EBR Registry No. - 013 1680…

EBR Registry No. - 013 1680
Cumulative Effects Assessment in Air Approvals
Submitted by – Victims of Chemical Valley; Sarnia
January 30, 2018

This EBR post for this proposal states in the description that this is:
A new policy …….. to more effectively consider cumulative impacts from multiple air pollution sources – both industrial and non-industrial.

However, VOCV feels that this does not consider the impacts of multiple air pollution in the air sheds to which it uniquely applies, which are Sarnia and region and Hamilton and region. This proposal will not apply to the multiple, existing industrial and non-industrial sources that put populations in those air sheds at unique risk. Thus, it may consider but will not serve to address provincial responsibility for the environmental health of populations in those regions.

This proposal is intended to outline a process for approving new emitters into those high risk airsheds; it even contemplates its potential use in establishing a Site Specific Standard where a new or expanding facility cannot meet the provincial standard.

VOCV does not support the addition of any emissions into airsheds that are out of regulatory attainment. The identified airsheds are known for their complex mixture of emissions with its poorly understood combined impact, and populations under stress.

We do not understand how the province could contemplate approving emissions in such airsheds, but notes that the methodology proposed is weak in areas of identification and assessment. For example, the province is currently undertaking work that will establish a baseline for population health in Sarnia. Should models use the unique health baseline of the community being impacted? Should the models account for the increased exposure associated with occupational or recreational exertion in poor air quality?

We appreciate that recent federal and provincial commitment to a number of improved emission standards, when fully implemented, may create opportunity in these airsheds for new ECA’s. It would be useful to revisit the proposal at that time.

If the province proposes to investigate cumulative impact assessment as a general regulatory tool for environmental-health protection in Ontario, then VOCV would be interested in commenting on appropriate application and methodology.

[Original Comment ID: 212311]