February 7, 2018…

February 7, 2018

Attention: Lubna Hussain - Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch

RE: POLICY PROPOSAL - Cumulative Effects Assessment in Air Approvals (EBR Registry No 013-1680)

Dear Ms. Hussain,

Please accept this submission as Environment Hamilton’s formal comments on the MOECC’s proposed ‘Cumulative Effects Assessment in Air Approvals’ policy. First, Environment Hamilton appreciates all of the effort MOECC has put into exploring how best to address cumulative effects of air pollution emissions in Ontario. Addressing cumulative effects is not a straightforward undertaking and many other jurisdictions continue to struggle with this – if they are addressing these impacts at all.

However, given the challenges facing communities like Hamilton and Sarnia, we believe more must be done to address cumulative effects of emissions to air – especially in communities with compromised airsheds. To this end, we have reviewed the detailed list of 13 recommendations put forward to you by EcoJustice and we strongly support all of the recommendations they have put forward in their submission.

We are particularly concerned that the policy, in its current form, applies only to new or expanding facilities. In Hamilton, this means that an assessment of cumulative impacts will not be applied to existing sources of benzene and benzo(a)pyrene which, in the case of benzo(a)pyrene, have resulted in exceedances of ambient air quality criteria. We want to see air quality in Hamilton improve over time through this policy. Otherwise, we wonder whether there is any point to the effort. We are, therefore, also strongly supportive of a CEA policy that involves just saying no to new facilities in airsheds that are already heavily compromised. The current policy does not entertain the possibility of saying no to new sources of the contaminants in question and we cannot support such an approach.

Thank you,
Lynda Lukasik
Executive Director
Environment Hamilton

cc EH Board of Directors

[Original Comment ID: 212399]