In my opinion the extension…

In my opinion the extension should not be granted for the following reasons:

1. Extending the site-specific standard for both particulates and benzene does not follow the regulation’s principle of continuous improvement.

2. The ESDM for 2019 shows the facility had a value of 116 ug/m3 and therefore met the standard of 120 ug/m3. Assuming similar operations and maintenance the plant should be able to continue to meet the current site-specific standard.

3. Benzene values under the site-specific standard of 2.2 ug/m3 are five times the regulation value of 0.45 ug/m3. Extending the site-specific standard at the current level represents a continued health risk.

4. Articles have appeared in the media suggesting that Algoma is being give an exemption from the regulated values and are getting a free pass to continue to emit beyond what the Ministry’s regulation considers to be a safe level.

Given that the site-specific standard expires at the end of 2020 not much time is allotted to review the public comments and it is hoped that all comments will be carefully considered. The facility has been aware of the deadline and at most a one year extension would be reasonable.