As Lead, Integrity of…

As Lead, Integrity of Creation and Climate Change for the Providence Centre for Justice, Peace, and Integrity of Creation in Kingston, Ontario, I am writing to register our office's recommendation that the Application for a Site-Specific Air Pollution Standard at Lennox Generating Station be denied.

The applicant is not responding to the intention of stricter air quality standards, instituted by the province to protect air quality and health. Instead of proactively responding to these revised standards, the applicant is in effect asking for a licence to pollute. This is particularly concerning given the possibility the facility might be called upon more often to provide power in the period in question.

When a site asks for an exemption from provincial standards, there must be an expectation that they convincingly demonstrate why they cannot meet these standards and why they deserve this exemption. That has not been demonstrated by the applicant. Why is residual fuel oil still being relied upon by the applicant? What efforts are they making to phase out its use? These are salient questions, more salient when one considers that there is no maximum use of RFO provided for in this application.

The application also lacks sufficient effort and concern to understand and mitigate impacts on the climate, and the health of local residents. The lack of cumulative modelling of impacts, given several other facilities of concern in the area, is unacceptable. Sulphur dioxide, nitrogen oxides, and sulphuric acid are harmful to human health. This application can not be approved before a human health study that considers possible health impacts and methods of mitigation is completed.

Finally, the climate emergency requires all Ontarians, but particularly those who generate our energy, to know of and contribute to our climate goals, nationally, provincially, and regionally. That no assessment of the GHG impacts of this proposed change is included is irresponsible and we are long past the point where approving projects without this consideration can be considered reasonable.

To contact me to discuss these comments and concerns further, please email me at the address with which I registered at the ERO site. Thank you for your consideration.