Thank you for the…

Thank you for the opportunity to comment on the proposed new regulation aimed at reducing sulphur dioxide emissions (SO2) associated with flaring events at Ontario petroleum facilities. We support the proposal for additional efforts to reduce SO2 from petroleum facilities. We view these efforts as being complementary to the measures implemented with the 2018 amendments to the Local Air Quality Regulation (Ontario Regulation 419/05).

We are confident that the suite of amendments to the SO2 emissions reductions regulations proposed and implemented over the last two years are based on recent and extensive review of the epidemiological and toxicological evidence. This evidence relates to the health effects associated with short and longterm exposure in both the general population and sensitive subpopulations. In addition, these amendments are consistent with and support efforts aimed at reducing the health impacts of other air pollutants (i.e. the secondary formation of particulate matter associated with ambient SO2). As we understand, this proposal sets out important requirements for petroleum facilities in Ontario, specifically that facilities should:

• Calculate sulphur dioxide emissions from flaring incidents and within two to
• four years, install continuous in-stack monitoring equipment
• Report sulphur dioxide flaring incidents
• Submit reports to the ministry that analyze the root cause of flaring incidents
• and sets out corrective and preventive actions to be taken
• Submit plans to the ministry for reducing emissions of sulphur dioxide and
• flaring incidents at the facility within one year
• Engage the local community about sulphur dioxide emissions and plans to
• address the emissions

We understand that some petroleum facilities will not be able to meet the new SO2 air standard and that they will need to develop either a site-specific or a technical standard based on the use of technology and/or best management practices. This proposed regulation is a reasonable first step towards a site-specific or technical standard that focusses on preventing and reducing SO2 emissions from flaring events that can result in short-term elevations in SO2 emissions.

We also appreciate the need for flexibility to tailor the requirements and account for facility-specific circumstances. However, these tailoring efforts should not foster health inequities that would result in increased exposure to SO2 in some communities over others. The MECP needs to ensure that the flexibility is not used to justify indefinite delay in implementing these emissions reduction requirements.

We therefore support the overall intent of these new requirements and believe that
they could improve monitoring, reporting, emissions reductions planning and
community engagement. However, the information provided to date is insufficient to
assess if the requirements adequately protects communities.

Recommendations:

It is recommended that:
• After each flaring event, the report on root cause analysis, SO2 emissions,
• corrective actions and preventive actions be shared with the local medical
• officer of health and the community.
• The local medical officer of health and the community receive an annual
• report of SO2 emissions, generally, with those related to flaring events
• noted.
• Facilities that do not have established mechanisms for engaging the local
• community should be required to develop a mechanism appropriate to the
• local context, in consultation with the local community representatives, the
• local medical officer of health and other petroleum facilities that have
• successfully engaged their local community.
• The MECP require calculations of SO2 flaring emissions within a year and
• in-stack monitoring within two years. The current proposal to allow up to four
• years for the implementation of in-stack SO2 monitoring is too long and
• could disproportionately expose communities near petroleum facilities.

Thank you for the opportunity to comment.

We have also sent a hard copy of these comments my mail.