Toronto Public Health (TPH)…

Toronto Public Health (TPH) supports the Ministry of the Environment and Climate Change's proposed policy Cumulative Effects Assessment (CEA) in Air Approvals. The CEA proposal sets up a framework to approve new or expanding facilities in Hamilton and Sarnia for two pollutants. While this is a good first step, TPH encourages the Ministry to develop a comprehensive cumulative effects policy covering emissions of all pollutants across the province.

Below are responses to the questions posed by the Ministry in the consultation document:

1.What other information should be considered in defining areas where CEA policy applies?

A number of factors should be considered when defining areas where CEA policy applies. Ambient air quality data should be used to screen all locations with data in order to identify areas that are consistently near or above the Ambient Air Quality Criteria (AAQC). In addition, the Ministry should capitalize on existing databases with emissions information including the National Pollution Release Inventory and Toronto's ChemTrac program reporting data to identify other areas of potential concern without ambient air quality monitoring data. The Ministry should also consider using any relevant information on the potential for significant emissions resulting from transient operating conditions. The characteristics of the exposed population should be considered. Densely populated areas and locations with sensitive and marginalized populations should be prioritized. Lastly, priority locations identified through the Air Zone Management Framework should also be assessed through the CEA policy.

2.Are there other requirements that should be considered for each of the action levels?

Risk communication and community engagement should be considered at each of the action levels. In its present form, it is unclear how the Ministry would communicate the results from multi-source modeling or decisions to allow a new or expanded facility to the public. Having this mechanism in place for facilities operating in a compromised airshed is an important consideration to maintain public trust.

3.What should the ministry focus on as priorities for future steps?

TPH encourages the Ministry to continue to identify pollutants or groups of pollutants of interest. This may not be strictly limited to carcinogens but other pollutants that can cause non-cancer acute and chronic health effects. TPH also encourages the Ministry to examine emissions precursor gases that enable fine particulate matter and ozone to form. These secondary pollutants contribute to a large burden of illness related to cardiovascular and respiratory diseases in many parts the province. Limiting their formation would improve the health of Ontarians.

In its current form, the CEA proposal presents a framework for approving new and expanding facilities. However, the overall policy objective of this proposal is not clearly defined. TPH encourages the Ministry to define the policy objective (e.g. lower emissions, improve health) and to formulate an evaluation plan.

Lastly, the CEA proposal is a first step towards a comprehensive risk management strategy for air pollutants across Ontario. In urban areas, non-industrial sources contribute significantly to the area's air quality. While not covered under O. Reg 419, traffic related air pollution is a major health concern. Toronto's Board of Health recently adopted recommendations aimed at reducing traffic-related air pollution (HL22.3). TPH acknowledges that the Air Zone Management Framework is intended to address non-industrial emissions; however, it is unclear how the CEA and Air Zone Management Framework fit together. TPH encourages the Ministry to further develop the Air Zone Management Framework in parallel with the CEA policy to continue to address both industrial and non-industrial sources.

Thank-you for the opportunity to comment.

[Original Comment ID: 212365]