G. Bennett, "Exposure of Man to Environmental PCBs-an Exposure Commitment Assessment," Science of the Total Environment 39 (1983): 101-111. 40  See H.E.B. Humphrey, "Population Studies of PCBs in Michigan Residents," PCBs: Human and Environmental Hazards (1983), as cited in Douglas Hallett, "Human Exposure," PCBs: A Case Study. Report to the Council of Great Lakes Research Managers, Proceedings of a Workshop on Great Lakes Research Coordination held in Windsor, 20-22 Nov. 1985 (Windsor: Council of Great Lakes Research Managers, 1985)13. Humphrey's study of Great Lakes fish-eaters indicated a significant difference between serum PCB levels of trout-eaters and controls. 41 42  See Humphrey, as cited in Hallett 13. CCREM.PCBStorv14.  43  K. Higuchi, ed., PCB Poisoning and Pollution (New York: Academic Press, 1976); and M. Kuratsune and R. E. Shapiro, eds., PCB Poisoning in Japan and Taiwan. (New York: A. R. Liss Press, 1984) 155. 44  T. Yoshimura and M. Ikeda, "Growth of School Children with Polychlorinated Biphenyl Poisoning or Yusho," Environmental Research 17 (1978): 416-425. 45  M. Harada, "Intra-Uterine Poisoning, Clinical and Epidemiological Studies and Significance of the Problem." Bulletin of Environmental Contamination and Toxicology16 (1976): 559-566.  80 46  Environment Canada, "Chapter 5: Toxic Effects of PCBs," Polychlorinated Biphenyls (PCBsV-Fate and Effects in the Canadian Environment (Ottawa: Environment Canada, 1988). 47  D. Wilson, Imbroglio 5.  48  D. Wilson, Imbroglio 5.  49  "Chemical Food Additive-PCBs Have Become an Unwanted Part of the Daily Diet of Every Canadian," Canada and the World Feb. 1986:1. 50  "Chemical Food Additive," Canada and the World Feb. 1986:1.  51  "Chemical Food Additive," Canada and the World Feb. 1986:1.  52  Stephen H. Safe, Kathy Farrell, Roy Bannister, Michael Kelley, Stelvio Bandiera, and Grant Mason, "Health Effects of PCBs and Related Substances," Industry and PCBs: Practical Solutions to PCB Problems (Pickering: The Canadian Electricity Forum Inc., 1987) 26. Charles Lynch, in his article, "The Case Against the PCB Scare," as reported in Province 11 Jan. 1989:18, cites Dr. Walter Harris of the University of Alberta as stating that "an enormous amount of information has been received and it is obvious that transformer workers from the 1930's, '40s, '50s, and '60s using PCBs day after day, were not adversely affected in terms of their health. Simply put PCBs do not appear to represent an important health hazard to human  beings." 53  See D.P. Brown and M. Jones, "Mortality and Industrial Hygiene Study of Workers Exposed to Polychlorinated Biphenyls," (1981), as cited in Safe et. al., "Health Effects of PCBs and Related Substances." Industry and PCBs: Practical Solutions to PCB Problems (Pickering: The Canadian Electricity Forum, 1987)26. 54  W.R. Gaffey, "The Epidemiology of PCBs," PCBs; Human and Environmental Hazards (1983), as cited in Safe et. al., "Health Effects of PCBs and Related Substances," Industry and PCBs: Practical Solutions to PCB Problems (Pickering: The Canadian Electricity Forum, 1987) 26. 55  D. Wilson, Imbroglio 7. For dibenzofurans to be produced, PCBs must be heated at high temperatures between 250°C and 700°C. There is little evidence to indicate that concentrations of PCB by-products, to which humans are typically exposed, are sufficient to endanger their health. 56  Safe et. al. I26. The Yusho incident resulted from a faulty heat exchanger in a food processing plant releasing most of its PCB heat transfer fluid into a batch of rice oil. It has been suggested that the high concentration of furans in the cooking oil may have originated from heating the PCBs in the heat exchanger, or when the contaminated cooking oil was itself being heated. The toxic effects commonly cited in the Yusho incident were due to high concentrations of the toxic PCDFs.  81 57  Tanabe 18. The development of more sophisticated measures has led to the detection of PCBs in the environment in concentrations of parts-per-trillion. More recently, other toxic components in commercial PCB fluids have been found. Known as co-planar PCBs, these chemicals are as acutely toxic as most furans and dioxins. 58  Randolph Hurst, "Facts about PCBs," Industry and PCBs: Practical Solutions to PCB Problems (Pickering: The Canadian Electricity Forum, 1987) 14. 59  Canadian Environmental Advisory Council, A Report to the Federal Minister of the Environment, PCBs: A Burning Issue: On the Siting of a Mobile PCB Incinerator (Ottawa: Minister of the Environment, 1989) 17. CEAC questions whether mobile technologies can provide a complete answer to the federal government's objective of destroying all its PCB wastes. VESTA Technologies has mobile PCB incinerators which move on two flat bed trucks, as compared with ENSCO models which are better termed as a transportable PCB incinerator, requiring 6-9 flat beds (equivalent to the size of one football field). For an extensive study on available technologies, see P. Piersol, The Evaluation of Mobile and Stationary Facilities for the Destruction of PCBs (Ottawa: Environment Canada, 1987). 60  John W. Kingdon, Agendas. Alternatives, and Public Policies (Boston: Little, Brown and Company, 1984) 208. 61  Council of Great Lakes Research Managers, PCBs: A Case Study xii.  62  This was the primary reason cited in a 1983 public information brochure on PCBs published by Environment Canada on the lack of facilities. See Environment Canada, Environmental Protection Service, PCB: Polychlorinated Biphenvls (PCBs) Their Control and Elimination (Ottawa: Environment Canada,1983). 63  Desmond Connor, "Managing the "NIMBY Syndrome" in the 1990's: Principles and Cases for Waste Managers," Twelfth Canadian Waste Management Conference Proceedings. St. John's, Newfoundland, 3-5 Oct. 1990 (Ottawa: Environment Canada, 1990) 1. 64  Connor 1-2.  65  Connor 2.  66  Connor 2.  67  PCB Consultation: a statement by members attending on behalf of: West Coast Environmental Law Association, Ecology Action Centre, Green Peace, Society Promoting Environmental Preservation, Canadian Environmental Law Association, Environmental Coalition of Prince Edward Island, Quebec Public Interest Research Group-McGill. See Appendix B of Federal PCB Destruction Program. Proceedings of the National Stakeholder Workshop in Edmonton, Alberta, 22 Nov. 1989 (N.p.: Synergistics Consulting  82 68  D. Wilson, Imbroglio 3.  69  D. Wilson, Imbroglio 3.  70  Occupational exposure has lessened over the past two decades due to improved work procedures, protective equipment, ana safe personal hygiene, as prescribed in government regulations and codes ( D. Wilson, Imbroglio 8.). 71  Environmental Contaminants Board of Review, Report on PCBs (Polychlorinated Biphenvls) (Ottawa: Environment Canada, Health and Welfare Canada, 1980) 104. 72  Environmental Contaminants Board of Review, Report on PCBs 109.  73  Environmental Contaminants Board of Review, Report on PCBs 109.  74  Tracey Tyler, "'Safe' PCB Level is Far Too High Labor Critic Says," Toronto Star 12 Jan. 1987: A2. 75  Tyler, Toronto Star 12 Jan. 1987 A2.  76  Tyler, Toronto Star 12 Jan. 1987 A2.  77  Hurst 14.  78  Kingdon 20.  79  Terrance Wills, "Ottawa Could Have Averted Toxic Blaze: Opposition, Federal Government Accused of Delaying Use of Technology Designed to Destroy PCBs," Montreal Gazette 27 Aug. 1988: A-4. 80  Wills, Montreal Gazette 27 Aug. 1988: A-4. In Keeper's view, the federal government had the technology through NRC, but did not put a high priority on implementing it. Instead, the federal government chose to find private companies to use the technology to destroy the PCBs. 81  Terrance Wills, "Government is Pressed to Enforce Safe Storage, Destruction of PCBs," Montreal Gazette 30 Aug. 1988: A-5. 82  On 15 September 1988, Charles Caccia released the "Liberal Party Policy on PCBs" which included the following commitments: "(1) Promulgating national regulations for the safe storage of PCBs. (2) Swift introduction of standards and an approval process for PCB destruction technology, likely modelled on the Ontario Regulations which are the only regulations currently in place in Canada. (3) Eliminating all PCBs from use in Canada by 1993, starting with replacement in hospitals, schools and other public institutions." Caccia's policy paper also proposes some interesting amendments to CEPA: "(1) Give the Federal Government the power to issue enforceable national standards; and (2) Allow citizens, not only the Minister of the Environment, to seek an injunction to prevent a violation of the Act."  83 83  Pascal Dennis, "How Dangerous are PCBs-Really? Not at All," Globe aDdJMi4 0ct. 1989:A7. 84  Colin Isaacs, Executive Director, Pollution Probe, suggests that government is to be blamed as well for poorly educating the public. 85  Dennis, Globe and Mail 4 Oct. 1989 A7.  86  Media play an important role in the agenda-setting stage of the policy cycle, as we will see in our discussion of the "Issue-Attention Cycle" in the next chapter. 87  Kathryn Harrison, "Federalism and Environmental Policy in Canada," Dept. of Political Science, University of British Columbia (Vancouver: unpublished paper, 1989) 20-21. 88  Harrison 18.  89  Harrison 20.  9°CCREM,EQB_Sloiy.16. 91  CCREM. PCB Storv 16.  92  "Canadian Environmental Protection Act," Canada Gazette Part in,  Sept. 1988. 93  CEAC, Listing Toxics Under CEPA-ls the Chemistry Right? 14.  94  Canada Gazette Part III, Sept. 1988: 2-8. Tom Spears, "Standards Imposed for PCB Storage," Toronto Star 20 Sept. 1988: A-10. 95  9  6 Canada Gazette Part III, Sept. 1988: 28.  97  Canada Gazette Part III, Sept. 1988: 27.  98  Canada Gazette Part III, Sept. 1988: 27.  99  Canada Gazette Part III, Sept. 1988: 90.  100  Francine Laperriere, telephone interview, Aug. 1991 (Ottawa: Environment Canada, Regulatory Affairs). The authority under which these exemptions from the interim order were given is on the legal advice of the Department of Justice to Environment Canada. 101 102  Canada Gazette Part III, Sept. 1988: 5-6.  The CCREM is now known as the Canadian Council of the Ministers of Environment (CCME).  84  103  D. J. Pascoe, Management and Remedial Measures (Toronto: Environment Canada, 1986) 81. 104  Pascoe 8 1 .  105  Pascoe 8 1 .  106  Pascoe 8 1 .  107  See Appendix E, Environment Canada, Manual for the Management of Wastes Containing Polvchlorinated Biphenyls (PCBs) (Ottawa: Environment Canada, 1987)79. 108  See Appendix E, Manual for the Management of Wastes Containing Polvchlorinated Biphenyls (PCBs) 79. 1  °9 Canada Gazette Part 11. Jan. 1985.  110  Roger W. Cobb and Charles D. Elder, Participation in American Politics. 2nd ed. (Baltimore: John Hopkins University Press, 1983) 85. 111  Cobb and Elder 86.  112  Harrison and Hoberg 5.  113  Harrison and Hoberg 5.  114  Harrison and Hoberg 5.  115  Pascoe 80.  118  Canada Gazette Part 11. Sept. 1977.  117  Environment Canada, Environmental Contaminants Board of Review, Outside Review and Public Participation (Ottawa: Environment Canada, 1980)17. 118  Environmental Contaminants Board of Review, Outside Review and Public Participation 17. 119  Environmental Contaminants Board of Review, Outside Review and Public Participation 17. 120  See Environmental Contaminants Board of Review, Report on PCBs.  121  Canada Gazette Part II, July 1980.  122  Serving as a coordinating forum of efforts to control PCBs and hazardous wastes, this Committee became the CCREM Waste Management Committee in 1985 to work with the Toxic Substances Steering Committee of CCREM. 123  CCREM. PCB Story 8.  85  124  CCREM. PCB Story 16.  125  CCREM, PCB Story 16.  126  Mary Janigan, "The Trail of a Toxic Disaster," Maclean's 29 April 1985:14. The Alberta provincial government is no longer accepting PCB wastes from other provinces, for disposal at its Swan Lake facility. 127  Pacoe79.  128  Ross Howard, "'Spills Bill' Goes Too Far, Grits Told," Globe and Mail 30 May 1985:8. 129  Margaret Polanyi, "$1 Million Liability Law on Spills to Hit Owner, Shippers Next Month," Globe and Mail 25 Oct. 1985: A18. 130  This bill was originally passed in the Ontario Legislature in 1979, however, the Conservative Government continuously blocked its final approval. 131  J. E. Slater, Consultations are Required-6-9's Are Not Enough! The Phase Out of PCBs in Canada. Environment Canada, PCB Destruction Program (Ottawa: Environment Canada, 1988) 4. 132  Canada Gazette Part I, May 1986.  133  Canada Gazette Part I, May 1986.  134  Canada Gazette Part II, May 1985. This level would exempt equipment containing less than 50 ppm. 135  Canada Gazette Part II, May 1985.  136  Ken Ogilve, telephone interview, Dec. 1990 (Ottawa: CEAC, Executive Director). 137  The largest PCB fire in Canada previously was at Hydro-Quebec's research laboratory in Varennes. Approximately 670 litres of PCB oil were partially burned, releasing dangerous levels of dioxins and furans. The clean-up, which took more than one year, cost $15.7 million. See Rick Boychuk, "Clean-ups of Past Fires were Costly and Difficult," Montreal Gazette 26 Aug. 1988: A-7. 138  Rick Boychuk, "Quebec Seeking Owner of PCB Storage Site," Montreal Gazette 26 Aug. 1988: A-7. 139 140  Canada Gazette Part II, Sept. 1988: 5.  Canada Gazette Part III, Sept. 1988: 78-79. This penalty is under paragraph (i) of section 113. See Canadian Press,. "Stiff Fines Planned for PCB Offenders-Jail Terms or Fines of up to $1 Million a Day Proposed," Ottawa Citizen 20 Sept. 1988: A5.  86  141  Ross Howard, "Plan to Destroy PCBs Announced," Globe and Mail 22 Sept. 1988: A2. See also Information Release, Canadian Council of Resource and Environment Ministers, "CCREM Ministers Commit to 1993 Phase-Out of PCBs," Ottawa, CCREM, 7 Sept. 1988. 142  Howard, Globe and Mail 22 Sept. 1988 A5.  143  Canada Gazette Part I, March 1989.  144  Canada Gazette Part I, May 1989.  145  Canada Gazette Part III, Sept. 1988: 29.  14  6 Canada Gazette Part I, Sept. 1990:1-8.  147  Canada Gazette Part I. June 1992:1-17.  148  Canada Gazette Part III, Sept. 1988: 3.  149  Dave Campbell, telephone interview, July 1992 (Ottawa: Federal PCB Destruction Program, Environment Canada). 150  M. Menard, telephone interview, July 1992 (Ottawa: Regulatory Affairs, Environment Canada). See Environmental Protection, Regulatory and Economic Affairs Division, Report on Regulatory Initiatives in Conservation and Protection (Ottawa: Environment Canada, 1992). 151  Interview with Campbell, July 1992. These regulations, previously under the ECA. were incorporated into an interim order, and then into CEPA in March 1991. (See Environment Canada, Canadian Environmental Protection Act: Report for the Period Ending March 1991 (Ottawa: Environment Canada,1991)21.) 152  Canada Gazette Part II, Jan. 1990: 20-31.  153  Canada Gazette Part II, Jan. 1990: 21-22.  154  Interview with Ogilve, 22 Nov. 1990.  155 Environment Canada, News Release, Ban On Overseas Exports of PCBs in Place (Ottawa: Environment Canada) 1 Aug. 1990. 156  Canada Gazette Part II, Aug. 1990.  157  Canadian Press, "Incinerators for PCBs Still Lacking Despite Vow," Toronto Star 11 Aug. 1989: A11. 158 159  Both these facilities will be discussed in more detail in Chapter 4.  Environment Canada, Canada's Green Plan (Ottawa: Environment Canada, 1990)44.  87 1  6° Green Plan 59.  161  Michael Cohen, James March, and Johan Olsen, "A Garbage Can Model of Organizational Choice," Administrative Science Quarterly 17 (1972): 1-25. 162  Kingdon20.  163  Kingdon92.  164 165  Kingdon 92-93. Kingdon93.  166  Kingdon 93-94.  167  This window provided an opportunity for policies which had been proposed in the past to be re-examined and potentially implemented. An example of such a policy is the recommendation by the Environmental Contaminants Board of Review in 1980 that"... the Government of Canada consider replacing present guidlines, wherever relevant and practical, which now express the Federal Government's views on storage and all other aspects of the PCB problem, with uniform rules and regulations, jointly agreed upon by the federal and provincial governments concerned, enacted as Federal Regulations." (Environmental Contaminants Board of Review, Report on PCBs 17). Kingdon postulates that there may be spillovers: "The appearance of a window for one subject often increases the probability that a window will open for other similar subjects." (Kingdon 200). PCBs serve as a "lightening rod" for the regulation of other hazardous wastes. 168  Interview with Ogilvie, Dec. 1990. Also Dave Campbell, telephone interview, Nov. 1990 (Ottawa: Environment Canada). According to Campbell, the five-year phase-out plan was tabled and acknowledged by the Environment Department, but not put into place due to impracticality. 169  Anthony Downs, "Up and Down with Ecology--the 'Issue-Attention Cycle'," The Public Interest 28 (1972): 38. 170  Downs 39-41. Downs' model has five stages: (1) pre-problem stage; (2) alarmed discovery and euphoric enthusiasm; (3) realization of the cost of significant progress; (4) gradual decline of intense public interest; and (5) post-problem stage. 171 172  Downs 41.  This telephone survey randomly interviewed 1,550 adult Canadians to form a sample proportionate to the population of each of the ten provinces. To the question: "Compared to a year ago, would you say you are more concerned, less concerned or concerned to the same degree, about PCBs?", 43% of respondents have the same level of concern, 39% are more concerned, and 16% are less concerned. See Environment Canada, The  88  Environmental Monitor, Winter 1990 Omnibus Survey on PCB Destruction for Environment Canada (Toronto: International Environmental Monitor Ltd., 1990). 173  To the questions: "How much progress do you think has been made in solving the PCB problem over the past year? Would you say there has been considerable progress, some progress, not very much progress, or no Drogress at all in solving the PCB problem in Canada?", 42% of respondents Delieve some progress nas been made, 10% believe considerable progress has Deen made, 30%believe little progress has been made, and 11% believe there las been no progress. See Environment Canada, The Environmental Monitor, Winter 1990 Omnibus Survey on PCB Destruction for Environment Canada (Toronto: International Environmental Monitor Ltd., 1990). 174  Charles E. Lindblom, "The Science of Muddling Through," Public Administration Review 14 (1959): 79-88. 175  Environmental Contaminants Board of Review, Report on PCBs 8.  176  Environmental Contaminants Board of Review, Report on PCBs 99.  177  Environmental Contaminants Board of Review, Report on PCBs 9.  178  Environmental Contaminants Board of Review, Report on PCBs 9.  179  Richard Daignault, "Farmers to Get at Least $3M for PCB Fire,"  Montreal Daily News Sept. 1988:4. 180  Francis Thompson, "PCBs Found in Beef from St. Basille Region," Montreal Gazette 8 June 1990: A3. 181  Daignault 4.  182  Irwin Block, "Emotional Troubles in St. Basille Kids Linked to PCB Blaze," Montreal Gazette 8 June 1990: A4. 183  Wills. Montreal Gazette 30 Aug. 1988 A-5.  184  Wills. Montreal Gazette 30 Aug. 1988 A-5.  185  Wills, Montreal Gazette 30 Aug. 1988 A-5.  186  Interview with Ogilve, Nov. 1990.  187  Howard A5.  188  Howard A5.  189  Stephanie Hunt, telephone interview, Nov. 1990 (Ottawa: Federal PCB Destruction Program, Environment Canada). 190  Interview with Ogilve, Nov. 1990.  89 191  Telephone interview with former member of McMillan's staff, May 1990 (Vancouver: Environment Canada). 192  Daniel Mazmanian and Paul Sabatier, Implementation and Public Policy. (Glenview, Illinois: Scott, Foresman, 1983) 13. 193  To a certain degree, some alteration of the objectives during the process of implementation is expected. 194  Mazmanian and Sabatier 22. The other two variables are: (2) the extent to which policy formulators legally and favourably structure the implementation process; and (3) the net effect of factors such as the activities of the relevant interest groups and local communities on the balance of support for statutory objectives. 195  Mazmanian and Sabatier 21-23. Mazmanian and Sabatier suggest that a policy problem is most tractable if: "(1) there is a valid theory connecting behavioral change to problem solution, the requisite technology exists, and measurement of change in the seriousness of the problem is inexpensive; (2) there is minimal variation in the behavior which causes the problem; (3) the target group constitutes an easily identifiable minority of the population within a provincial jurisdiction; ana (4) the amount of behavioral change required is modest." (24). 196 D Wilson, Imbroglio 4. 197 Q Wilson, Imbroglio 4. 198  Mazmanian and Sabatier 13.  199  Interview with Campbell, Nov. 1990.  200  Mazmanian and Sabatier 41.  201  Craig Mclnnes, "All Provinces but PEI Want PCB Rule Waiver," Globe aMMail19 0ct. 1988: A2. 202  Mclnnes A2.  203  "Schedule A, Storage of PCB Wastes Interim Order - Amendment" Canada Gazette Part I, May 1989. 204  Newfoundland: "Mobile PCB Destruction Facility Regulations" under Department of Environment and Lands Act (5 June 1989), and "Storage of PCB Waste Regulations" under Waste Material (Disposal) Act tNF Reg. 230/88) (20 Sept. 1988); New Brunswick: PCB Waste Storage Act-Clean Environment Act (Feb. 1990); Nova Scotia: "PCB Storage Regulations" under the Dangerous Goods and Hazardous Wastes Management Act (NS Reg. 225/88); and Saskatchewan: "PCB Waste Storage Regulations" under Environment Management and Protection Act (section 38) (chapter E-10.2 Reg 6) (11 April 1989). 205  CCREM. PCB Story 18. Order in Council 281/89, 11 April 1989.  90  206  Monica Cray-Solomon and Kyle Korneychuk, telephone interview, July 1990 (Regina: Industrial and Hazardous Waste Unit, Saskatchewan Environment and Public Safety). 207  Carl Strong, telephone interview, July 1990 (St. John's: Newfoundland Department of Environment and Lands). See Newfoundland Reg. 230/88. In June 1989, Newfoundland also enacted Mobile PCB Destruction Regulations under The Department of Environment and Lands Act (NF Reg. 102/89). Prior to the enactment of these regulations, provisions of The Waste Material (Disposal) Act. 1973 required the licensing of storage sites, disposal facilities and hazardous waste transportation services. 208  See Pat Doyle, "New Regulations Cover PCB Storage in Province," Evening Telegram 22 Sept. 1988. 209  PCB Storage Standards-Clean Environment Act. Appendix A, 15 Nov.  1988. 210  Craig Benjamin, "Courting Disaster," Cities Dec. 1988: 30.  211  Bill Larrett, telephone interview, July 1990 (Halifax: Nova Scotia Department of Environment). See also PCB Waste Storage Regulations, 15 Nov. 1988. 212  Regulations made pursuant to the Dangerous Goods and Hazardous-Wastes Management Act (S. 12, R.S.N.S., July 1989, c. 118). 213  Serge St.-Laurent, telephone interview, Aug. 1990 (Quebec: Direction des Substances Dangereuses, Gouvernment du Quebec, Ministere de I'Environment). 214  CCREM, PCB Storv 18.  215  "Hazardous Waste Regulation," (Order in Council 1000-85) (29 May  1985). 216  "Hazardous Waste Regulation (Amendment)," Gazette Qfficielle Du Quebec 120.38,14 Sept. 1988. 217  "Hazardous Waste Regulation (Amendment)," Gazette Qfficielle Du Quebec 120.38.14 Sept. 1988 218  Interview with St.-Laurent, Aug. 1990.  219  "Alberta Regulation 505/87," Hazardous Chemicals Act.  220  "Alberta Regulation 505/87," Hazardous Chemicals Act.  221  "Ministerial Order #04/89." Hazardous Chemicals Act (Alberta: Department of the Environment) 4 March 1989.  91 222  Tom Trimble, telephone interview, July 1991 (Edmonton: Industrial Wastes Branch, Alberta Environment). With the disposal plant at Swan Hills, there has been less demand for storage sites in Alberta. Swan Hills has been effective in relieving the pressure on the existing storage sites. As the inventory records indicate, sites which appear on the January inventory often do not appear on the July inventory. 223  "Special Waste Regulation." Waste Management Act (BC. Reg. 63/88), 1 April 1988. 224  "Special Waste Regulation," Waste Management Act (BC, Reg. 63/88), 1 April 1988. 225  E. Mindoza, telephone interview, Jan. 1991 (Vancouver: Pacific Region, Environment Canada). 226  Calvin Hickey, telephone interview, July 1991 (Victoria: BC Ministry of the Environment). An inventory of PCB storage sites compiled by the Ministry of Environment as of June 1989 indicated that there were 246 high-priority sites out of a total of 447 which included schools, hospitals, food establishments and other storage sites with greater than 5 kg or litres of special wastes containing PCBs (BC Ministry of Environment, British Columbia Inventory of Waste Sites Containing PCBs 26 June 1989). A federal inventory indicates that BC Hydro is the largest storer of PCBs in the province witn 73,495 L at its Kennedy substation in Mackenzie, 51,000 L at its Victoria operation and 12,500 L at Hope (See Larry Pynn, "Industries to Get Copies of Tough PCB Regulations," Vancouver Sun 21 Sept. 1988: A-16.). The provinces inspection program is delegated to eight regional offices which administer the regulations autonomously. As to enforcement issues, Environment Canada officials in the Pacific Region have found that all new sites that have been inspected are in full compliance (Interview with Mindoza.). 227  Regulations under the Dangerous Goods Handling and Transportation Act (S.M. c.7 - Chap. D12), 20 Aug. 1984. 228  Procedural Guidelines for PCB Waste Storage Sites 17 June 1991. Manitoba Reg. 474/88. 229  Dale McEachern, telephone Interview, Aug. 1990 (Winnipeg: Manitoba Dept. of Environment. 230 when the PCB ballasts are removed, they are placed into individual containers which are double-bagged and inserted into 45 gallon double-barrelled drums which are one-third full of sawdust and placed on palates. (Interview with McEachern.) 231  General-Waste Management under "Waste Management-PCBs Regulation (O. Reg. 11/82)." Environmental Protection Act (Reg. 309). 232  1984.  "Amendments: O. Reg. 575/84," Environment Protection Act Sept.  92 233  1984.  "Amendments: O. Reg. 575/84," Environment Protection Act. Sept.  234  Bill Edmonds, telephone interview, July 1990 (Toronto: Ontario Ministry of the Environment). 235  Mazmanian and Sabatier 29.  236 Environment Canada, Enforcement and Compliance Policy, Canadian Environmental Protection Act (Ottawa: Environment Canada, May 1988) 15. 237  Enforcement and Compliance Policy, Canadian Environmental Protection Act 15. 238  Environment Canada, Canadian Environmental Protection Act: Report for the ie Period Ending March 1991 (Ottaw (Ottawa: Environment Canada, 1991) 9 Also, Interview with Campbell, July 1992. 239  Andre Chartrand, telephone interview, Aug. 1990 (Ottawa: Coordinator of Planning, Division of Legislation, Compliance and Enforcement, Environment Canada). 240  Interview with Chartrand, Aug. 1990.  241  Interview with Mindoza. Regional offices of Environment Canada have developed their own inspection plans. 242  Canadian Environmental Protection Act (1991): 79.  243  Canadian Environmental Protection Act (1991): 79.  244  CEAC, Listing Toxics Under CEPA 14.  245  Environment Canada, CEPA: Report for the Period Ending March 1990  23. 246  Environment Canada, Canadian Environmental Protection Act: Report for the Period Ending March 1991 39-40. 247  Environment Canada, CEPA: Report for the Period Ending March 1991  248  Environment Canada, CEPA: Report for the Period Ending March 1990  249  Interview with Ogilve, Nov. 1990.  250  Interview with Ogilve, Nov. 1990.  251  Michael Rose, "Dangerous Cargo." Maclean's 28 Aug. 1989:12.  252  Rose 12.  40. 24.  93  253  "Look Before You Leap," editorial, Montreal Gazette 5 Oct. 1988: B-2.  254  Rose 12.  255 Environment Canada, Canadian Environmental Advisory Council, A Report to the Federal Minister of the Environment, PCBs: A Burning Issue: On the Siting of a Mobile PCB Incinerator (Ottawa: CEAC, 1989) 7. 256 Environmental Contaminants Board of Review, Report on PCBs 13. 257  Stephanie Hunt, "The Federal PCB Destruction Program-An Approach to the Siting of Mobile PCB Incinerators in Canada," Twelfth Canadian Waste Management Conference Proceedings. St. John's, Newfoundland, 3-5 Oct. 1990 (Ottawa: Environment Canada, 1990) 55. 258  Hunt 55.  259  Judy Wilson, "The Role of the Politician in the Site Selection Process," Twelfth Canadian Waste Management Conference Proceedings. St. John's, Newfoundland, 3-5 Oct. 1990 (Ottawa: Environment Canada, 1990) 311. 260  Judy Wilson 320.  261  Judy Wilson 314-315.  262  CEAC, PCBs: A Burning Issue 20.  263  Douglas White and Greg McGuire, "Goose Bay Mobile PCB Incineration Project," Twelfth Canadian Waste Management Conference Proceedings. St. John's, Newfoundland, 3-5 Oct. 1990 (Ottawa: Environment Canada, 1990) 33-34. 264  CEAC, PCBs: A Burning Issue 19-20.  265  CEAC, PCBs: A Burning Issue 5.  266  White and McGuire 33-34.  267  White and McGuire 33-34.  268  White and McGuire 36-37.  269  Hunt 52.  270  Hunt 52.  271  James Q. Wilson, American Government: Institutions and Policies. 3rd ed. (1986)443. 272  James Q. Wilson 428.  94 contends that something is required to form the need for a policy, either an individual to point out the problem and gjve it shape, or an event itself which raises awareness and concern. Employing Wilson's perspective we see the possibilities of spillover effects in turning public attention to other hazardous wastes. 274  James Q. Wilson 444.  275  Peter Gorrie, Toronto Star 7 Jan. 1991: A8. The Chemical Waste Management Ltd. (CWM) was granted a license by the Ontario Environment Ministry in 1978. 276  Gorrie A8.  277  Doug Draper, "Bubble, Bubble, PCB Trouble-The Making of a Toxic Cauldron." This Magazine Dec. 1988: 26. 278  Draper 26.  279  Peter Gorrie, "Incinerator to Rid Town of PCBs," Toronto Star 7 Jan. 1991: A8. 280  Peter Gorrie, "Clean-Up of PCB Site Falls Behind Schedule," Toronto Star 23 Sept. 1991: A8. The incinerator was leased from Arkansas-based Ensco Inc. at a cost of $15.9 million. Monitoring of the portable incinerator by the Ontario Environment Ministry found acceptable emission levels. (Canadian Press, "Incinerator Wins Passing Marks," Globe and Mail 13 April 1991 :A2.) 281  Gorrie. Toronto Star 23 Sept. 1991 A8.  282  Hunt 54.  283  Hunt 54. Politicians and the electrical utility representatives later withdrew from the group to allow the group to proceed independently, free from any potential conflict of interest situations. 284  Hunt 54.  285  Connor 3-5.  286  Connor 3-5.  287  Hunt 50. See also Environment Canada, News Release, "Joint Federal-Provincial Program Will Destroy PCB Wastes in Atlantic Canada," (Ottawa: Environment Canada) 22 Aug. 1990. 288  Hunt 50-51.  95  Bibliography  Benjamin, Craig. "Courting Disaster." Cities Dec. 1988: 30-34. Bennett, B.G. "Exposure of Man to Environmental PCBs--An Exposure Commitment Assessment." Science of the Total Environment 39 (1983): 101-111. Block, Irwin. "Emotional Troubles in St. Basille Kids Linked to PCB Blaze." Montreal Gazette 8 June 1990: A4. Boychuk, Rick. "Quebec Seeking Owner of PCB Storage Site." Montreal Gazette 26 Aug. 1988: A-7. Brown, D.P., and M. Jones. "Mortality and Industrial Hygiene Study of Workers Exposed to Polychlorinated Biphenyls." 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