Comment
More information needs to be provided on new or expanding facilities that would be required to purchase and operate ‘best available’ pollution control technologies as a result of high concentrations noted in the cumulative effects assessment. Newer facilities with better technology, equipment and pollution control devices should not be held responsible for mitigating cumulative air impacts from surrounding facilities that are older sites with outdated and worn pollution control technology and equipment. If each site is required to meet, at minimum, a sector based standard then the whole area should meet the sector based standard.
Consideration and direction should be provided in the proposal that in the event it is evident that the cumulative effects assessment demonstrates that surrounding facilities do not meet the air criteria then it is their responsibility to mitigate, not the new or expanding facility.
[Original Comment ID: 212034]
Submitted February 9, 2018 10:59 AM
Comment on
Cumulative effects assessment in air approvals
ERO number
013-1680
Comment ID
595
Commenting on behalf of
Comment status