December 11, 2017…

December 11, 2017

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

The Ontario Society of Professional Engineers’ (OSPE) comments on Regulatory Amendments to Ontario’s Air Standards for Sulphur Dioxide Emissions (EBR 013-0903)

Ms. Hussain,

The Ontario Society of Professional Engineers is pleased to offer comments to Ontario’s Ministry of the Environment and Climate Change regarding the proposed amendments to Ontario’s Air Standards for Sulphur Dioxide Emissions.

At a high-level, OSPE is impressed by the thorough approach and organization of the proposed regulation. The need for more stringent standards is well described, based on epidemiological data. The comparisons with standards from other jurisdictions sets a good background for Ontario and puts the proposal in context.

OSPE’s comments present recommendations concerning six elements of the proposal:

1.ADOPT THE HEALTH CANADA 10-MINUTE AVERAGE STANDARD

The Ministry of the Environment and Climate Change should adopt the Health Canada standard of 175 ug/m3 for an average 10-minute discharge of SO2 for its Reg. 419 standard.

2.ESTABLISH A 30-MINUTE AVERAGE STANDARD

The Ministry of the Environment and Climate Change should develop a 30-minute average standard for the discharge of SO2 for its Reg. 419 standard.

3.MEASURING CUMULATIVE IMPACTS

The MOECC should develop a clear guideline with regard to how it will take cumulative impacts into consideration via its regulatory functions. This could include the decision whether to issue an environmental compliance approval or not; determining what conditions to impose upon an approval; setting air standards; and updating the permit-by-rule regulation for activities with air emissions.

4.REVIEW & EVALUATION

The Ministry of the Environment and Climate Change should provide a review and evaluation component to show how effective Regulation 419 has been in the regulating SO2 air emissions and other air pollutants in Ontario. Part of the evaluation should include a summary of the past five years of all enforcement actions (administrative infractions excluded) as a result of Regulation 419.

5.SCIENTIFIC ACCURACY

The Ministry of the Environment and Climate Change should review the scientific accuracy of the following statement in the section entitled: Other Information: Sulphur Dioxide. “Generally, a URT is set as a multiple of a given standard. For substances with non-carcinogenic effects, the URT is set 10-fold higher than the standard. For substances with carcinogenic effects, the URT is set as 100-fold higher than the standard.” OSPE has concerns that this is not accurate.

6.LOCAL AIR QUALITY vs REGIONAL AIR QUALITY

It is OSPE’s concern that members of the public, industry stakeholders, and even some experts may not understand the difference between local air quality and regional air quality.

Without a clear explanation it may cause stakeholders to ask questions like, “why is the government making Ontario’s standards more stringent? Hasn’t Ontario already shut down its coal-fired electricity generators?” To help pre-empt these questions the preamble could better explain that O.Reg.419/05 aims to address local air quality – not regional air quality that has long been improved by the closure of coal-fired plants.

Questions & Comments:

For any questions or comments regarding this document, please contact Patrick Sackville, Lead, Policy and Government Relations at (416) 223-9961 ext. 225 or patrick@ospe.on.ca.

About OSPE:

The Ontario Society of Professional Engineers (OSPE) is the voice of the engineering community in Ontario. We represent 80,000 professional engineers and over 250,000 engineering graduates who contribute to the most strategic sectors of Ontario’s economy.

OSPE elevates the profile of engineers by advocating with governments, offering career building services, and providing opportunities for ongoing learning, networking, and community building.

Engineers are trained, innovative problem solvers who develop solutions by considering costs and benefits, sustainability, public safety, and the complete lifecycle and integration of projects. Engineers are also on the frontlines of developing, safeguarding, and maximizing Ontario’s investments.

OSPE was formed in 2000 after members of Professional Engineers Ontario (PEO) voted to separate regulatory and advocacy functions into two distinct organizations.

[Original Comment ID: 211527]