All public comments received during the proposal posting period were reviewed and considered in this decision.
In response to our public consultation on the proposal, the Ministry received a total of 31 submissions; of these only 22 were unique as some duplicate submissions were received through different channels.
Breakdown of responses by mode of submission:
(a) online via EBR: 13 (one included a request for a meeting);
(b) e-mail to ministry contact: 13;
(c) letter: 5.
Ministry staff also received informal feedback on the proposal at two stakeholder meetings: Clean Air Hamilton on July 13, 2015, and the Aamjiwnaang First Nation Environmental Committee on July 21, 2015.
A summary of key issues frequently raised as well as the ministry’s response is provided below.
Comment: Unable to meaningfully review and comment on the delineation proposal without additional supporting rationale for the proposed zones as well as details on how air zones will be used to drive Ontario’s proposed approach to air zone management (AZM).
Response: The approach to managing air zones in Ontario is currently being developed. The approach will include and build on all laws, regulations and policies currently in place, involve partnerships with local governments, stakeholders and communities. The Ministry plans to engage key stakeholders and the public on the approach to managing air zones at a later date.
Comment: Ontario’s approach to air zone delineation is inconsistent with the intent and guidance provided by the Canadian Council of Ministers of the Environment (CCME), in particular, for Air Zone 3 with a focus on industrial sources and emissions. Delineation of the Sarnia area and Hamilton as Zone 3 unnecessarily targets industry, and is inconsistent with the all sources approach of AQMS. Air quality data suggests that Sarnia/St. Clair and Hamilton should be classified with the rest of Southern Ontario as Zone 2.
Response: CCME’s Guidance Document on Air Zone Management defines an air zone as “a finite geographic area, within a particular province or territory that typically exhibits similar air quality issues and trends throughout”. The guidance also states that “it will be up to provinces and territories to delineate and manage their air zones based on local circumstances”.
CCME’s Guidance Document is intended as a reference tool for jurisdictions and the public.
Ontario’s proposed delineation of air zones is not based on air quality alone, but rather, is broadly based on: air quality characteristics, patterns and trends for current Canadian Ambient Air Quality Standards (CAAQS) (PM2.5, ozone, NOx and SO2), emission sources and types, geography and topography, transboundary air pollution, population density and urban/rural considerations, and the focus and types of local issues and management actions that may be required to improve or maintain air quality in a particular air zone.
Though Ontario’s approach to managing air zones is currently being developed, a key concept underpinning it is that as air quality approaches or exceeds the CAAQS, Ontario will implement progressively more proactive measures, tools and activities to improve air quality.
Comment: Traffic and transportation-related emissions, combined with population density in the Greater Toronto Area (GTA) and the City of Toronto merit reconsideration of the proposed Zone 2 classification:
- Toronto/adjacent regions comprising the GTA may be better suited as part of Zone 3 or as a new zone focused on transportation-related emissions, mobile sources, as well as smaller industrial sources.
- Zone 2 is too large and varied to effectively manage as a single zone, and needs to be modified to take better account of urban / rural differences.
Response: At this time, the City of Toronto and surrounding GTA municipalities will be classified as Air Zone 2.
Regardless of the air zone classification, air quality management actions and activities can be tailored to the needs of the community based on the sources and types of pollution.
The Ministry has a comprehensive policy, program and operational framework in place that is aimed at maintaining and improving air quality in all parts of Ontario, and this will continue. Furthermore, the approach to air zone management currently under development is expected to build on existing legislation, regulations and policies.
For example, the Drive Clean Program, operating in most of Zone 2 and all of Zone 3, requires emission testing and vehicle repairs for both light duty and heavy duty vehicles, thereby improving air quality consistent with the goals of the AQMS.
Air zone management in Ontario will also involve partnerships with local governments, stakeholders and communities. The Ministry plans to engage key stakeholders and the public on an approach to air zone management at a later date, and also expects to collaborate with key partners and stakeholders to implement air zone management and determine the most appropriate ways to improve local air quality.
In addition, the Ministry will continue to participate in national and federal-level initiatives focused on reducing smog associated with transportation emissions. For example, the Ministry is an active participant on CCME’s Mobile Sources Working Group (MSWG), focused on reducing vehicle emissions through measures such as proper vehicle maintenance, anti-tampering of emission control devices, and promoting electric vehicles and charging infrastructure.
Comment: Ontario should consider periodic review of air zones if air quality improves and/or sources, issues, and circumstances change for a particular community or region.
Response: Air zone categories and boundaries may be reviewed if the need arises, for example, due to changes in air quality patterns and sources, and/or population distribution. Management activities within air zones – as per the System – will be given due consideration with emphasis placed on proactive measures.
Comment: Concerns with the large geographic area and variability of zones 1 and 2 in terms of air quality, urban vs. rural communities, population density, and major transportation corridors.
Different areas and sources within the zones may require different air zone management approaches.
Several enquired about the role of communities, local/regional governments and municipalities in air zone management.
Response: The approach to managing air zones in Ontario is currently being developed. The approach will include and build on all laws, regulations and policies currently in place, and involve partnerships with local governments, stakeholders and communities.
The Ministry plans to engage key stakeholders and the public on the approach at a later date, and expects to collaborate with key partners and stakeholder to implement air zone management and determine the most appropriate ways to improve local air quality.