Base Metal Smelters and Refineries and Zinc Plants – Response to Stakeholders' Comments

Comments

Several comments related to costs of achieving the proposed targets and implementing best available techniques:

• Need to consider costs and socio-economic implications of implementing the best available techniques.
• No existing best available technology to meet some proposed targets.
• The Proposed Notice does not maximize environmental benefits at minimum cost and target least cost emission reductions for early implementation.

Responses

Targets are proposed as "factors to consider", and benefits/costs evaluation may be done by facilities developing P2 plans. The Pollution Prevention Plan instrument allows companies to develop plans that take into account scientific information on health and environmental impacts as well as, technological, economic and social factors.

Following the publication of the Proposed Notice, a study on the technical feasibility and costs of the proposed targets was commissioned. In the final Notice, the targets were modified to take into account the cost effectiveness of various targets and advice from stakeholders.

When proposing conventional release regulations, Environment Canada is required to develop a Regulatory Impact Analysis Statement (RIAS) documenting benefits and costs. This would be done for the 2015 release regulations using multistakeholder consultations and consultants, information submitted in Interim Progress Reports for the P2 Plans, and various studies.

Comments

Several comments relating to the need to evaluate site-specific conditions to develop site-specific emission limits were received:

• Need for site-specific health and environmental studies to support proposed emission reduction targets and schedules.
• Facilities should undertake studies to demonstrate feasibility and equity of their P2 plans.
• Emission of specified toxic substances should be reduced to levels that do not threaten human health and the environment.
• It cannot be suggested that there are no health and environmental effects from Manitoba smelter emissions and no reason for reductions.
• The need to include low emitters is questioned, as there is no significant impact on regional air quality, and provinces are best positioned to manage local air quality. Objective should be to reduce emissions from largest emitters.

Responses

The emission guidelines, targets and schedules in the Code and P2 Notice are based on commonly used pollution prevention and control techniques in the sector and may not be adequate for protection of ambient air quality at all times in all locations. Consequently, a Community Air Quality Protection Program has been added to the Final Notice so that ambient air quality objectives are not exceeded. This may involve periodic reductions and special management of emissions from some operations at some times.

A meeting was held in Winnipeg, Manitoba in November 2004 between Environment Canada, Health Canada, the Manitoba government, and representatives from Manitoba smelter companies to exchange information and views on base metal smelter emissions and their effects, address concerns specific to Manitoba facilities, and explore potential opportunities for collaborative assessment of studies.

There was agreement on the need for more effective monitoring to fill in gaps in scientific information on the ecosystem impacts of emissions from the base-metal smelting sector. Following the meeting, Environment Canada and Manitoba Conservation agreed to discussions about acid rain monitoring and research in Manitoba and other western provinces. Beginning in April 2005, Manitoba and Saskatchewan joined the Canadian Council of Ministers of Environment (CCME) Acid Rain Task Group, bringing the provincial representation to all ten provinces. Various cooperative studies are now planned which will help better understand the ecological impacts of smelter emissions.

Comments

Some comments suggested that the Proposed Notice and Code was focussed on available technologies, economics and the profitability of companies, rather the protection of the health of workers, the public and the environment.

Responses

The modified Pollution Prevention Planning Notice is balanced, and includes a Community Air Quality Protection Program. It also encourages consideration of existing and new scientific, health, environmental, technical, economic and social studies.