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UBC Theses and Dissertations

Ex ante assessment of secondary impacts of environmental regulation: case study--organochlorines in the Canadian pulp and paper industry Inch, Hilary


This thesis examines how the secondary effects of environmental regulations are assessed before the regulations are proclaimed. Negative secondary effects of a policy (such as regulation) may outweigh direct benefits; it is important that secondary effects are clearly assessed. The case study is the control of organochlorines in the Canadian pulp and paper industry via federal regulation of dioxins and furans and British Columbia's regulation of Adsorbable Organic Halogen (AOX). The thesis is founded upon the premise that sustainability must be an integral consideration. A systems approach is used to evaluate assessments and to generate recommendations. The evaluation is divided into two parts: the process of assessing the regulation and the contents of the assessments. Background information is provided on organochlorines, pulp and paper making, the pulp and paper industry and the relevant regulatory processes. A chronology of the regulation is established. Assessments are reviewed from five classes of stakeholders: industry, labour, environmentalists, the federal government and the British Columbia government. The study found that secondary impacts of the regulation were less important than the primary action, which was managing the risk posed by organochlorines in effluent. For the secondary assessments, stakeholders felt problems with the process were greater than shortcomings in content. In particular, governments' lack of response to submissions caused a lack of confidence in the system, which was well-founded in British Columbia's highly political process. The federal Regulatory Impact Analysis Statements gave a valuable but limited summary of impact assessments and the rationale behind the regulations. To improve the process of creating environmental regulation I recommend that the federal government assemble a reference document for assessments, that all levels of government institute class assessments for general cases, and that all stakeholders use a consistent, multiobjective framework. The proposed framework is presented.

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