December 11, 2017…

December 11, 2017

Lubna 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: EBR Registry 013-0903 Regulatory Amendments Related to Air Emissions of Sulphur Dioxide and Other Items

Sulphur Dioxide

Overall Hamilton Public Health supports the proposed amendments to O.Reg.419/05 including Schedule, 3, Schedule 6 and Schedule 7. Public Health supports the rationale for updating the air standards and Ambient Air Quality Criteria (AAQC) for Sulphur Dioxide that will protect the most sensitive populations (asthmatics, the elderly and young children). As Hamilton contains an intensive industrial core and experiences short-term (acute) exposures, these more stringent SO2 concentrations will help to protect our most sensitive populations.

Hamilton Public Health strongly disagrees with the proposal to exclude northern Ontario for the updated SO2 standards. This two tier system approach is not consistent with the science only approach the ministry has used to establish these new standards. Furthermore, there are several SO2 intensive facilities located within northern Ontario including in Sudbury and Sault St. Marie. This two tier system is also not consistent with Ontario’s air zone delineation approach that designated Sudbury and Sault St. Marie as an Air Zone 2 which is the same designation has the majority of southern Ontario. There is concern regarding the 2 tier SO2 approach whereby Sudbury would be subject to a different/less stringent SO2 standard than remaining areas of Ontario. Given this difference in the SO2 standard, there is a potential for transboundary effects originating from Sudbury to be negatively impacting the Cumulative Effects Assessment (CEA) undertaken in other areas of Ontario that are working to meet the more stringent SO2 standards. Due to these reasons we at Hamilton Public Health strongly encourage the ministry to adopt these standards across all of Ontario.

Transitional Operating Conditions

Public Health supports the changes made in Section 10 of O.Reg. 419/05 regarding the Transitional Operating Conditions (TOC). Modeling certain scenarios will help prevent potential acute exposures during unlikely scenarios. Additionally it also important to have a tool that allows the Director to require a facility to consider “non-normal” operating scenarios.

It will be important for MOECC to work with local stakeholders to help identify what “non-normal” scenarios are occurring locally and the concerns of the community.

Thank you for taking the time to read these comments. If you have any questions regarding these comments please do not hesitate to contact the undersigned below.

Sincerely,

Trevor Imhoff
Coordinator – Air Quality and Climate Change
Hamilton Public Health Services
110 King Street West – 3rd floor, Hamilton, ON, L8P 4S6
City of Hamilton
Clean Air Hamilton
Phone: 905-546-2424 ext. 1308

[Original Comment ID: 211507]