Thank you for providing the…

Thank you for providing the opportunity to comment on the recently proposed regulatory amendments to Ontario Regulation 419/05: Air Pollution – Local Air Quality, specifically related to updated air standards for sulphur dioxide.

The Canadian ambient air quality standards for sulphur dioxide were recently adopted under the pan-Canadian process under the Canadian Council of Ministers of the Environment (CCME) coordination as part of the national Air Quality Management System (AQMS), which is fully endorsed by the Government of Ontario.

The Cement Association of Canada (CAC) is part of the national working group whose mandate is to provide recommendations to the CCME on Canadian Ambient Air Quality Standards. In October 2016, CCME Ministers announced new CAAQS for SO2, which reflected the recommendations of the working group. These new SO2 standards have been formally adopted by the Government of Canada.

We understand that the CAAQS is a baseline and that Ontario, like other Provinces, may choose to implement these national standards in a way that is most suitable to their specific circumstances. Our main concern is that Ontario is proposing a more stringent standard than the new Canadian Ambient Air Quality Standards (CAAQS) for sulphur dioxide throughout the Province. This situation raises questions with respect to the science supporting such a stringent approach as the national standard was developed using the most recent and up-to-date science as it relates to health effects.

We would propose that rather than adopting a province wide approach to the proposed standard, or considering a rudimentary north-south Ontario division, Ontario should set a more stringent standard only in localized areas to address local or regional sensitivity if needed. We understand that O.419 includes a clause that allows emitters to apply for a site- or sector-specific technical standard in order to address achievability issues. However, this approach triggers a laborious and time-consuming process, along with social acceptability issues, all of which could and should be avoided unless there are specific local human health or environmental concerns warranting more stringent standards.

Under the AQMS, all jurisdictions have agreed to manage air quality through an Air Zone Management Framework. This framework requires jurisdictions to divide their territory into a number of air zones. Air management actions should then be taken according to these air zones. By applying a blanket approach throughout the province, Ontario’s suggested approach seems misaligned with the intent of the air zone management framework that is a foundational element of the AQMS.

The cement industry has supported the province’s efforts to reduce local air emission impacts and has demonstrated significant sulphur dioxide reductions over the last decade. It is also important to note that Ontario emitters such as cement plants are also subject to Ontario regulations 0.194 and 0.397 which set SO2 emission intensities and includes an emission trading system for SO2. These regulations have resulted in significantly lower SO2 emission targets over time and we question the need for and the feasibility of further reductions. We would like to understand how will the proposed new requirements fit into these and whether it would bring any additional restrictions to the existing trading system?

With respect to Ontario’s Sulphur Content in Fuels regulations and associated proposals, would the province consider further supporting or facilitating the use of low-sulphur fuels to replace higher-sulphur/higher-carbon fuels for energy intensive industries? Such a framework could serve both the Province’s GHG and SO2 reduction efforts while encouraging local solutions for waste diversion, decreased transportation-related emissions, etc.

We respectfully request your consideration of our concerns and recommendation to create localized approach that establishes more stringent standards only where it is needed to protect human health and the environment. We would request an opportunity to meet with MOECC officials to better understand the Province’s intended approach with respect to the application of the new standards.

[Original Comment ID: 211522]