Within the hour, I submitted…

Within the past hour, I submitted a comment on this proposal. Please accept this as an addendum to that submission.

As stated, I do support the Ministry in its desire to replace all the CofAs for air at this facility and replace them with a comprehensive, consolidated and updated ECA that includes the addition of new or historically unapproved sources for all emissions from this facility.

I believe that the sooner a well-done, comprehensive, appropriate ECA can be issued, the better it will be for compliance/enforcement officers and for the environment.

As expressed in my earlier submission, I have serious concerns about the transparency of the facility's environmental communications and ESDMs and, in general, about the facility's dedication to its responsibilities for meeting environmental standards and communicating with the community.

The proposal does not provide any justification or rationale for why an ECA-LF is better in this particular instance for this particular facility than a standard ECA. Further, it is not clear why consideration of an application for a subsequent ECA-LF might be justified and would constitute the preferred choice for the environment and the community for this particular facility. I submit that failure to consider known plans for fuel changes should not be considered a reasonable justification.