1) The Technical Industry…

1) The Technical Industry Standard for Steel Mills will be an optional path to compliance. Under the current regulation it will be possible for the company to simply opt for another Site Specific Standard after the June 2023 date. Thus I am opposing to not have the company go through a full application process for a Site Specific Standard now, rather than offering them an extension of the current one. The company should apply for a 5 year Site Specific Standard and during that time the company can evaluate if the Technical Standard suits them down the road.

2) The main spirit of the Site Specific Standard is working towards significant emission improvements to hopefully one day be in compliance with the Reg. 419 limits. Therefore it does not make much sense to extend the period for 2.5 years without implementing any significant emission improvements. This will a lost opportunity for improvements and an additional burden to be carried by all surrounding areas and citizens.

3) Access to supporting materials. This access has been very limited and for most part non existent. There are virtually no meaningful documents that the MECP has shared that warrant this extension without demanding further improvements.

4) The Site Specific Standard extension is not proposing an update to the action plans for Suspended Particulate Matter (SPM). I ask that a reduction update to the action plans for SPM be included in the extension. The MECP is not proposing any reduction for the extension (177 ug/m3). I suggest to reduce the target value to a value well below 177 ug/m3 to show a path of continuous improvement.

5) The Site Specific Standard for Suspended Particulate Matter for Harsco expires on the last day of December 2020. The last day of commenting for this Proposal is December 14, 2020. The closeness of these two dates concerns me greatly as Christmas/New Year holidays are between the end of commenting period and the start of 2021. The concern is that there seems to be very little or no time for the MECP to consider all the comments to this proposal from the public regarding changes or amendments to your proposal. This public consultation is this not done in a meaningful and honest way because it will have no impact on your decision.

6) Ministry orders associated with existing Site Specific Standard require Harsco to establish community liaison committees (CLCs) and to host quarterly public meetings with CLCs to update CLC members and the broader community on progress in reducing the emission levels of contaminants for which the plants have Site Specific Standards. It is not clear based on the posting and supporting documents if the MECP will continue to impose this. I want the same order re. Hosting CLC meetings quarterly continued and have a requirement for the company to post quarterly performance data.

7) The Site Specific Standard for Manganese does not expire until June 2021. I ask that the Ministry take more time to extend the SSS and consider making the limits lower for Manganese. The limits have stayed stagnant since 2016. Again I do not see the continuous improvement mantra applied here.