February 2, 2017…

February 2, 2017

Lubna Hussain, Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West, Floor 7
Toronto, Ontario M4V 1M2

Re: EBR Registry 013-1680 Cumulative Effects Assessments in Air Approvals

Hamilton Public Health Services is supportive of the Cumulative Effects Assessment (CEA) in air approvals and commends the Ministry of the Environment and Climate Change (MOECC). Cumulative effects are an important consideration for the overall protection of population health in Hamilton with respect to benzene and benzo[a]pyrene.

Please see below Hamilton Public Health Services comments to the MOECC’s proposed questions.

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

•The MOECC should consider all Canadian Ambient Air Quality Standards (CAAQS) when undergoing cumulative effects assessment such as PM2.5 and NO2.

•To help identify other local contaminants of concerns it is important for the MOECC to work with local MOECC district offices and community organizations focusing on improving air quality. Clean Air Hamilton is comprised of federal/provincial/municipal government staff, industrial partners, not-for-profit organizations, academic partners and individual citizens all with knowledge of local air quality concerns that can be beneficial to the MOECC.

•Majority of benzene and benzo[a]pyrene in Hamilton are from local sources which the CEA model addresses. However moving forward to other contaminants of concern it will be very important for the model to consider transboundary sources since a significant portion of contaminants can be attributed to contributions originating from outside the city but potentially contributing to adverse population health impacts within the City of Hamilton..

•MOECC should consider receiving data from more than 3 Hamilton air monitors to more accurately measure concentrations at sensitive receptors in the east of Hamilton, which sits at a level 2 currently.

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

•If a company is designated as within Action Level 3 (>1 in 10,000), the company be given sanctions not to increase production if risk level is not reduced or meaningful Point of Infringement (POI) limits are reach.
•New companies cannot be approved within compromised Action Level 3 areas or even Level 2 unless they meet minimum 1 in 100,000 levels.
•Action Level 3 should contrast to the lowest possible emission rates globally and not just North America. If it is proven North America is the best technology it should be backed by sound evidence.

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

•Strengthening collaborative partnerships with the Ministry of Health and Long-Term Care and Public Health Ontario in addressing CEA policy is imperative as we work to protect population health from air pollution impacts.
•Source apportionment be deciphered if you have a certain amount of emitters within a specific zone.
•MOECC take into consideration the legality and potential difficulty of enforcing O.Reg.419/05 by allowing a few companies to emit larger amounts of certain contaminants through the Site Specific Standards (SSS) which will negatively impact another smaller company to grow due to the already compromised airshed.
•Risk communication that assists local public health units in messaging risk consistently across the province to meet the needs of the population being served.

Sincerely,

Trevor Imhoff
Coordinator – Air Quality and Climate Change
Hamilton Public Health Services
110 King Street West – 3rd floor, Hamilton, ON, L8P 4S6
City of Hamilton
Clean Air Hamilton
Phone: 905-546-2424 ext. 1308

[Original Comment ID: 212385]