December 11, 2017…

December 11, 2017

Lubna Hussain
Ministry of the Environment and Climate Change
40 St. Clair Avenue West, Floor 7
Toronto, Ontario
M4V 1M2

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

Dear Ms. Lubna,

Thank you for the opportunity to comment on EBR Registry Number 013-0903, Regulatory amendments related to air emissions of sulphur dioxide and other items. On behalf of the Ontario Forest Industries Association (OFIA), I would like to provide the following comments on the October 27th Ministry of Environment and Climate Change (MOECC) proposal.

Ontario’s forest sector generates $15.5 billion of economic activity and provides well-paying jobs for 172,000 people in every region of the province. Our forestry sector is proud of the leadership role we have taken in reducing greenhouse gas emissions and improving emissions affecting local air quality. As stated in the 2015 Air Quality Report prepared by the MOECC, since 2006, the Ontario sulphur dioxide (SO2) emissions were reduced by 48 percent. Our members are committed to continue reducing the air emissions, as the industry continues to invest and innovate.

As a result, OFIA does support the Canadian Ambient Air Quality Standards (CAAQS), but does not agree with the intended application proposed in the current EBR posting. CAAQS, established as air quality objectives under the Canadian Environmental Protection Act and approved by the Council of Ministers of the Environment, are intended as community objectives, to drive the improvement of air quality through public reporting and air zone management, and not as the basis for industrial property line limits, or “never to exceed” limits. Northern Ontario being in a zone that requires no further management action, it would be justified maintaining the current SO2 standards in the region.

The new proposed standards would require a mill to meet a maximum point of impingement (POI) standard that nears half of the CAAQS. This is of very significant concern to members of OFIA as achievability of the new standards is technologically not possible, given the current available process configurations in our facilities. Registering to the technical standard as the alternate pathway to compliance implies tedious processes, that can take years to complete, with a significant impact on industry’s and MOECC’s resources, as proven in the past.

By establishing AAQS and standards that are the most stringent in Canada, and in the world, without consideration for achievability or economic issues, MOECC creates a high level of business uncertainty, affecting the industry’s competitiveness.

It is important to note that all three pillars of sustainability – environmental, social and economic – must be recognized and considered when proposing new or changing regulations. The broader economic and social impacts to the local communities should be considered when establishing new standards. The cost and uncertainty of meeting the new SO2 standards, if applied across all of Ontario, presents a serious risk to business operations and new investments. Thereby, affecting families among the 57,000 hard-working men and women employed directly by Ontario’s forest products sector.

The sector remains committed to working with the MOECC on this important file and look forward to the further discussion on developing a standard for SO2 that will achieve the protection of health, environment and will consider the economic concerns.

Sincerely,

Lauren McBride
Environment and Energy Advisor
Ontario Forest Industries Association

[Original Comment ID: 211520]