I’m happy to see that the…

I’m happy to see that the MECP if finally moving ahead with providing clearer guidance for land use assessments. I’m also happy to see that you are proposing expanded Areas of Influence and Minimum Separation Distances for larger operations. I think this is a great idea. Although quarries are still only at a 1 km AOI, but they do have an expanded MSD.

It’s also good to see that clearer guidance and more detailed work are being required when a facility has receptors within their AOI or MSD. This will hopefully lead developers and municipalities to think more carefully about where facilities and residences are placed, especially with respect to one another.

I was disappointed, however, that there was very little discussion of cumulative impacts. What is the MECP's rationale for not considering stronger wording for the requirement of cumulative impacts and under what circumstances cumulative impacts may be critical in determining adverse effects? While facility emissions may be covered by ECA/EASR assessments, these emissions combined with roadways could lead to elevated levels of TRAP, as currently seen in the GTA. Planning decisions within other urban areas with significant industry and major roadways could benefit greatly from cumulative assessments. However, based on this proposed guidance, I would suspect that these assessments will not likely be conducted on a regular basis.