I am writing my feedback and…

I am writing my feedback and concerns from a Hamilton perspective, simply because I live in Hamilton and have more background information available. But I would want to see my comments applied for both Hamilton and Sarnia areas.

1) It is a concern for me that the policy only applies to new or expanding facilities. In my opinion Site Specific Standards and technical standards approaches do not address cumulative effects. Thus even with the proposed policy the air quality is not necessarily improving, at least not as a direct effect of this policy.
This policy therefore should have a legally binding phase in period to include existing facilities within a proposed timeframe of 5 years.

2) The focus on benzene and benzo(a)pyrene alone is not nearly enough to effectively improve air pollution. I propose legally binding timelines for adding other substances to the list. This is critically important for communities like Hamilton.

3) There should be prohibitions on approvals of new facilities when the levels of a pollutant in a community are > 100x the ambient air quality criterion (AAQC) – in other words – need to consider not allowing new facilities in hotspot airsheds like Hamilton

4) Ensure the policy is based on a range of information sources, including all monitoring data, emissions information, and community concerns.

5) Improve and expand air monitoring network in areas around elevated AAQC values (calculated or measured). The MOECC should NOT rely only on measurement stations it does not directly control. Furthermore the MOECC should not ONLY rely on air models that have been prepared by proponents seeking a Site Specific Standard approved. In other words the MOECC needs to be funded to independently create air models for the purpose of comparing them with the applicants’ models.

6) The MOECC needs to establish a legally binding and transparent approach for expanding the policy for cumulative effects to all Ontario communities, with priority being placed upon other communities with significant levels of industrial or other air pollution.

7) Management Actions for “Action Level 2” should have a wording change from “- may be required to include best available pollution control methods to “- must” include best available pollution control methods.

8) Management Actions for “Action Level 3” should have a wording change from - include pollution control methods to achieve the lowest possible emission rates as compared to an existing pollution source of the same kind in “North America” to - include pollution control methods to achieve the lowest possible emission rates as compared to an existing pollution source of the same kind “globally”.

[Original Comment ID: 212391]