December 10, 2017…

December 10, 2017

Lubna I. Hussain, Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West, Floor 7
Toronto, Ontario, M4V 1M2

Re.: Regulatory amendments related to air emissions of sulphur dioxide and other items (EBR #013-0903)

Dear Ms. Hussain:

BESTECH appreciates the opportunity to comment on the proposed changes to the air standards for sulphur dioxide (SO2) and clarify the requirements for assessing operating conditions in O. Reg. 419/05.

BESTECH has been maintaining the SO2 network of 18 stations in Greater Sudbury since 2003. We collect, validate and report on SO2 data in the community for both smelter operations and the Ministry of Environment and Climate Change (MOECC). This data (collected in real-time) is used by smelter operations to control emissions and protect public health.

SO2 data is also made available on a public access website (www.sciencenorth.bestech.com).

We value the work the MOECC are doing at improving the protection of human health and the environment. While we are committed to these same goals, we are concerned of the potential negative effect this may have to our local economy as this proposed change along with other requirements would exert greater financial burdens on our local smelting facilities. We have seen the effects on industry due to high electricity prices alone, forcing closures or industry moving to other provinces.

Having grown up in Sudbury, I have seen a significant reduction in SO2 emissions in the community. The airshed in Northern Ontario is much different relative to Southern Ontario, and we believe a different approach should be applied in the North, given such a large area and so few emitters.

We trust that you will consider our comments when finalizing updates to the standard. Thank you for the opportunity to provide our input on the regulatory amendments related to SO2.

Sincerely,

Marc Gascon
Manager, Product Support
BESTECH
1040 Lorne Street, Unit #3
Sudbury, ON P3C 4R9

[Original Comment ID: 211504]