SOR/2016-137: Ozone-depleting Substances and Halocarbon Alternatives Regulations
REGISTRATION OF FEDERAL REGULATION - VIA OIC DATABASE, PRIOR TO PART II OF THE GAZETTE
REGULATORY IMPACT ANALYSIS STATEMENT (This statement is not part of the regulations.) Issues Severe depletion of the ozone layer over the Antarctic has been occurring since 1979 and a general downturn in global ozone levels has been observed since the early 1980s. In 1987, Canada signed the Montreal Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol). This agreement has be... (Click for more)
REGULATORY IMPACT ANALYSIS STATEMENT (This statement is not part of the regulations.) Issues Severe depletion of the ozone layer over the Antarctic has been occurring since 1979 and a general downturn in global ozone levels has been observed since the early 1980s. In 1987, Canada signed the Montreal Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol). This agreement has been signed and ratified by 197 countries. To date, the Montreal Protocol has enabled reductions of over 97% of all global consumption of controlled ozone-depleting substances (ODSs), (see footnote 1) including chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons and methyl bromide. At the 19th meeting of the Parties to the Montreal Protocol in September 2007, new commitments were made to accelerate the phase-out of the consumption of HCFCs and to introduce controls on the production of HCFCs. These new obligations are not yet reflected in the Ozone-Depleting Substances Regulations, 1998 (ODSR). To ensure that Canada's international obligations under the Montreal Protocol continue to be met, these new commitments, which took effect on January 1, 2015, must be reflected in Canada's ODS regulations. In addition, to inform the potential establishment of future controls that would be aligned with possible new obligations under the Montreal Protocol relating to hydrofluorocarbons (HFCs), which are alternatives to HCFCs, data on HFC activity in Canada is required. Background CFCs, HCFCs and HFCs are all classified as halocarbons and are included in the fluorocarbons niche market. CFCs and HCFCs are also ODSs, while HFCs are powerful greenhouse gases (GHGs) and are alternatives to CFCs and HCFCs for use in applications such as refrigeration and air conditioning. Based on the North American Industry Classification System (NAICS), firms involved in the manufacture of these substances in Canada are in the industrial gases manufacturing segment (NAICS 325120). The refrigeration and air conditioner manufacturing sector is the largest consumer of fluorocarbons; other industrial sectors that consume fluorocarbons include the industry sectors producing polymer precursors, foam blowing agents, aerosol propellants and solvent cleaning agents. Ozone depletion is the term commonly used to describe the thinning of the ozone layer in the stratosphere. The ozone layer acts as a natural filter, absorbing most of the sun's ultraviolet (UV) rays. Stratospheric ozone depletion leads to an increase in UV rays that reach the Earth's surface, which in turn can disrupt biological processes and damage a number of materials, such as synthetic polymer products, wood, paper, wool and cotton. Human activity is the major factor causing ozone depletion, mostly from releasing ODSs to the atmosphere. Exposure to UV radiation has been linked to many human health problems, including skin cancer and eye cataracts. Scientific research also indicates that increased exposure to UVB rays affects the human immune system and causes premature aging of the skin. Under the Montreal Protocol, Parties must phase out the production and consumption of a wide range of substances known to contribute to ozone depletion, including CFCs, HCFCs, halons and methyl bromide. Since 1999, Canada's obligations under the Montreal Protocol have been met through the implementation of the ODSR. Over the years, the Montreal Protocol has been amended or adjusted several times by the international community. Consequently, the ODSR have been amended five times to ensure that Canada continues to meet its obligations under the Montreal Protocol. Controls in Canada have resulted in an overall phase-out of over 99% of ODSs from baseline levels. Canada has successfully phased out the production and consumption of 94% of HCFCs from baseline levels and 100% of production and consumption of all other controlled ODSs from baseline levels. Hydrochlorofluorocarbons (HCFCs) At the 19th meeting of the Parties to the Montreal Protocol in September 2007, the Parties agreed to an accelerated phase-out of HCFCs that included, for the first time, controls on the production of HCFCs. HCFCs are the only fluorocarbons produced in Canada. Canada produces approximately 5 300 tonnes of HCFCs annually, predominantly for export to the United States (U.S.). A phase-out of HCFC production was not previously part of the obligations under the Montreal Protocol; therefore, domestic controls on production were not previously required. To ensure that Canada would meet its production phase-out obligations between 2010 and 2015, the Department of the Environment (the Department) entered into a performance agreement with Canada's only producer to control its production of HCFCs in Canada. To date, this performance agreement has been an effective tool. However, this agreement is temporary, and it does not prevent other companies from producing HCFCs in the future. Hydrofluorocarbons (HFCs) HFCs are not currently controlled under the Montreal Protocol. They are substitutes for HCFCs that do not deplete the ozone layer, but they are GHGs and some HFCs have global warming potentials thousands of times higher than that of carbon dioxide (CO2). HFCs are included in the basket of GHGs controlled under the United Nations Framework Convention on Climate Change (UNFCCC), although they are not subject to specific measures under this convention. Taking into consideration GHG global warming potentials, HFC emissions currently represent only 1 to 2% of total GHG emissions covered under the UNFCCC, but these emissions are rising by about 8 to 9% per year. (see footnote 2) The global consumption and emissions of HFCs are projected to increase substantially in the coming decades, according to the UNFCCC, making HFCs an emerging concern because of their immediate and future impact on the climate. Canada has partnered with the U.S. and Mexico in submitting a North American proposal to amend the Montreal Protocol and gradually phase down the use of HFCs. Canada has also made commitments in relation to the Climate and Clean Air Coalition to Reduce Short-Lived Climate Pollutants. (see footnote 3) Also, at the 2014 North American Leaders' Summit, Canada agreed to further intensify its efforts to promote an amendment to the Montreal Protocol to phase down HFCs; and during the 2014 Group of Seven (G7) Summit, Canada agreed to promote low global warming potential alternatives to HFCs. Import and manufacture in non-refillable containers The use of refillable containers for halocarbon refrigerants, which include ODSs and HFCs, is more desirable than the use of non-refillable containers. Refillable containers are more suitable for storing and transporting controlled substances as they are less likely to leak. Reusing these containers avoids having to dispose of them in landfill sites. All Canadian provincial and territorial governments have introduced control measures on the use of halocarbon refrigerants in non-refillable containers, and some provinces have introduced controls on their sale or offer for sale. However, halocarbon refrigerants in non-refillable containers can still be legally manufactured and imported, and there is evidence that they are still being used, notwithstanding the provincial and territorial government controls. Methyl bromide The import and manufacture of methyl bromide in Canada have been phased out since 2005. However, there are exemptions for quarantine application, pre-shipment application, critical use, emergency use, feedstock, and laboratory and analytical use. The ODSR currently prohibit the transfer of methyl bromide between these exempt uses. The demand for methyl bromide is diminishing as alternatives are introduced into the market, leaving users with inventories that are no longer needed. Stakeholders have previously expressed concern over the lack of flexibility in the ODSR to allow them to transfer methyl bromide to another authorized user where a need has been identified. As the demand for this substance decreases, the lack of flexibility has resulted in growing inventories of methyl bromide with regard to some exempt uses, while imports of this substance have continued for other exempt uses. Objectives The objectives of the Ozone-depleting Substances and Halocarbon Alternatives Regulations (the Regulations) are to repeal and replace the ODSR and introduce new regulatory requirements to continue to ensure that Canada's international obligations under the Montreal Protocol are met, and to introduce a permitting and reporting system for the import, manufacture and export of HFCs. The Regulations also aim to achieve the following objectives: to support provincial and territorial government controls by introducing a prohibition on the manufacture and import of HCFC and HFC refrigerants in non-refillable containers; to allow the transfer of methyl bromide between exempt uses, thereby reducing inventories and the demand for imports of this substance; to improve the clarity of the regulatory text, make necessary administrative changes and address other administrative issues raised by the Standing Joint Committee for the Scrutiny of Regulations (SJCSR); and to allow for consequential amendments to the Regulations Designating Regulatory Provisions for Purposes of Enforcement (Canadian Environmental Protection Act, 1999) [the Designation Regulations]. Description The Regulations repeal and replace the ODSR. They add new regulatory requirements to allow Canada to meet its international commitments, and they consolidate the five previous amendments to the ODSR. HCFCs The Regulations implement the phase-out schedule for consumption and production of HCFCs in accordance with the Montreal Protocol. Given the lack of alternatives to HCFCs for use in fire-extinguishing applications, the Regulations expand the allowable uses of HCFCs until 2020 to include these applications, while respecting the applicable phase-out schedule. The Regulations also prohibit the import and manufacture of HCFC refrigerants in non-refillable containers. HFCs The regulatory provisions concerning HFCs introduce a permitting and reporting system to monitor quantities of HFCs that are imported, manufactured and exported. This will allow for more accurate projections of activities involving HFCs to inform the possible establishment of future controls. No restrictions on quantities are being introduced at this time. The monitoring measures introduced in the Regulations are coherent with Canada's participation in the North American proposal to phase down the production and consumption of HFCs under the Montreal Protocol. The Regulations also prohibit the import and manufacture of HFC refrigerants in non-refillable containers. Methyl bromide The Regulations allow for the transfer of methyl bromide between exempt uses and thus help users better manage the overall decreasing domestic demand for methyl bromide, thereby reducing inventories and the demand for imports of this substance. Other modifications A number of other changes have been made, including the integration of the ODSR and past regulatory amendments, removal of obsolete provisions, and corrections to improve the clarity of the regulatory text. The Regulations also address issues raised by the SJCSR; some wording changes have been made to improve the clarity of the regulatory text and to establish conformity and consistency between the English and French versions. Finally, the submission of quarterly reports that was required of persons with a permit for the import or export of substances under specific conditions is removed. The Regulations require the submission of an annual report rather than quarterly reports. The Regulations also eliminate the declaration of use, which users are currently required to complete and retain when transferring substances that are exempt for specific uses. Designation Regulations The repeal and replacement of the ODSR by the Regulations also require consequential amendments to the Designation Regulations. The Designation Regulations designate the various provisions of regulations made under the Canadian Environmental Protection Act, 1999 (CEPA) that are linked to a fine regime following a successful prosecution of an offence involving harm or risk of harm to the environment, or obstruction of authority. (see footnote 4) The ODSR are listed in the Designation Regulations, which must now be amended to reflect the new title and structure of the Regulations, as well as the addition of new permitting offences pertaining to the import, manufacture and export of HFCs. "One-for-One" Rule Under the Regulations, the requirement for quarterly reports is being replaced with a requirement for an annual report, which is expected to save up to three hours per stakeholder on an annual basis. In addition, the declaration of use is eliminated, which is estimated to save stakeholders 5 hours per year, assuming 10 declarations per company per year. However, the permitting and reporting measures regarding the import, manufacture and export of HFCs impose a new administrative burden on affected businesses. It is estimated that these businesses will be required to submit an average of three permits per year (up to two hours per year). Also, all regulated parties will need to learn about the administrative requirements (one hour). Overall, it is projected that the regulatory changes will result in a net decrease in annualized average administrative burden costs of around $2,200, or $35 per business, over a 10-year time frame (2012 Canadian dollars; discounting base year of 2012; 7% discount rate). (see footnote 5) The Regulations are therefore considered to be an "OUT" under the Government of Canada's "One-for-One" Rule. Small business lens The small business lens does not apply to the Regulations since the estimated annual cost impacts are below $1 million; further, the cost impacts incurred by small businesses are expected to be negligible and are not considered disproportionate. There are approximately 61 companies that will be impacted by the Regulations, including 12 small businesses. For these small businesses, the Regulations are expected to result in a net reduction in total annualized average costs of about $550, or $45 per small business, over a 10-year time frame (2012 Canadian dollars; discounting base year of 2012; 7% discount rate). Consultation Consultations prior to the publication of the proposed Regulations in the Canada Gazette, Part I Consultations were conducted on several occasions, providing opportunities for interested parties to review and comment on the proposed regulatory provisions. The consultations addressed the nature of the proposed provisions and any ancillary concerns related to their implementation (e.g. administrative practices or policy interpretation). The consultations involved the dissemination of a discussion document by email and its posting on the Department's Web site, face-to-face discussions, and the solicitation of written comments and submissions. Participants in consultation sessions included regulated parties, namely, companies exporting, importing, manufacturing, using and selling ODSs; representatives of provincial and territorial governments; environmental non-governmental organizations; and public advocacy groups. HCFCs In 2008, the Department consulted stakeholders on the Government of Canada's plan to implement the commitments made in the Montreal Protocol to accelerate the HCFC phase-out, simplify the HCFC consumption allowance system, prohibit the import, manufacture and export of refrigerants in non-refillable containers, and clarify and streamline administrative requirements. The Department presented various options on ways to implement the accelerated HCFC phase-out, including a more aggressive phase-out schedule than that agreed to by the Parties to the Montreal Protocol. Stakeholders believed that by maintaining the provisions in the ODSR related to the use of HCFCs after 2015 and adhering to the phase-out schedule as agreed upon by the Parties, Canada would be ahead of the phase-out schedule without having to adopt a more aggressive schedule domestically. Stakeholders supported the proposed regulatory provisions related to the simplified allowance system, as well as the proposed provisions related to non-refillable containers and administrative requirements. Stakeholders requested an opportunity to review the proposal prior to its publication in the Canada Gazette, Part I. In 2013, stakeholders were given the opportunity to review the proposal. A consultation document was provided to stakeholders in advance of a meeting in June 2013, explaining the proposed provisions and how the Department had addressed stakeholder feedback obtained during the consultations in 2008. During the multi-stakeholder consultation meeting held in June 2013, stakeholders expressed concerns regarding the regulatory provisions limiting the use of HCFCs only to refrigerants, and prohibiting their use in other applications such as fire extinguishing, after 2015. Given the lack of alternatives to HCFCs for use in fire-extinguishing applications, stakeholders requested that this use be allowed to continue after 2015. Provisions to allow the continued use of HCFCs in fire-extinguishing applications are included in the Regulations. HFCs In June 2013, the Department consulted stakeholders with respect to adding HFCs to the list of substances controlled under the proposed Regulations, introducing a permitting and reporting system for the import, manufacture and export of HFCs, and prohibiting the import and manufacture of HFCs in non-refillable containers. During this consultation session, stakeholders expressed support for the proposed regulatory provisions. One stakeholder, while supportive of the proposal, suggested that Canada should adopt more stringent measures in addition to the permitting and reporting system being proposed for HFCs, such as introducing a phase-down approach for these substances. The Department responded that one of the objectives of the permitting and reporting system is to inform potential future controls on HFCs. Methyl bromide During a consultation session on methyl bromide held in 2008, stakeholders requested that provisions be added to the ODSR to allow the transfer of methyl bromide between exempt uses among authorized users. The proposed Regulations included provisions that would allow more flexibility for users and help reduce inventories and imports of methyl bromide. In addition, the 2008 consultation document provided to stakeholders included a proposal to add reporting requirements for the use of methyl bromide in quarantine and pre-shipment applications. Stakeholders expressed concern with this proposal given that this information was already being collected by the Canadian Food Inspection Agency (CFIA). After further analysis and consultation with the CFIA, the Department decided not to proceed with this proposal. Updates were provided to stakeholders on the provisions included in the proposed Regulations. Consultations following the publication of the proposed Regulations in the Canada Gazette, Part I The publication of the proposed Regulations in the Canada Gazette, Part I, on March 21, 2015, initiated a 75-day comment period during which interested parties were invited to submit their written comments. Various stakeholders requested changes to some elements of the proposed Regulations to modify the regulatory text for improved clarity concerning definitions or other administrative provisions. As well, some stakeholders requested clarifications regarding the applicability of the regulatory provisions. The Department has addressed most of these concerns by providing explanations to stakeholders or by making modifications to the regulatory text. The following paragraphs summarize the key issues raised by interested parties with respect to the proposed Regulations and the Department's consideration of these issues in finalizing the Regulations. Applicability of the permitting and reporting system for HFCs Comment: Several stakeholders sought clarification with respect to the applicability of the permitting and reporting system for the import, manufacture and export of HFCs and questioned whether HFCs in manufactured products such as vehicles and domestic appliances would be targeted by this system. Response: The permitting and reporting system only applies to bulk HFCs manufactured in, imported into or exported out of Canada. Therefore, HFCs in manufactured products such as vehicles and domestic appliances are not included in the scope of the permitting and reporting system. Modifications to the Regulations have been made in order to accurately convey the Department's intention in this regard. Additional information and clarification on the permitting and reporting system for HFCs will be made available to stakeholders through compliance promotion material. Permit application system for HFCs Comment: A stakeholder sought clarification on whether a company could request a permit containing its estimated quantities of bulk HFCs to be imported or exported in numerous shipments over the course of a year. Response: There are currently no limits on the quantity of HFCs that may be imported into or exported out of Canada. Instead of the Department requiring that a company submit a permit application for each import or export of bulk HFCs, the Regulations allow a company to submit an initial permit application containing its estimated quantity of bulk HFCs to be imported or exported for a given year. If a company chooses to surpass the estimated quantity in the initial permit, it may import or export additional quantities of bulk HFCs at any time throughout the year by applying for additional permits. Restrictions on the import and manufacture of HFCs Comment: Several stakeholders presented submissions on the provision in the proposed Regulations prohibiting the import or manufacture of an HFC intended for a use for which the substance has never been used in Canada. (see footnote 6) They indicated that their interpretation of this proposed provision was that it would prohibit companies from importing or manufacturing technically innovative products containing HFCs, even if the HFCs in question are already being used in Canada for other purposes. Response: The intended purpose of the proposed provision was to prohibit the import or manufacture of HFCs for uses for which ODSs have never before been used in Canada, not to prohibit the import or manufacture of HFCs contained in technically innovative products. It is recognized that section 67 of the proposed Regulations, as published in the Canada Gazette, Part I, may not have accurately conveyed the intended purpose of this provision and, as a result, the text of the Regulations has been revised accordingly. (see footnote 7) Continued use of HCFCs in certain applications Comment: A stakeholder requested modifications to the proposed Regulations to allow for the long-term use of HCFC-123 for fire protection purposes until 2030 given the uncertainties relating to other alternatives. However, another stakeholder argued that the changes introduced by the proposed Regulations, to extend the use of HCFC-123 for fire protection purposes until 2020, were not necessary. This stakeholder stated that suitable and effective alternatives, such as fire-extinguishing agents containing HFCs, are available. Response: The Regulations, which repeal and replace the ODSR, aim to ensure that Canada's international obligations under the Montreal Protocol are respected. The decision XIX/6 of the Parties to the Montreal Protocol limits the production and consumption of HCFCs in bulk between 2020 and 2030 to the servicing of existing refrigeration and air-conditioning equipment. While alternatives are expected to be readily available before 2020, in accordance with the Montreal Protocol, the Regulations extend the permitted use of HCFCs for use as a fire-extinguishing agent until December 31, 2019. Between 2020 and 2030, as per the decision XIX/6, the production and consumption of HCFCs in bulk will be limited to the servicing of existing refrigeration and air-conditioning equipment, and the Department will limit the use of HCFCs to the use of HCFC-123 during this time period. Impacted stakeholders are not expected to have issues with switching away from HCFCs for fire protection purposes after 2019. Confidentiality regarding information submitted in the annual report Comment: Several stakeholders expressed that some of the information to be submitted in the annual report should not be required as it represents confidential business information. Response: The information requested in the annual report is necessary to ensure that Canada fulfills its reporting obligations under the Montreal Protocol. The Department's usual business practice is to treat the information in the annual report submitted under the Regulations in a confidential manner. In addition, the Department recommends that regulated parties requiring that the information they submit under CEPA be treated as confidential submit a formal request for confidentiality in accordance with section 313 of CEPA. Rationale The Regulations address Canada's commitments under international agreements by phasing out the consumption and production of substances known to contribute to ozone depletion. The Regulations are expected to result in benefits to Canadians and to the Government of Canada, while reducing costs to industry. Canadians The Regulations benefit Canadians by supporting Canada's international commitments pertaining to ODSs in the Montreal Protocol. Complying with these international commitments to accelerate the phase-out of HCFCs will provide benefits to Canadians by gradually eliminating these substances from the marketplace, as well as by prohibiting their import in non-refillable containers. In addition, the Regulations demonstrate Canada's actions to address harm to the environment and human health resulting from the use of ODSs, and other issues linked to the export, import, manufacture, use and sale of these substances. For example, the HFC permitting and reporting system is expected to provide benefits to Canadians by helping to address the illegal importation into Canada of ODSs through false labelling. (see footnote 8) Government of Canada Government costs due to the Regulations are expected to be negligible. It is anticipated that costs related to enforcement, compliance promotion and administration of the Regulations will either remain unchanged or decrease slightly, as the notification process (declaration of use) will be eliminated and the current reporting requirements will be reduced. Also, as the HCFC phase-out progresses and reduction steps are achieved, administrative costs associated with the management of HCFCs will decrease. Although there is no permitting and reporting system currently in place for HFCs, it is anticipated that costs for administering such a system will be negligible. The permitting and reporting system will be similar to the one already in place for ODSs. Therefore, the Department will simply introduce HFCs into its existing system. The establishment of HFC monitoring controls will serve as a preliminary measure to track the importation, domestic production and consumption of HFCs. Information collected relating to HFCs will inform the potential establishment of future controls on HFCs and contribute to more robust data for reporting of GHG inventories in the National Inventory Report on GHG sources and sinks in Canada, which is submitted to the UNFCCC. The Regulations also complement provincial and territorial government controls on the use of non-refillable containers by prohibiting the import and manufacture of such containers. Industry The impacts to industry of prohibiting the production of HCFCs are expected to be minimal as the substance is being phased out according to the terms of the existing performance agreement. Likewise, costs to regulated parties due to the provisions in the Regulations related to the import and manufacture of refrigerants in non-refillable containers are expected to be negligible. Many regulated parties already use refillable containers, and the use and sale of refrigerants in these containers are tightly controlled at the provincial and territorial level. Further, the transfer of methyl bromide between exempt uses will reduce inventories of methyl bromide, which could result in benefits to businesses by reducing storage and insurance costs. The new permitting and reporting system for HFCs will increase administrative costs to businesses. These costs are expected to be more than offset by reductions in administrative costs that will be realized by businesses regulated under the ODSR. Specifically, notifications regarding declaration of use will be eliminated and the obligation to submit quarterly reports will be removed. Stakeholders will instead be required to submit an annual report. Designation Regulations Consequential amendments to the Designation Regulations are required to allow for the effective enforcement of the Regulations as well as to promote compliance. These consequential amendments are also necessary to consistently and accurately designate provisions of the Regulations for the purposes of enforcement. Strategic environmental assessment As required by the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary review was conducted which concluded that there would be no expected important environmental effects, either positive or negative; accordingly, a strategic environmental assessment is not required. (see footnote 9) Implementation, enforcement and service standards The service standard relating to the issuance of permits for the import, manufacture, export and use of ODSs, including permits required for products containing or designed to contain these substances, has been in place since April 1, 2014. (see footnote 10) Once the Department receives all of the information that is required for a permit to be approved, the permit is issued within 10 working days. This standard will be extended to the issuance of permits for the import, manufacture and export of HFCs. The Regulations come into force six months following the date on which they are published in the Canada Gazette, Part II. Implementation and enforcement of the Regulations will be undertaken by the Department in accordance with the Compliance and Enforcement Policy for CEPA. (see footnote 11) The compliance promotion approach for the Regulations will be similar to that taken for the ODSR, which includes maintaining a presence on the Department's Web site and responding to inquiries from stakeholders. As well, the Department will undertake outreach activities to raise stakeholder awareness of the new regulatory requirements, including the implementation of the permitting and reporting system for HFCs. Contacts Lucie Desforges Director Chemical Production Division Industrial Sectors, Chemicals and Waste Directorate Department of the Environment 351 Saint-Joseph Boulevard, 11th Floor Gatineau, Quebec K1A 0H3 Telephone: 819-938-4209 Email: [email protected] Yves Bourassa Director Regulatory Analysis and Valuation Division Strategic Policy Branch Department of the Environment 200 Sacré-Cœur Boulevard, 10th Floor Gatineau, Quebec K1A 0H3 Email: [email protected] Footnote a S.C. 2004, c. 15, s. 31 Footnote b S.C. 1999, c. 33 Footnote c S.C. 2002, c. 7, s. 124 Footnote d S.C. 1999, c. 33 Footnote 1 http://ozone.unep.org/en Footnote 2 United Nations Environment Programme (2011). HFCs: A Critical Link in Protecting Climate and the Ozone Layer: A UNEP Synthesis Report. Chapter 3, section 3.2. Footnote 3 Short-lived climate pollutants include HFCs. Footnote 4 http://www.ec.gc.ca/lcpe-cepa/eng/regulations/detailReg.cfm?intReg=206 Footnote 5 The non-rounded decrease in annualized average administrative burden costs was estimated to be $2,222, or $36 per business. The wage rate was assumed to be around $45 per hour in all cost calculations (weighted hourly average). Footnote 6 See section 67 of the proposed Regulations: http://gazette.gc.ca/rp-pr/p1/2015/2015-03-21/html/reg1-eng.php. Footnote 7 See sections 64 and 65 of the Regulations. Footnote 8 Cases of unlawful imports containing controlled ODSs have been identified in which imported ODSs were falsely labelled as HFCs. Footnote 9 Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals: http://www.ceaa.gc.ca/default.asp?lang=En&n=B3186435-1. Footnote 10 http://www.ec.gc.ca/default.asp?lang=En&n=2019647B-1 Footnote 11 http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=5082BFBE-1