This facility, built in the…

This facility, built in the 1950s, has been operating on some very old CofAs. I therefore applaud the Ministry's desire to replace all the CofAs for air at this facility and replace them with a comprehensive, consolidated and updated Environmental Compliance Approval (ECA) that includes the addition of new or historically unapproved sources for all emissions from this facility.

Given the poor environmental track record of this facility, and the lack of effective, timely compliance and enforcement, however, I question whether ECA-with Limited Operational Flexibility (ECA-LF) should be issued; instead a standard ECA should be issued.

I believe there is a need for stricter conditions and effective and timely Ministry oversight at this facility, particularly when the facility cannot meet NOx and SO2 standards set in the 1970s (much less the "new" 2023 SO2 standard).

The Proposal Summary notes that the facility has also made a request for site-specific standards for this facility for SO2 and NOx emissions. I will be submitting comments on that request later this week. I respectfully ask that you consider my comments related to the site specific standards as part of my comments on this proposal also. Included in my comments to be submitted later this week are fundamental issues such as why are site-specific standards being considered instead of compliance/enforcement proceedings, the lack of a holistic approach and openness on the part of the facility, failure to assess cumulative effects despite evidence of the need to do so. All of these matters call into question why an ECA-LF should be considered.

If an ECA-LF is issued for a limited time period, I do not believe that this facility, given my comments here and in the comments provided in my submission on the site-specific NOx and SO2 standards, should be given an opportunity to reapply for an ECA-LF at the end of limited time period. Instead, the ECA-LF should revert to a standard ECA.

In addition to the request for site-specific standards for this facility, the facility has also been actively working to add natural gas to its fuels, as the Ministry knew. The information provided to the community on this proposal and on the proposal for site-specific standards failed to take into account the change in fuel in the ESDMs. To be clear, I support the replacement of coal as the operating fuel at this facility with natural gas. I believe, however, that the ESDMs submitted should take the change in fuels into consideration.

In addition, the Ministry was aware of the facility's intent to submit an application to burn waste-derived fuels, called ACLF, at this facility. To be clear, I do not support the use of ACLF at this particular facility. However I believe that up-front, transparent information should be provided to the community and in the ESDMs.

Has the ESDM for this proposal for an ECA-LF taken the change in fuels into account? I do not believe it has. I believe it should consider all inputs, including fuel (coal, chlorinated waste solvents, and natural gas, and, if deemed even appropriate for this specific facility, ACLF).

Therefore, given the incomplete nature of the ESDMs provided to the community, I do not believe the facility has fulfilled its obligations to even apply for this ECA-LF.