• The Region recognizes the…

• The Region recognizes the potential benefits from the usage of ACLF within the facility, including the offset of other fuel usage. However, given the nature of the facility, including proximity to residential areas, understanding potential impacts of the facility are important in ensuring the health of the community and the environment.
• The Air Quality Study and Cumulative Effects Assessment in support of the application identifies maximum concentrations for five communities in table 6-1. The Region notes that the Air Quality Criteria identified in table 2-1 for sulphur dioxide are not reflective of the changes announced in March 2018 to the AAQC’s or O.Reg 419/05 values. The Region is of the understanding that the AAQC’s for sulphur dioxide (SO2) were scheduled to come into effect in Spring 2020, and that the O.Reg 419/05 values are currently in a phase in period until July 1, 2023. These updated limits will reduce the 1-hr values from 690 µg/m3 to 100 µg/m3, based on respiratory morbidity in exposed sensitive populations.
• Information presented at the first Public Meeting identifies that the ambient monitoring stations surrounding the facility record PM10 (BAM and Hi-Vol), Dust, and contain seismographs. Given the list of emissions from the facility identified above, including the levels of SO2 being emitted, consideration should be given to upgrading or adding additional monitoring stations with an expanded list of parameters, and requirements be included for reporting the results of the monitoring to the MECP and the public.
• It is important that the potential impacts on local air quality are well understood during project development and remain monitored against MECP standards and objectives throughout the project lifecycle. Given the similarities in emissions between the St. Marys projects and the DYEC, it is important that comparable monitoring and information reports be provided to stakeholders, so that they can remain informed with regards to how projects could potentially impact their communities. To this end, the Region would like to see the St. Marys project be required to have comparable in-stack limits, ambient air monitoring requirements and report to the public as those directed in the DYEC ECA.