Comment 1: In regards…

ERO number

019-2785

Comment ID

57497

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Comment 1: In regards Appendix B.2 - Dust and other Air Emissions, p.69 - Recommendations for facilities with potentially hazardous fugitive dust emissions - this section incorrectly focuses on just metal species of fugitive dust, whereas the ESDM Procedure document section 7.4 makes it clear that _any_ hazardous component of fugitive dust must be accounted for. The section should include an expanded focus on all species of fugitive dust (e.g., crystalline silica) to determine which are hazardous.

Comment 2: In regards Appendix B.2 - Dust and other Air Emissions, p.71 - Recommendations for situations where cumulative impacts should be considered - this should be expanded to include any and all compatibility plans, not just in the 3 Ontario Regions 3's (and for the two contaminants ID'd), as cumulative concentration are a reality across Ontario and need to be assessed to truly test for adverse effects. Without assessing cumulative air quality levels in all cases adverse effects cannot be assessed.

Comment 3: section B.4 - Sources of Information - just considers current land uses (ECAs/EASRs, liaising with current users) and does not consider other planned, as-of-right, uses that area allowed but that do not exist at present. There may be a need for proponents to deposit an escrow account to allow for future as-of-right developments to be assessed accurately.

Comment 4: p.77 - at first mention please provide a URL link to OMAFRA's MDS Guidelines in the document.