.,
DISTRIBUTION LIST #1
IOL ' S RESPONSETO ENVIRONMENT
CANADA'S
"A FRAMEWORK
FOR DISCUSSION ON THE ENVIRONMENT
THE GREEN PLAN: A NATIONALCHALLE
NGE"

Management c , ,,r.mi ttf'- e
A.R. Haynes
R.B. Peterson
R.A. Brenneman
Presidents

of Operating

Di v is i on s

D.D. Baldwin
B.J. Fischer
Y.R.K. Inne s
Environment

Network & EQC

Barbeau
G.
J.P. Ba tycky
D.R. Boucher
Y. R. Bur ton
J. D. Cook
R . P. Delane y
J.M. Fin l ayson
J.A . Hughes
A.H . Katz
R .E . Landry
R.F. Lipsett
B. L. Lockhart
R. J . Michael ides
R.K . MacEachern
R.H.G . Millar
Murray
N.
R.J. Ottenbreit
J .Y. Pollock
R.A. Shaver
D.H. Shaw
D.E. Toye
c.c. Yild

Attachments:
1)
R.B. Pet e rso n' s letter
dated June 29, 1990,
Minister
of t he Environment.
2)
IOL's "Green Plan" response document.

to the Hon. Robert

Note:
A wider distribution
list and a foreword,
response document, will be developed next week.

which will

Jun e 29, 1990

de Cot '..e t,

form part

of TOL's

 Imperial Oil Limited

111 St. Clair Avenue West
Toronto, Ontario
Canada M5W 1K3

R.B. Peterson
President and
Chief Operating Officer

June 29, 1990

The Hon. Robert de Cotret,
P.C.,
Minister
of the Environment
Room 333, Vest Block
House of Commons
Ottawa, Ontario
KlA OA6

M.P.

Dear Minister:
I am pleased
to enclose two documents representing
Imperial Oil's formal
response to th is st age of consultations
on the "Green Pl an"; namely, a Response
to "A Framework for Discussion
on the Environment" and a Discussion
Pape r on
Potential
Global Warming.
We believe
these will contribute
to the current
national
discussion
on dev e lopment of a new environmental
policy framework for
Canada, and we urge you to examine our ideas.
Ve have also been involved
directly
as a company,
industry
associations,
in the recent consultativ e sessions
Our judgment is that the process was effective
in bridging
of governments,
business,
environmental
interest
groups,
public
in a cooperative
effort
to find workable solutions
problems.
The challenge
will be to assi milate
the many
that have been offered,
and we look forward to the results
the wrap-up sessions
planned at the end of ._the summer.

as well as through
held across Cana da.
the many interests
academia and the
to environmental
helpful
suggestions
of this process in

A key theme in our submissions
is the need to balance environmental
and
economic priorities.
We believe
that a strong economy provides
the means to
achieve
environmental
quality.
In addition,
the globalization
of trade and
commerce requires
that we increase
the international
competitiveness
of our
economy at the same time as we tackle
environmental
issues
that increasingly
have international
dimensions.
A constructive
outcome for global environmental
quality
will require
international
cooperation
rather
than unilateral
actions
by individual
countries.
Our submissions
also outline
work we have underway to further
contribute
to the development
of Canada's
new environmental
policy
framework.
This
includes
a seven-point
work program relating
to potential
global warming and
discussion
papers
on air
quality
and economic
instruments
to
achieve
environmental
goals.
Upon completion
of this
work later
this
discuss
the results
with you and your officials.

year,

we will

be

pleased

to

Yours very truly,

Enclosure a

Imperial Oil

 (§)
Imperial Oil

Responseto
EnvironmentCanada's

"A Framework for Discussion
on the Environment
The Green Plan:
A National Challenge"

JUNE 1990

 TABLE OF CONTENTS

I.

Introduction

1

II.

Guiding

4

III.

Environmental
A.

Principles

Air

Challenges

10

Quality
1.
2.

10

Ground-level
Urban Smog
Toxicity
Fuels

Ozone

and
11

of Transportation
13

· B.

Water

14

C.

Waste

15

D.

Potential

IV.

Instruments

v.

Recommendations

This docunent has been
printed on recycled paper

Climate

Change

of Change
and Commitments

17
18

22

 INTRODUCTION

Imperial
to

Oil

respond

to

Discussion

on

Challenge".
major

Limited
the

the

federal

Environment

As a leading

producer

of
we have

participating

fully

concerning

most

parts

Our
development

Potential
as

a

are

Global

Warming

contribution

describes
results

have

integrated
define

will

since

further

To complement
discussion
environmental

paper

s recent

1990),

commissioned

of

We believe

and

is

also

work

can

to
in

The

paper

Imperial,

the

year.

develop

make on these

economic

instruments

discussion

on

tabled

Canada

developing

- 1 -

Paper

this

also

these

These

being

in

later

issues

other

success.

process.

quality

we are

policy

Discussion

which

other

Imperial

use

policy

we can make the

its

widely

on the

goals.

to

be communicated

efforts,

in

responding

principles

now underway

air

public

environmental

consultative

contributions
these

the

critical

Imperial'

on

and

interest

we are

a

discussion.

work plan

perspective

and as

products

of
end,

guiding

are

this

a seven-point
of which

we

the

Canada

we believe

on

(March

to

in

for

A National

and a keen

To this
where

opportunity

Framework

petroleum
stake

focussed

for

Green

company

to the

and

context

The

development

Plan

we believe

the

Plan:

the

Green

process

considerations

--

fuels,

c ontribution

comments

"A

issues.

of the

meaningful

provided

in

the

government's

an important

environmental

those

welcomes

industrial

fossil

petrochemicals,

to

("Imperial")

an

and

to

issues.

a companion

papers

to

achieve
--

which

 we

plan

to

complete

by

contribution

toward

finding

environmental

challenges.

In
Canada,
been

designing

a

new

we believe

it

is

and where

we are

Looking
progress

back,

has

is

to

and these

need

a

of

science

the

the

economy,

World

Brundtland
Europe.
commitment
realistic
many
terms

this

has

by

in

been

many

environmental

intervention

the

into

1987

has

improved

we

Canadian
is

seen

of market

the

right

and

understanding

of

events

We

society

report

in

to

recognition
dimensions.

benefits

have

environment

consultation

forces.

of

techniques

Development

a wider

have

2 -

This

by the

and

international

-

in Canada.

of the

have

workings

the

solutions.

by recent

· There

quality.

come as a result

cooperation,

of

we have

some things

reinforced

and

for

improving

measurement

guided

increased

issues

the

doing

Environment

goals.

economy,

in

been

sectors

environmental

of

has

Canada's

- considerable

in

interrelationship

on

Commission)

that

and land

Progress

have

to

on where

fronts

we are

and

valuable

framework

reflect

water

enabled

a

of environmental

many

air,

. the

and

to

have

Commission

There

on

Advances

recognized

policy

acknowledge

to be continued.

problems

increasingly

to

because

technology

environmental

and

need

make

solutions

in terms

of the

factors.

and

important

recognize

will

environmental

made

quality

important

number

we

end
effective

heading

been

environmental

year

of

of
(the

Eastern
and
achieve
that
In
reduced

 As

look

we

Environmental
more costly.
more
to

issues

measure.

toughest

In

the

face
to

of

past

of

ground
guiding

and

regard,

the

guiding

principles

its

are

a

federal

are

perhaps

becoming
expectations

our

Looking

the

on a set
the

and

as

important

we

Societal

demanding

loom

ahead,

success
farther

for

complex

and

potentially

and

standards

out,

world

population

growth

may

issue.

we believe

reflect
emerging

may wish
helped

ideas.

-

becoming

may be harder

these

have

are

these

that

government
which

crossroads.

it

new environmental

principles
sense

new

achieving

challenges,

Canada's

more

a

in

environmental

such

at

3 -

policy
lessons

to

critically
framework

learned

realities.

to consider

Imperial

is

In
the

shape

from
this

following
and · focus

 GUIDING PRINCIPLES

1.

"Strike

the

balance

between

environmental

and

economic

priorities."

A strong

economy

quality.

provides

The sooner

we Canadians

think

more

we

likely

between
Reasonable

io n.

This

also

need

economy

of

upon

our

and

commerce

effectively.

We are

increasing

nation

the

trend
actions
understand
and

the

at

for
to

unique

real

the

workable

the

balance

priorities.
It

will

full

cost

way

mean

costs

of

of environmental

require

a str~ng

commitment

by many

to

together

as

to

interest

groups,

work

and

the

public

and economic

better

well

political
and

strengths
contribution

4 -

work

economists,
mutually

goals.

for

the

full

impact

worldwide
Canada

in history
and

as

achieve

competitive

a point

-

to

understand

imperative

be global
our

a

of the

resources,

a balance.

increasingly

and

find

such

special

to

a part

and its

equation

environmental

Canadians

to

will

environmental

environmental

and the

community

agreed-upon

need

the

industry,

scientific

to

and
find

departments
with

policy

can

becomes

country

able

degradation

government

the

our

be

into

environmental

closely

about

people

means to achieve

reality

economic

incorporating

protect

this

will

our

the

to

where

and weaknesses
we make to

compete

there

economic

integrated.

trade

is

forces
This

an
and

means

we

as a - trading
the

worldwide

 economy

and factor

internation

Canada

al

is

a large

industrial

international

that

trade.

This

ineffective
their

2.

it

operations

viewpoints

and

individuals
process
role
to

of
set

business
these
that

ensure

has
goals

the

the

best

avoid

with
would

trading

costly

simply

and

redirecting

stakeholders."

effectively

the

draws

out

of

interested

variety
country

is

vital
It

policy.

facilitate

the

consultative

goals,

and

ties

and

negotiations.
role

in

Our

problems

be

public

as

.on

taking

other

effective

desired

manner.

heavily

to

industries

across

essential

well

step

a wide

international
an

as

achieve

efficient

of

priori

in

relies

environmental

of all

expertise

to

producers

countries.

groups

national

effectively

in

thinking

developing

on

resource-driven,

therefore,

leadership

that

government

that

of

process

and
of

of

resulted

best

consultative

economy

on global

to other

the

a

out

kind

if

"Searc h out

A

action

. significantly

nations.

negotiations

of commodity

from

We need,

Canadian

are

a country

flows

energy-intensive

into

protocols.

extent

prosperity

unilateral

considerations

environmental

to

whose

these

both

-

of

results

in

most

5 -

is

the

participate

helping

development

available

the

process,

to

the

responsibility,

to

We believe
in

the

the

policy

shape
·options

effective

therefore,

information,

to

that

and
is

knowledge,

to

i

 experience,
shared

3.

and

with

"Enroll

s c1.en
· t 1.
· f 1.c
·
and

government

th ose

business

and other

c 1 osest

to

perspectives

are

participants.

the

problem

to

-help

find

can

help

solutions."

Fully

informed,

governments

to

effective
each

shape

action

of

being

knowledgeable

us as
a

kind

all

we

contribute

to

And

that

responsible

Canadian

corporate

operations

can

the

as
our

the

evokes

economy

we are

includes

that

and

from

dedicated

to

reflected

in

commitment

to

environmental

many

as Canadians.

Imperial

socially

policy

Canada,

for

challenges

boundaries.

of

in

solutions

we face

public

At Imperial

corporation
do.

these

of

sectors

individuals.

everything

Many of

from

premier

challenges

the

participants

span
Oil

the

has

citizen

globe,

a role
of the

citizen,

to

have

truly

play,

not

but

also

world

because

potentially

and

know no
only

a

as a good

we recognize
adverse

as

that

effects

our

on

the

we and

our

environment.

Without

doubt,

colleagues
environmental
business

the

in

most

valuable

industry

can

technologies

to

the

science

minimize

the

-

6 -

is

a top

We continue

operations.
of

make

remains

protection

development

contribution

and
effect

to

ensure

priority

in

that
all

our

participate

in

the

implementation·

of

new

to

of

our

operations

and

 products

on the

environment.

operating

practices

are

continuously

being

water
of

and

our

believe

a wide
work

public

interest

we use

to

in the

is

our

of

balanced
of

commitment

and

and

air,

the

the

to the

effective

public.

and expertise

to

public

to

challenges

policy

by continuing

business,

the

place,

and distribution

knowledge

and

in

safeguard

governments,

groups

are

production

environmental

industry,

standards,

systems

we can contribute

range

with

managing
improved,

This

development

meet
to

land

products.

We also
the

the

and

Comprehensive

scientists,

communities

in

which

we

operate.

4.

sound

"Apply

to

define

an

essent:~al

science

problems

and

guide

to

ensure

solutions."

Scientific
that

the

and

that

knowledge
right

actions

are

taken

these

actions

are

effectively

developing
order

Industry

to

data
foster

has

understanding.
a

is

seven-point

and

to

risk

assessments

informed,

intelligent

a major

role

to

play

foundation
protect

the

environment

applied.

This

means

have

integrity,

in

that

debate.

in

improving

For

example,

at

Imperial,

work

program

to

find

-

7 -

more

we have
answers

scientific
undertaken
based

on

 sound

science

related

to

the

comprehensive

issue

Because

Imperial

research

and

cost

of potential

Oil

can

only

technical

personnel

comprehensive

scientific

inquiry

environmental

knowledge

for

us:

namely,

and nurture
this

5.

and

an expanding

global

warming.

do

so

much

to

contribute

needed

we see

provide

analyses

with

to

another

financial

niche

benefit

its

own

to

the

enhance

the

important

support

to

of environmental

role

encourage

research

in

country.

"Utilize

market

private

endorses

instruments,
achieve

this

approach

imagination
to

creative

principle

environmental
will
and

and

control"

states

ev oke the

possible,

economic

talents

of the

It
full

drives

of

in
than

the

market
is

power
the

most

economic

using

to harness

the

that,

effective

of

goals.

unleash

solutions

efficient

an

to

the

wherever

help

lead

forces

sector."

Imperial

As

to

base,

and

our

forces
belief

of

This

will

traditional

that

innovation,

market.

cases,

to

will

be

more

"command

and

approach.

example,
have

trading
development

other

jurisdictions,

experience

arrangements,
of

similar

in

the

such
use

of

which

could

be

public

policy

in

-

8 -

as

the

emissions
invaluable
Canada.

United
rights
to

Now is

the
the

 tim e

to

challe

At

appl y

ng i ng environmental

th

e i nd ividua1

opportunities

box"

example.
v ital

6.

to

the

"Harmon i ze

Let's

not

and

education

effective.
of purpose

enroll

one

awareness

the
success

sp 1 en d 1· d

programs

is

across

country

to

a

to

the

action."

other.

and to
operational

and interfere

and

are many

many publics.

legislation

Jurisdictional

there

·
was t e is

and

intergovernmental

and

ever-more

The tremendous

household

each

duplication

meet

.
.
imagination

consumers.
of

to

our view that

and effective

framework

lack

is

of informing

"out-green"

current

and prevent

1·ng

envir onmen tal

efficient

and

the

for

task

f os t er

policy

tap

recycl

Funding

enhance

it

of Canadian

"blue

approaches
needs.

level,

to

participation
of

innovative

There

is

partnerships
ensure

that

to
the

mechanisms
disputes
with

eliminate

environmental
are

spawn
getting

need

efficient
uncertainty

the

job

done.

 ENVIRONMENTALCHALLENGES

Following
concern

to

are

Imperial

contribution
comments
are

in
are

four

environmental

d t
.
an
o which we can make the
terms
of the policy
development

focused

on issues

in

developing

important

challenges

of
most

meaningful

process.

and considerations
public

particular

that

policy

Our

we believe

to

meet

these

challenges.

A.

AIR QUALITY

Canadians
has

been

Canada

should

achieved

in

particulates

minimize

of

lead

and . the

fuels;

reductions

transportation
(NOx) and volatile
atmosphere

ozone

nitrogen

also

. being

by

oxides

that

vary

could
to
widely

lead

halons

and,

control

contemplated

government

results

to

acid

develop
in each

climate

goals

and

of these

to

business

reduction
in

(VOCs) to

sulphur

timetables

of
upper
dioxide

New initiatives
reduce

of

emissions

minimize
of

change.

areas.

our

elimination
to

rain.

initiatives

compounds

reductions

worldwide
to

Environment

of
to

formation;

and

depletion;

directly

organic

ozone

(CFCs)

by

and a number

elimination

chlorofluorocarbons

and

remain

most

lower

improvement

agencies.

relate

oxides

atmosphere

measured

that

from

of nitrogen

considerable

as

environmental

Those

the

include:

that

quality

many challenges

underway.

emissions

air

and provincial

However,
are

be encouraged

are

greenhouse

gas

The approaches

used

and

to

achieve

 In

our

view,

integrated,

Canada

coo rd inated

quality

and

could

and

climate
and

have

dimensions

has

international
important

setting

priorities,

For

its

discussion
by

the

end

of

perspective
which
policy

where

we also

approach

because

more
to

with

protocols,

fully

these

air

there

are

strong

Many of

these

issues

an understanding

in dealing

Imperial

on air
1990.

that

a

the

of the

parts

making

whole

in terms

commitments

.of
and

plans.

part,

paper

ti zed

.
issues

negotiating

action

f rom

interdependencies.

implications

establishing

priori

change

interrelationships

benefi't

is

believe

is

quality
Our

issues

objective

important
will

developing

to

in
is

to

a

Canada,

for

develop

how we manage

make a valuable

comprehensive
completion

an

our

integrated

business

contribution

and

to public

development.

Turning

to

transportation

fuels,

Ozone

Smog

we

have

a

number

of

produced

by

observations:

1.

Ground-level

ozone

is

a key

a reaction

that

NOx in
cause
steps

the

contributor
occurs

presence

respiratory
to

and Urban

reduce

to
at

of

smog and

warm temperatures
sunlight.

ailments
ozone

urban

have

and
already

- 11 -

between

Ozone

has

agricultural
been

is

taken.

been

voes
shown

damage,

and
to
and

 Engine

exhaust

oxides

have

been

standards

been

reduced

t'

and

recycle

hydrocarbon

filled

throughout

for

h
ig tened,
II

s t age

hydrocarbons

gasoline
one"

vapours
the

and

vapour

controls

pressures

(which

when gasoline

nitrogen

capture

storage

distribution

have
and

tanks

system)

are

are
being

introduced.

Further
in

steps

draft

means
to

to

legislation.
being

to

and

and

the

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sound

reduce

-

ground-level

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particulates
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in

and

particulate

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- 12 -

Also

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Targets
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Many

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- 13 -

1,

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esign
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 Imperial
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POTENTIAL CLIMATE CHANGE

The
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1990

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- 17 -

base.

work

program

I
I
I

I
I
I
I
I
I

 INSTRUMENTS· OF CHANGE

Much of
Canada's

the

Imperial

responsibility
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The question
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·

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priorities

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determined.

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- 18 -

to

while
This
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- 19 -

private

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-

19 -

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Such

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- 20 -

against·

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I
I
I

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- 21 -

 COMMENDATIONSAND COMMITMENTS

I nd

v lo ping

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the

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gov rnm nt s hould
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22 -

 Imperial's

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23 -

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 warming.

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considering

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carbon

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including

consequences

dioxide

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human

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by
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financial

or grant-giving
research

pertaining

challenges.

- 24 -

to

to

or fuel

resources
bodies
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to

of

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key

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of the

Canada

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as carbon

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emphasis

an assessment

macroeconomic
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research-related

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Reallocate

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end-uses;

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the

cycle"

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federal
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 Imperial's

commitment:
To collaborate

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5.

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particulates

volatile

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carbon

compounds,

and benzene.

- 25 -

end

paper
of

the

on

year,

interdependencies

trade-offs,

Imperial

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organic

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sort

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to
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sulphur

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