We submitted this written brief to the Standing Senate Committee on Energy, the Environment and Natural Resources, in relation to its study of Division 42 of Bill C-15. Division 42 of Part 5 amends the Canadian Environmental Protection Act, 1999 (CEPA) to remove the mandatory five-year limit on equivalency agreements with the provinces. We recommend against extending the duration of equivalency agreements beyond five years, because longer agreements would make the equivalency process less responsive to data (including, crucially, emissions measurement data).
Five-year limits are crucial to the efficacy of equivalency agreements
Pembina Institute comments and recommendations submitted to the Standing Senate Committee on Energy, the Environment and Natural Resources
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