Comments on Algoma Steel's…

Comments on Algoma Steel's Environmental Compliance Approval (Air)

Public Comment
We are very pleased with the opportunity to comment on Algoma Steel’s proposal. Algoma Steel is the city’s largest employer. As such, many staff and Board members have direct family members working with the steel plant. Many are concerned about the potential for negative impacts they fear will result in commenting. The legal clinic is a unionized workplace and the union representing its workers is the Steel Workers Union. However, we believe Algoma Steel and the Ministry will hear the concerns and respond appropriately.

Algoma Legal Clinic and CELA
The Algoma Legal Clinic is committed to providing essential legal services to individuals facing economic and social challenges. The Algoma Community Legal Clinic provides free legal advice and representation to those who qualify financially. In essence, we provide legal service to the most vulnerable sector of our community. With a dedicated team of professionals, we offer comprehensive support tailored to each client's unique needs.
The Canadian Environmental Law Association (CELA) is a sister legal aid clinic. The Canadian Environmental Law Association (CELA) is a non-profit, public interest organization established in 1970. Its mandate is to use existing laws to protect the environment and advocate for environmental law reforms. CELA provides free legal advisory services and represents citizens or groups in environmental legal matters, particularly those who cannot afford legal assistance.
With the support of CELA the Algoma Legal Clinic makes the below listed comments.

Sault Ste. Marie and Area
Sault Ste. Marie is renowned for its stunning natural environment, which plays a crucial role in the lifestyle and recreation of its residents. The city is situated on the St. Mary's River and surrounded by lush forests, lakes, and trails that offer abundant opportunities for outdoor activities. Residents heavily rely on the outdoors for sports and recreation, with activities such as hiking, fishing, and skiing being popular. The development of the John Rowswell Hub Trail has further enhanced access to outdoor recreation. This multi-use trail encircles the city, providing a scenic route for walking, cycling, and jogging, thus encouraging more residents to engage with the natural environment. The community's connection to nature not only supports physical health but also fosters a strong sense of community and well-being among its residents.

Staff and most Board members of the Clinic work, play, raise families, buy homes, and fully live life in Sault Ste. Marie. Our concern about the environment is not merely an academic concern. We are deeply worried about environmental impacts for children, our future generations and ourselves.
As legal aid clinics, our client communities are lower-income communities, including those living close to the Algoma Steel plant in the Bayview and Steelton neighbours and most impacted by the local air pollution. Environmental justice requires that decisions about significant environmental proposals prioritize the consideration of the impacts on communities already disproportionately impacted by pollution, including from historical emissions from this facility. It is critical that air emissions, particularly during the current and transition periods, are considered from the perspective of protecting the health of neighbours of this facility.
Significance of the Project
The transition to electric arc furnaces (EAF) by Algoma Steel is a significant development for Sault Ste. Marie, promising a substantial reduction in carbon emissions and local air pollution. The project is expected to decrease Algoma’s carbon footprint by approximately 70%, marking it as one of Canada's most impactful investments in greenhouse gas reduction. This transition aligns with global trends towards sustainable steel production and positions Algoma as a leader in "green steel" manufacturing. While we are very pleased with the prospect of lower emissions we raise a number of significant concerns.

Lack of Meaningful Public Engagement
The Registry posting lacks detail and supporting documents, which Algoma Steel has marked as confidential. Engagement with local stakeholders is essential for addressing concerns about potential downsides of the project and accountability and transparency during the transition period. Continuous updates and transparent communication about progress, challenges, and environmental impacts will be crucial. By failing to produce supporting document, the steel plant is creating a shroud of secrecy around the project. This secrecy undermines the public's ability to provide informed feedback on the proposal. Moreover, it reduces the community’s trust and lowers the credibility the plant enjoys in Sault Ste. Marie.

Environmental Impact – Air Pollution
Algoma Steel has applied for four site-specific standards for air pollutants, but the Ministry has not yet posted these applications for public comment on the Environmental Registry. It is instead relying on an Air Pollution Abatement Plan, which has not been disclosed. It is not clear what, if any, air pollution standard applies to Algoma Steel. Algoma Steel has requested the site specific standard for Benzene be 884% of the provincial standard. The impact to human health and environmental sustainably has not been analyzed. The requested standards for sulfur dioxide and other pollutants like benzo(a)pyrene, sulphur dioxide and total suspended particulate matter also far exceed provincial limits, posing ongoing risks to local air quality.

Construction and Transition Emissions

While the long-term benefits of the project are promising, there are concerns about the emissions generated during the construction phase and the interim period before full EAF operations commence. The construction of new infrastructure, including fume treatment plants, aims to mitigate these emissions by capturing and recycling dust and air pollutants.
Noise Pollution
Algoma has incorporated noise-reduction measures in the design of the new facilities. However, limited information is provided. The Acoustic Assessment Report and the proposed Noise Abatement Action Plan remains undisclosed, leaving residents in the dark about mitigation measures.
Health and Safety Concerns
The health and safety of residents and workers remain paramount. Algoma is implementing an ISO 45001 Safety Management System and participating in health and safety programs to ensure rigorous standards are met. However, transparency regarding safety incidents, such as recent accidents during construction, should be prioritized to maintain public trust. There is an understanding that accidents occur with heavy industry. However, there is also a growing concern that accidents are dealt with behind closed doors. As such, we are very concerned about public and employee safety.
Accountability and Transparency
There is concern about whether Algoma will meet its projected timelines, given delays observed in similar projects elsewhere, such as Hamilton. Ensuring adherence to schedules is vital for maintaining community confidence. Community Involvement:
Engagement with local stakeholders is essential for addressing concerns about potential downsides of the project. Continuous updates and transparent communication about progress, challenges, and environmental impacts will be crucial. We are recommending strong, regular and fulsome updated on the project.
Alternative Measures
While transitioning to EAF technology is a significant step forward, exploring additional measures to further reduce pollution should be considered. This includes evaluating other technologies or practices that could complement the current plan.

In summary, while the transition to electric arc furnaces at Algoma Steel presents a promising reduction in environmental impact, ongoing accountability, transparency, and community engagement are critical to addressing potential challenges during this transformative project. We love Sault Ste Marie and we love living in this rich, ruggedly beautiful centre point of Canada. We want to ensure the health of our residents and future generations and we want to ensure the forests, sky and waterway stay beautiful clean and healthy into the future.

Thank you for considering our position.
Algoma Community Legal Clinic