The issue around the…

The issue around the outgassing from the Lennox Power Generating Station towers is a concern because a blanket request to have an exemption on the emission standards implies no standards (past or most recent one) whenever demand for electrical power is high and natural gas is limited. The looser emission standards reflects OPG intention to run more fuel oil (vs. natural gas). Does this request come with a plan to ameliorate the problem through capital investment in technological improvements. If no plan, this would be an environmental step backwards in clean energy and it would appear POPG expects to run the plant more when the nuclear plants undergo their retro-fits cycle which are decade long projects (https://www.opg.com/strengthening-the-economy/our-projects/darlington-r…).

Questions and Considerations that should be asked include the following:
1. Who makes the decision on the FuelOil/NaturalGas mixture fed into the plant? It's likely an economic feedstock cost decision but is the environmental impact being factored into the "cost?" Unlikely.
2. Will permitted emissions levels be on a sliding scale of the fuel ratio?... Or blanket no matter what fuel is utilized? This could open up the community to higher overall emission during normal plant operations.
3. Have capital projects to increase the effectiveness and capacity of the air pollution control system been investigated to meet the current/future air emission standards? If not, why not? When could these be carried out? These new standards have been a long time coming and should not be ignored even before they are brought into play.
4. The Public website for up to date notification is needed, but requires people to be proactively checking/ monitoring it. Plant management should also be required to inform local papers/radio stations if they are, have, or plan to exceed the current limits for a 'stated' period of time. An important consideration is during the critical spring season when young plants (crops) on farmer's fields are most vulnerable. Longer cumulative effects are still a concern, especially along the shoreline. A stated maximum period should be provided, after which additional approval must be sought.
5. What is OPG doing to ensure it will be able to meet current/future emission limits after this 5/10 year request expires, if granted (capital investments etc?). If the answer is to ask for another waiver then serious discussion should be sought about plant operations and viability vs. alternative greener energy options. Perhaps a plan and capital investments to improve tower emission monitoring and abatement interventions should be required before an exemption is approved or put in place prior to the anticipated need to use fuel oil.