I would like to express my…

I would like to express my support for the Proposal for Cumulative Effects Assessment (CEA) in Air Approvals , while also stating my concern that this is the bare minimum of what is needed to protect the citizens of Hamilton. The proposal is a very modest starting point for further action which is urgently needed.

-The cumulative effects of numerous polluters on Hamilton's air quality is a daily concern for many of us. Contaminants such as benzene and benzo(a)pyrene are amongst the worst, but they aren't the only ones which the MOECC should address in a policy like this. We need explicit deadlines for adding other contaminants to the assessment.

-This proposal only impacts new and expanding facilities. What will be done about the existing multiple sources of benzene and benzo(a)pyrene? And for new facilities, what actions will be taken when their operations degrade Hamilton's ambient air quality over the 100x threshold?

-What consideration has been given to the use of the current air dispersion models when assessing air quality in a community like Hamilton which is so gravely impacted? I am concerned that too much is left to guesswork. Isn't there a more effective tool that takes into account some of our unique geographical features?

-What will happen with this policy as technology advances? Is there a provision to react in a timely fashion as the science of pollution and our understanding of its impacts change? If it took nearly ten years to draft this proposal, what steps are in place to more rapidly respond to environmental changes as they occur?

-The wording of this proposal suggests that it is merely a set of loose guidelines and not a clear set of actions. It feels as if this proposal is the result of far too many concessions made on behalf of and at the expense of citizens who count on the Ministry to look out for their interests.

I hope the Ministry will bolster this proposal with stronger language and clearer determinants to improve our air quality not only in Hamilton and Sarnia, but all other Ontario communities which could be impacted.

[Original Comment ID: 212371]