Thank you for the…

Thank you for the opportunity to comment on the Cumulative Effects Assessment (CEA) in Air Approvals proposal. The following outlines Peel Public Health’s (PPH) responses to the questions posed in the consultation document:

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

Defining areas where the CEA policy applies should be based on rigorously conducted and peer-reviewed evidence. PPH agrees with the use of ambient air quality monitoring data (both from the MOECC stations as well as the federal National Air Pollution Surveillance Program), data from the National Pollutant Release Inventory and compliance monitoring required by the MOECC. As well, PPH recommends that the MOECC evaluate the data contained in the Toxic Reduction Act database as well as the data from Toronto’s ChemTRAC program. This data should inform the decision to conduct further assessments (for example, multi-source modelling).

The proposal is not clear about what concentration of a pollutant would trigger the MOECC to conduct multi-source modelling. PPH recommends that the MOECC develop criteria to determine when multi-scale modelling would be triggered for future assessments.

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

Communication is a key component of risk management. When a contaminant exceeds the AAQC (Level I and beyond), and multi-source modelling is complete, a communications strategy should be developed to communicate the results of the multi-source modelling. Key stakeholders should include:
•the MOECC district office,
•the sources of the contaminant in the affected area (industry or others)
•other Ministries as appropriate (i.e., Ministry of Transportation if a provincial highway is involved)
•the regional/area municipality and
•the local public health unit and Public Health Ontario.

The multi-source modelling provides important information that can influence land use planning (for example, zoning, subdivision approvals, transportation and other infrastructure planning) as well as public health actions. This information should therefore be shared with the appropriate partners as soon as possible.

The data should be used to trigger a locally-based working group to identify, implement and evaluate solutions to reduce the contaminant.

The data should also be communicated to the residents of the community so appropriate risk messages are developed and disseminated.

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

This proposal lays out a framework for the approval of new and expanding facilities under O. Reg 419, focussing on two geographical areas of concern and two contaminants. In the short term, Peel Public Health encourages the MOECC to articulate the desired goals and outcomes of the proposal and to develop and implement an evaluation plan to inform and guide future work in this area.

Peel Public Health also encourages the MOECC to evaluate the Ambient Air Quality Criteria data to identify other areas in Ontario with exceedances in order to ensure the health of all Ontarians is protected. Along with this, a risk management framework for non-carcinogens should be developed in the near-term. A longer-term outcome should include the development of a framework for contaminants emitted to air that are precursors (e.g., to ozone or fine particulate matter), persistent in the environment or bioaccumulative. The framework should also include a discussion of how trans-boundary sources are intended to be handled.

Lastly, emissions to air come from many sources and result in human exposure leading to adverse health outcomes. In order to protect human health, the sources of emissions to air need to be understood, areas of concern identified and comprehensive risk management strategies need to be implemented. The proposed EBR begins to address the source and areas of concern and is a part of the risk management solution but it is not comprehensive because it is limited only to approvals under O. Reg 419. The proposal and discussion paper notes that it is through other programs such as the Air Zone Management Framework that actions by non-industrial sources would be addressed. The MOECC has not defined how this would happen. If the cumulative effects work is only applied to industrial sources, there are other major sources that would not be addressed and risk management strategies need to be applied to these sources. Peel Public Health encourages the MOECC to broaden the work on cumulative effects to air beyond just the approvals of new and expanding facilities to comprehensively address cumulative effects and to develop a framework for this work. This framework should include how the MOECC would engage, communicate, and work with other stakeholders such as other ministries and partners.

Lastly, the CEA needs to be evaluated for all the compliance options (i.e., site specific standards…) under O. Reg 419.

Thank you again for the opportunity to comment. Peel Public Health looks forward to continuing to work with the MOECC on this important issue.

[Original Comment ID: 212372]