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Dear Madam/Sir,

Please accept this submission as Environment Hamilton’s comments on the posting ‘Regulatory amendments related to air emissions of sulphur dioxide and other items’. We have commented on both the proposed new sulphur dioxide standard and the proposed changes to the ‘transitional operating conditions’ requirements in Regulation 419/05.

Proposed New Sulphur Dioxide Standard
We welcome the proposed new air standard for Sulphur dioxide – and believe it is long overdue. We look forward to seeing a standard enforced that will provide strong protection for human health and the environment.

Recognizing this, we were extremely dismayed to read in the registry posting that the Ministry of Environment & Climate Change is asking Ontarians to consider the following:

In addition to a phase-in period for the updated SO2 standards, the ministry is considering whether to apply the standards on a regional basis. Specifically, the ministry is seeking input on whether to apply the updated standards to Southern Ontario and have the current standards apply to Northern Ontario or part thereof.

We are strongly opposed to such a proposal. When new air standards are developed and designed to be protective of human health and the environment, these protections must be applied across the province. We do not support even entertaining the possibility of a ‘two-tiered’ system of air standards in Ontario, with one jurisdiction – in this case northern Ontario – less protected than another one.

We also find it interesting that the proposal to consider sticking with the sadly outdated 1974 sulphur dioxide standard is for the north where Ontario’s largest point sources of sulphur dioxide emissions to air are located – namely Vale and Glencore. It is our sense that the MOECC’s decision to consider this option was driven purely by politics – and not based on sound science – taking the effort away from what Regulation 419 sets out to achieve. We believe it is shameful that this idea is even being put out there for public consideration!

Proposed Changes for Transitional Operating Conditions
We are pleased that improvements are being proposed to clarify requirements for assessing and addressing air emissions generated during transitional operating conditions. In Hamilton, we do have concerns about some local industrial sources that generate emissions during TOCs but it is not completely clear to us yet how these proposed regulatory changes might play out in a Hamilton context – especially for any contaminants that do not have acute impacts.

Thank you,
Lynda Lukasik, PhD
Executive Director
Environment Hamilton

[Original Comment ID: 211536]