I noticed that the Suspended…

I noticed that the Suspended Particulate Matter (SPM) for Harsco expires on the 31 of December 2020. The last day of commenting for this Proposal is today, December 14, 2020. This does not seem to provide much time for you to consider all the public comments to this proposal regarding changes or amendments to your proposal.

I noticed the Ministry 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 is included in the extension. Harsco’s limits for SPM have been at the same level for 5 years. How is this showing any real commitment to reducing these pollutants? We need to see constant improvements and we need the Ministry to prescribe that in writing to the industry. It’s time to reduce the limit from 177 ug/m3 to something closer to the Reg. 419 limit of 120 ug/m3. When they control SPM then Manganese will be automatically reduced.

Another issue I have with SPM is that it’s combined. I would like to see a breakdown of PM10 and PM2.5 in limits. Enough data exists regarding the two sizes of the particulate & it’s health effects and combining them is outdated. Three of the HAMN monitor stations collect data regarding PM2.5 and 7 of them collect data on PM10 not mentioning monitors on the industry site that you have access to. http://newreporting.hamnair.ca

The SSS for Manganese does not expire until June 2021. I ask that the Ministry takes more time than Dec 31, 2020 to extend the SSS and consider making the limits LOWER for Manganese. We want the industry to have constant goals for improvements because we have no choice regarding the air we breathe here in Hamilton.

In addition to the above, I would like confirmation from the Ministry that the community liaison committees (CLC) continue during the extension of the SSS. We, as a community need regular updates to see the progress of the industry to meet the limits and that they communicate the quarterly reports to the CLC. This is really important because these are harmful chemicals and we should have a right to know what is happening. The proposal does not state whether the companies would be required to continue with CLC. Please make sure they do.