Ministry of Transportation -…

Ministry of Transportation - Environmental Policy Office
777 Bay Street
Suite 700
Toronto, ON
M7A 2J8

Attention: Katerina Downard

RE: ERO POSTING 019-0131 Update to the Environmental Guide for Assessing and Mitigating the Air Quality Impacts and Greenhouse Gas Emissions of Provincial Transportation Projects
Clean Air Hamilton is a voluntary committee established in 1998 to advise on air quality, climate change and related issues in the City of Hamilton. We also provide an authoritative voice and resource on local air quality issues. We are an innovative, multi-stakeholder agent of change and are committed to improving the health and quality of life of citizens through communication and promoting realistic, science-based decision-making and sustainable practices.
One of the goals of Clean Air Hamilton is to improve air quality throughout the City of Hamilton and to meet all ambient air quality criteria. Transportation is one of the largest sources of air pollutants in Hamilton resulting in negative health effects, such as respiratory and cardiovascular related illnesses, heart disease and a variety of cancers. Vulnerable populations including low income families are the most affected by the impacts of poor air quality. Scientific literature has shown that the life expectancy and level of health of residents in areas with lower air quality tend to be lesser than those in areas with higher air quality. This only emphasizes the importance of clean air within Hamilton and throughout Ontario.
Clean Air Hamilton would like to submit the following questions/comments for review:
1. Updated provincial and federal air quality standards
Clean Air Hamilton supports updating Provincial and Federal Air Quality Standards. Standards must be based upon data related to human health risk.
2. Updated emissions estimation software
Clean Air Hamilton supports using most up to date and accurate estimation software.
3. Benzo(a)pyrene included as an air toxic
Clean Air Hamilton supports including Benzo(a)pyrene as an air toxic.
4. Removal of “credible worst-case scenario” from Task 3
The previous inclusion of a “worst-case air quality impact assessment” recognized critical and sensitive receptors. By eliminating these criteria, the change shows a lack of consideration of critical and sensitive receptors, which has the potential to put these communities at risk. It is recommended that these groups continue to be taken into consideration in a “worst-case air quality impact assessment” or that these are included in other modeling that is included when evaluating and implementing projects.
5. Removal of equation for comparing alternatives
Clean Air Hamilton recommends that Alternatives be compared using risk factors impacting human health as the main priority.
6. Ministry of the Environment, Conservation and Parks (MECP) consultation is recommended when developing meteorological data and determining the need to mitigate
Clean Air Hamilton supports consultation being completed through this process.
In addition to the changes that have been made to this policy, Clean Air Hamilton would like to note that page 20 of the Ministry of Transportation Environmental Guide for Assessing and Mitigating the Air Quality Impacts and Greenhouse Gas Emissions of Provincial Transportation Projects, states that:
“During planning, the project team may have the opportunity to keep the distance of the highway or other major transportation facilities from sensitive receptors (e.g., residences) and critical receptors (e.g., hospitals, retirement homes, childcare centres, and similar institutional buildings) at approximately 100 metres or greater. This would help, in most cases, to avoid the need for air quality impact mitigation.”
Clean Air Hamilton recommend that the distance of 100 metres be increased to 250 metres. The recently released Near-Road Air Pollution Pilot Study released by The Southern Ontario Centre for Atmospheric Aerosol Research at the University of Toronto1 shows that elevated levels of traffic related air pollution can be found within 250m of main roadways. It is recommended that this distance be updated to current research.
It is also recommended that the Canadian Ambient Air Quality Standards be met through most applicable modeling approach and be followed with applicable monitoring.
Clean Air Hamilton is committed to working collaboratively with all levels of government, industry, local businesses, community groups and citizens to help reduce transportation emissions and improve air quality and the health of citizens of Hamilton and in the Province of Ontario. Please do not hesitate to contact Shelley Rogers, Clean Air Hamilton Coordinator, cleanair@hamilton.ca about the above information provided. Thank you very much for your time.
Sincerely,

Dr. Bruce Newbold,
Chair, Clean Air Hamilton
Director, Geography and Earth Science
McMaster University

1Near-Road Air Pollution Pilot Study, Summary Report Fall 2019, SOCAAR at the University of Toronto: https://www.socaar.utoronto.ca/wp-content/uploads/2019/10/SOCAAR-Near-R…