ArcelorMittal Dofasco has applied to the Ministry of Environment, Conservation and Parks (MECP) to renew conditions that allow it to emit noise and air contaminants above Ontario regulations. Read below for:

1. Important notes
2. How to submit a comment
3. Suggested material to include in your comment

LINK TO PUBLIC COMMENT PAGE

1. Important notes

• The MECP must consider your comments before making a final decision.
• The MECP must post a public response to concerns identified by residents who comment.
• Comment deadline: Thursday March 12, 11:59 pm.
• Do not include identifying information. For example:
  • Names
  • Addresses
  • Phone numbers

• We recommend drafting your comment using a word processing software or online word processing platform (like google docs) to make sure your work does not get erased!
• NOTE: your comment does not have to be long to be effective!

2. How to submit a comment

Step 1: Navigate to the public comment page LINKED HERE.

Step 2: Click "submit a comment."

Step 3: If you have submitted a comment before and created an account to do it, click "Log in." If you have not submitted a comment before you can click "Register for an account" or click "Comment without registering." If you want to submit files along with your comment you must register for an account, otherwise this is not necessary.

Step 4: Write your comment into the "comment" box.

Step 5: Add supporting links with a brief link description. Click "add another link" to add more than one supporting link.

Step 6: Select that you are commenting on your own behalf. Lastly, preview your comment and submit once you are satisfied with the preview!

3. Suggested comment outline

a. Intro

Dear Hon. Minister McCarthy and Ministry of Environment, Conservation, and Parks administration,

RE: Environmental Registry of Ontario #026-0039

I am writing as a resident of Hamilton, Ontario. This submission outlines my key concerns and recommendations regarding the proposed renewal of the Environmental Compliance Approval with Limited Operational Flexibility (LOF) for ArcelorMittal Dofasco (AMD).

b. Personalize it!

• How do you experience Dofasco emissions?
• What do you experience? When do you experience it? How frequently?
• Do you have trouble confirming the source?
• What would you like the Ministry to do about this?
  • E.g. real-time monitoring on site would help determine the source of pollution.

c. Important points to include (choose one or more)

1. Health concerns

• Researchers completed a large ambient air quality study for Hamilton in 2023.
• The study found that benzo[a]pyrene is higher than provincial guidelines in all urban areas of Hamilton and is concentrated closer to the industrial area.
• Researchers were quoted saying: "If you look at how much benzo(a)pyrene is in a cigarette... if you were to smoke it, that's about the same amount you'd be exposed to… by just breathing in the air in these urban neighbourhoods near the industrial sites," [1].
• What is the Ministry of Environment, Conservation, and Parks (MECP) doing to address these health impacts?

2. Lack of info about what is proposed in the Environmental Registry of Ontario (ERO) posting

The posting has a lack of info regarding:

• Upper limits on air pollution required for Limited Operational Flexibility (LOF) performance conditions now that site-specific standards have expired.
• Steps that AMD is taking to prevent discharges of air contaminants beyond the schedule 2 and 3 standards specified in section 19 and 20 of O. Reg. 419/05.
• Expiry date (how long does the approval last?).
• Reporting requirements
  • Some AMD facilities that would shut down during the coal phase-out project are exempt from more stringent sulphur dioxide emission regulations [2], but the Company is not committing to a clear project timeline.
  • To avoid indefinite violations of the sulphur dioxide regulation, the Company must provide quarterly updates on its coal-phase out project to the Director and make them publicly available.
• Monitoring requirements.
  • The MECP requires some petroleum facilities in Sarnia to share near-real time monitoring data with the public on a publicly accessible website, including monitoring data from the fence line, open path monitoring systems and existing near real-time monitors [3].
  • AMD should have to implement near-real time monitoring as part of this LOF renewal.

3. Clarity About the Abatement Plan

• After Site-Specific standards expired in 2023, the Ministry required AMD to submit an abatement plan. How is the Ministry enforcing the abatement plan?

4. Clarity on updated Sulphur Dioxide regulations

• New Sulphur Dioxide (SO2) regulations came into effect in July 2023.
• AMD now exceeds the MECP criteria for SO2.
• Local reporting indicates that AMD facilities expected to shut down due to the coal phase-out project are exempt from the more stringent SO2 regulations, but now the coal-phase out project is delayed.
• When will the MECP require AMD to comply with the updated SO2 regulations?
• Will the MECP require frequent coal phase-out project updates to ensure compliance with SO2 regulations?

5. Equipment included in the LOF

• Now that AMD has committed to phase-out coal, maintenance of key existing facilities like coke plants and blast furnaces should be subject to public notice and comment periods via the Environmental Registry of Ontario to avoid sunk costs.
• Under the previous ECA [4] this equipment is exempt from public notice and comments for maintenance even though maintenance and refurbishment projects can cost hundreds of millions of dollars.

6. Cumulative Effects

• Residents in Hamilton are subjected to cumulative air pollution impacts due to emissions from numerous industrial facilities.
• The Ontario government committed to review the Cumulative Effects Assessment in Air Pollution policy within two years of its release in 2018, but it has not done so [5].

7. Concerns about alignment with MECP Statement of Environmental Values

• Read the Statement of Environmental Values linked here [6] and outline aspects of the statement that conflict with approving this renewal application.

Supporting Links

1. URL
https://www.cbc.ca/news/canada/hamilton/air-quality-hamilton-1.6904964
1. Description
Breathing the air in parts of Hamilton is like smoking a cigarette a day, researcher says

2. URL
https://www.thespec.com/business/province-wont-investigate-arcelormittal-dofasco/article_2d802b73-b149-50da-9c95-e020b062f4ea.html
2. Description
Reporting on sulphur dioxide regulation exemption due to coal phase-out project. “Province rejects residents request for Dofasco investigation,” The Hamilton Spectator

3. URL
https://ero.ontario.ca/notice/019-8755
3. Description
ERO Posting including near-real time reporting requirements, "Reducing Benzene Emissions from INEOS Styrolution Canada Ltd.," June 3, 2024

4. URL
https://ero.ontario.ca/notice/019-3895
4. Description
Arcelormittal Dofasco G.P.- Environmental Compliance Approval (air), September 17, 2021, ECA renewal

5. URL
https://cela.ca/application-for-review-of-cumulative-effects-assessment-in-air-approvals-under-the-environmental-bill-of-rights/
5. Description
Application for Review of Cumulative Effects Assessment in Air Approvals under the Environmental Bill of Rights

6. URL
https://ero.ontario.ca/page/sevs/statement-environmental-values-ministry-environment-and-climate-change
6. Description
Statement of Environmental Values: Ministry of the Environment and Climate Change