Feb 7, 2018…

Feb 7, 2018
Lubna Hussain
Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West
Floor 7
Toronto Ontario
M4V 1M2
Dear Lubna Hussain,
Thank you for the opportunity to review the Ministry of the Environment and Climate Change’s proposal, Cumulative Effects Assessment (CEA) in Air Approvals.
From our understanding, the ministry currently addresses local air quality through regulation of a single industrial facility located within a community in isolation. This proposal aims to consider several industrial facilities and roadways (both within a community) together when specific conditions are met. Namely, the proposal is restricted to new or expanding industrial facilities located in two communities (Hamilton and Sarnia), where the contribution of two pollutants (benzene and benzo[a]pyrene) from several industrial facilities and roadways exceeds a certain level of risk. When all these conditions are met, new or expanding facilities may be required to include a technology benchmarking report and/or include specific pollution control measures as part of an application for an Environmental Compliance Approval.
1.Defining Cumulative Effects Combining the effects of multiple sources of the same pollutant in managing air pollution is a positive step and should improve protection of public health when compare with an approach the treats each source in isolation. However, we suggest that the cumulative effect be defined as the effect of multiple sources on the overall ambient concentration of a particular air pollutant. We believe that attempting to combine the effects of more than one pollutant on a particular health endpoint is problematic, as it may result in confusion and perversely may create the impression that health is being well protected while some of the greatest contributors to health risks may not be effectively addressed.

2.Use of the term “cumulative effects assessment” in regards to this proposal can be misleading. In reviewing the practice of cumulative effects assessment in Canada, Baxter et al. (2001) found that scoping was inadequate. This finding may apply to the MOECC’s proposal which intends to assess the cumulative effects of two sources (i.e., industrial and transportation located within the community) and two pollutants (benzene and benzo[a]pyrene). Local air quality is affected by many sources located inside and outside of the community. The proposal does not consider important sources of air pollution by focusing on industrial and transportation sources located within the communities. Moreover, a cumulative effects assessment might be expected to consider the impact of all air pollutants contributing to cancer risk, not just two pollutants that are listed in the AAQC and whose ambient levels are exceeded. In CCO and PHO’s Environmental Burden of Cancer in Ontario report, we found that the cancer risk for all provincial residents from exposure to fine particulate matter far exceeded the risks from benzene or polycyclic aromatic hydrocarbons (of which benzo[a]pyrene was the most notable). Using the term “cumulative effects assessment” to describe the summed cancer risk from two pollutants in Hamilton is likely underestimate the true cumulative cancer risks from exposure to all air pollutant carcinogens.
3.Many sources inside and outside of the community affect air quality within the community, though the proposal only considers industrial and roadway sources within the community. Emissions originating from industry, transportation, power generation, wildfires and more contribute to the air quality experienced by a community. The emission sources may be located within the community or 10’s or 100’s of kilometres away from the community. For example, emissions from a car may contribute directly to ambient fine particulate matter levels (i.e., primary particulate matter) and emissions from a point source 100’s of kilometres away may also contribute to ambient fine particulate matter levels (e.g., secondary particulate matter). In an analysis of the health impacts of air pollution in Toronto, only half of the burden of illness was attributed to local sources. Of the local sources, traffic and industrial sources were estimated to contribute to 21% and 9%, respectively, of the burden of illness for premature deaths (TPH, 2014). Therefore, in order to improve local air quality, it is essential to look at sources beyond the community. The proposal should be lauded for attempting to consider more than one industrial facility at a time (i.e., by looking at multiple industrial facilities and transportation sources), but may be more effective in protecting public health by managing all emissions sources based on an airshed basis. The Air Zone Management Framework, which is noted in section 6(c) of the Discussion Paper, would be better suited to account for multiple sources and multiple pollutants than the present proposal.
4.Fine particulate matter has been found to be the most significant contributor to public health impacts from air pollution, though it is not considered in the proposal. The International Agency for Research on Cancer has classified airborne particulate matter and ambient air pollution as an established human carcinogen (Group 1) (IARC, 2013). The importance of exposure to fine particulate matter on the global scale cannot be overstated. In a comparative risk assessment of the health burden of nearly 80 health risks, ambient particulate matter placed 6th, behind high blood pressure, smoking, high glucose, high BMI, and childhood undernutrition (Forouzanfar et al. 2016). The MOECC’s proposal is restricted to contaminants that have an established AAQC. In doing so, it excludes what is arguably the greatest contributor to human cancer risk, fine particulate matter. Use of CEAs that don’t include PM2.5 will considerably underestimate overall cancer risk and may be quite misleading to the public. While improvements levels of all air pollutants are desirable, unless the key drivers of overall risk are brought down (e.g. PM 2.5) there will not be a reduction in net overall risk to health.
5.Precedent for application to other health effects.
There are other health end points that may result from exposure to a multiple air pollutants. Examples of this include irritant effects on mucous membranes and the respiratory tract. In practice, it is not possible to come up with meaningful overall assessments of the combined effects of multiple pollutants in producing these effects. Given the strong links between PM2.5 and these outcomes any cumulative effects framework that does not include PM2.5 would underestimate health effects. From a policy and communication perspective, trying to integrate health effects other than cancer into a ‘cumulative effects’ framework based on health outcomes would create additional problems.

[Original Comment ID: 212393]