EBR 013-1680 – Cumulative…

EBR 013-1680 – Cumulative Effects Assessment in Air Approvals // Multi-source Modelling and Cumulative Effects -- Benzene and Benzo(a)Pyrene

It is encouraging to see that the Ministry of the Environment and Climate Change (MOECC) of Ontario in conjunction with other stakeholders has developed a policy proposal to look at the Cumulative Effects in Air Approvals for Effects Benzene and Benzo(a)Pyrene to apply to new and expanding industries.

As I look at the documents, I am thinking of other things that should likely be considered and some possible actions for the future.

Existing Facilities
-- currently, this proposal only looks at new and expanding facilities, it would be very useful for it to apply to current industries in the area
-- if areas where current industries exist exceed Ambient Air Quality Criteria (AAQC), then there is a problem with having those industries there – even if the MOECC is working with them to conform to regulations. It often takes too long for upgrades and extensions are given. What is the effect on residents and area flora and fauna when excessive levels are not curtailed in short order?

Effects on non-human Flora and Fauna
-- it sounds like this proposal is focusing on the cumulative effects of Benzene and Benzo(a)Pyrene toxins because of the human cancers that are caused by them
-- what about the effects on other flora and fauna in the area
-- does the MOECC exchange information with other ministries, such as Ministry of Natural Resources and Forestry
-- if the cumulative effects harm humans, then surely, they must affect animals, birds and fish as well as plants – even our agricultural areas
-- and what about people who grow vegetables and fruit in the area in their own back yards and eat it – surely the air would affect what is grown

Air Quality vs Water
-- does the MOECC have a tag team within the ministry (or with Ministry of Natural Resources and Forestry) who looks at the effects on water and drinking water from the Benzene and Benzo(a)Pyrene toxins that not just are in the air, but drop into the water
-- or when it rains, brings the toxins into the lakes, streams, and wastewater facilities

Workers within Points of Impingement
-- does this proposal suggesting sharing and/or comparing results with the Ministry of Labour for people working on site
-- how does the cumulative effects modeling affect them if they also live in the area – a double whammy – for the want of a better word

Ceiling on Industry that can be introduced to the area
-- this proposal looks at the ambient air quality to see if there is “pollution room” for other industries to be introduced to the area
-- the action levels regarding the standard Ambient Air Quality Criteria (AAQC) seem, to me, have weak “requests” for new or expanding facilities – too many “may” be required items rather than “must” when it comes to emission controls
-- if the goal is to achieve standards that fall at or below standard AAQC, then why would you not be absolute in your requirement to stop new or further emissions
-- and, in this regard, is there a ceiling at which no new facilities can be in the area – a moratorium on more facilities – and, instead work toward bringing levels down to the AAQC standard – or better than minimum

Monitoring stations external to company involvement
-- it is my understanding the current industries contribute to the Hamilton Air Monitoring Network (HAMN) which monitors the air quality
-- how arms length is this group vs if the monitoring was being done strictly through the MOECC
-- I would rather see companies have to pay a tax or required stipend to the MOECC and the Ministry do the monitoring independently rather than have an organization measure it that has member companies make up their Board – to me, that is not independent monitor reviewing

Location and timing of monitors
-- when I look at the placement of the monitoring stations, I would like to see more, and it would be helpful to see samples from within neighbourhoods where residents live adjacent to the industries
-- also, my understanding is that the monitors work for a 24hour period every 6 days
-- could it not be random
-- I know that I am presupposing possible nefarious action on the part of the industries, but could it not be possible for industries to keep track of the timing of the monitors and know when they can let down their guard on contaminants
-- hopefully, that is not the case, but I don’t know
-- a pop test is a good snapshot to see if students have been able to learn what was taught – why not the same for polluting industries

Having expanded on my comments, I do feel that the MOECC’s proposal for monitoring/modeling cumulative effects of contaminants on air quality is a good step and hope it can be expanded to other toxins and particulates

Thank you for the opportunity to comment.

[Original Comment ID: 212346]