Thank you for the…

Thank you for the opportunity to comment on the regulatory amendments to air emissions of sulphur dioxide (SO2) and other items. The Region of Peel – Public Health is satisfied that the proposed SO2 standards and AAQCs are based on a recent and extensive review of the scientific evidence which was completed by Health Canada and Environment and Climate Change Canada. The standards reflect the well-documented health impacts of SO2, which most commonly includes worsening symptoms for those with chronic respiratory conditions and a resultant increase in hospital admissions and emergency department visits. We also feel that the uncertainty factor that has been applied appropriately protects both the general population and sensitive subpopulations.

We agree that converting the acute effects-based 10-minute reference concentration to a 1 hour standard will minimize the number of 10-minute periods in an hour that exceed the reference concentration and overall minimize the spikes in levels of SO2. This health protective approach reduces the frequency of exceedances of the reference level which is the level that protects the most susceptible population (asthmatics) to the most critical effects (bronchial constriction, respiratory hospital admissions/visits). We are also in support of setting the annual standard to be protective of ecological effects as the most critical impact for long-term SO2 exposure. It is also important to acknowledge that the proposed amendments to SO2 standards support the efforts aimed at reducing the health impacts of other air pollutants (i.e. relationship between SO2 and secondary formation of particulate matter).

With respect to applying the updated SO2 standards on a regional basis, the Region of Peel - Public Health strongly opposes geographically-based standards that would see a more stringent, health protective SO2 standard applied only in Southern Ontario with the current standards remaining in effect for Northern Ontario. This approach does not support our collective public health efforts to ensure health equity across all Ontario communities. It is unclear as to why this option is being considered as a rationale for this approach has not been articulated. For those facilities that feel they cannot comply with the updated SO2 standards at the present time, Regulation 419 includes provisions to apply to the MOECC for site-specific standards. In the case of groups of facilities in specific industrial sectors, the sector can apply for technology-based standards if they anticipate not being able to meet the standard for technical or economic reasons.

Regarding transitional operating conditions (TOCs), the Region of Peel – Public Health supports the MOECCs efforts to a) clarify the modelling guidance provided to facilities, b) obtain discharge information and c) address those discharges that are not part of normal operations. Emissions associated with TOCs such as start-ups and shutdowns can result in higher but typically shorter-lived air pollution releases. This can result in increased population exposure in surrounding communities.

In summary, Region of Peel - Public Health supports the proposed amendments to the SO2 standards and to the transitional operations modelling and information requirements. The changes reflect current scientific evidence related to health and ecological effects. It is important that the standards apply equally across Ontario and that spikes in elevated levels of air pollutants are minimized to every extent possible even when associated with discharges that are not part of normal operations.

Once again, thank you for the opportunity to submit comments. If you require clarification please contact Louise Aubin (louise.aubin@peelregion.ca) or Franca Ursitti (franca.ursitti@peelregion.ca).

Sincerely,

Jessica Hopkins, MD MHSc CCFP FRCPC
Medical Officer of Health
Region of Peel - Public Health
7120 Hurontario Street
Mississauga, ON L5M 2C2
905-791-7800 extension 2856
jessica.hopkins@peelregion.ca

[Original Comment ID: 211519]