Background on 2010 Action Plan for Reducing Air Pollution in the OCA

Briefing Note

The Imperative for Implementing the 2010 Action Plan For Reducing Air Pollution in the Oakville-Clarkson Airshed (OCA)

Air quality in the OCA is a serious problem

Here's a copy of the letter sent by C4CA to Ontario Environment Minister John Wilkinson


Leading experts agree that air pollution is the most harmful environmental problem in Canada today. The David Suzuki Foundation, for example, has stated that air pollution causes "... thousands of deaths, millions of cases of illness, billions of dollars in health care expenses, and tens of billions of dollars in lost productivity every year."

In Halton and Peel, air pollution is directly linked to numerous premature deaths and excess hospital admissions that cost the health care system and society millions of dollars every year. According to the Ontario Medical Association (OMA), air pollution in 2005 was responsible for:

  • 190 premature deaths and 540 hospital admissions in Halton
  • 370 premature deaths and 1240 hospital admissions in Peel
  • estimated health care costs of $56.82M for Halton and Peel, and
  • estimated lost productivity costs of $45.82M for Halton and Peel.

And the health care impacts of air pollution in Halton and Peel are accelerating, and will continue to accelerate if no corrective action is taken. For example, according to the OMA, air pollution in 2008 was responsible for:

  • 336 premature deaths in Halton
  • 700 premature deaths in Peel

which are considerably higher than projections made in 2005.

The Oakville-Clarkson airshed also has the highest youth asthma rates in Ontario.

Air pollution in the Oakville-Clarkson Airshed is a serious medical, business and social issue that will only get worse in the decade ahead. Corrective action must be taken now to better monitor, manage and reduce the cumulative impact of air pollutants in the OCA.

There is no need for further study

The Ministry of the Environment has been studying the Oakville Clarkson Airshed for over a decade (as described in the Balsillie Report):

The Ministry of the Environment (MOE) began the Clarkson Airshed Study (CAS) in the year 2000. This study was carried out as a response to concerns from the community about poor air quality, elevated levels of inhalable particulate matter (PM10) being measured in the community downwind of the Clarkson Airshed, and an evaluation of historical regional monitoring data showing potential sources of oxides of nitrogen (NOx) within the area of the airshed. The CAS consisted of the following parts:
PART I, carried out between 2001 and 2002, identified major sources of targeted pollutants.
PART II, carried out between 2003 and 2005, was a 22-month ambient air monitoring program that confirmed, at times, especially during smog events, that the CAS study area represents a "taxed" or compromised area with respect to respirable particulate matter (PM2.5).
PART III, carried out between 2006 and 2008, focused on major sources of targeted industrial pollutants. The study involved complete emission inventories and air dispersion modelling. The findings were submitted to MOE. Regional modelling was then carried out to evaluate the contribution of these sources to the air quality in the area of the airshed.
PART IV of the CAS began in the spring of 2007, with the formation of the Clarkson Airshed Advisory Committee (CASAC). The mandate of CASAC was to operate an air quality management system within the Clarkson area on the basis of shared responsibility and the use of consensus building and a collaborative approach towards improving air quality. The Committee, working with an environmental consultant, began to develop and implement a permanent air monitoring program. Local industries were expected to design and operate abatement programs to reduce emissions of targeted pollutants. The original focus of CASAC was to achieve commitments from industry to "go beyond compliance."
This process involving CASAC did not achieve the desired outcomes. It was abandoned in mid-2009.

Later in 2009, the Minister of the Environment asked Dr. David Balsillie to chair an Air Quality Task Force (AQTF) that was:

... created to be a catalyst for developing forward-looking solutions on long- debated air quality problems ... the goal of the AQTF is to give the Ontario government an Action Plan (emphasis added) to achieve real improvements in air quality to enhance the health of residents and their children, the quality of the environment, and the economic competitiveness in the SWGTA.

Dr. Balsillie was given six months to complete his report, which was delivered to the Minster on June 24, 2010. Dr. Balsillie delivered. To date, the Ministry of the Environment has not.

Air pollution must come down

In his report, Dr. Balsillie concluded that:

The status quo for air emissions, however, is not sufficient. Pollution from transportation, industrial, and residential sources must come down. There are practical reasons why this must be the case quite apart from the health and environmental benefits. Congestion on the highways and roads in the airshed is getting worse. The economy is starting to re-bound, and many industries are looking forward to expanding production. The population of the area is growing. There will be pressure to increase air pollution emissions. This is unacceptable. (Page 3)

Dr. Balsillie also concluded that bringing air pollution down requires a new approach to managing air quality as set forth in his first recommendation, which is to:

"Develop and implement a new form of governance and an AMS in the OCA to effectively manage cumulative impacts".

Dr. Balsillie has sensibly concluded that if we want to reduce air pollution, then we must measure, monitor and reduce the aggregate impact of all pollutants regardless of source. This is a substantive change to how the MOE currently approves and manages regulatory compliance.

"Many jurisdictions around the world have adopted an airshed management approach to address local air quality problems by reducing emissions from every sector in the airshed. To implement an airshed management model, new tools are needed. In particular, cumulative impact assessments for airsheds with multiple sources are critical. This approach goes beyond "point-of-impingement" which currently characterizes the way in which the Ministry of the Environment approves and manages regulatory compliance for point-source emissions. The implementation of an Airshed Management System (AMS) is critical to the success of the Action Plan for the OCA."

Dr. Balsillie also provides a practical and cost effective way of developing an AMS in the OCA that could then be used in other airsheds and air zones in Ontario, and perhaps across Canada:

The Oakville-Clarkson Airshed, however, could serve as a pilot project for the more widespread application of cumulative impact assessment for AMSs. Without this tool, it will be very difficult, if not impossible, to make logical and important decisions concerning the current and future emission sources within this and other airsheds. In order to facilitate the implementation of the Action Plan, the development of some place-based (airshed specific) policies and/or regulations will be required."

It is unacceptable that after a decade of study, and a year since the release of the Balsillie Report, that little concrete action has yet been taken with respect to the implementation of his key recommendation "develop and implement a new form of governance and an AMS [Air Management System] in the OCA [Oakville-Clarkson Airshed] to effectively manage cumulative impacts."

Moving forward

The need to measure pollution impacts on a cumulative basis is a critical component of the Balsillie Action Plan and an Air Quality Management System. C4CA believes that without a system that measures, reports and monitors pollution impacts on an aggregate and cumulative basis, it will be impossible to establish a proper baseline to measure progress, improve the way we regulate emissions and emitters, or assess the effectiveness of community based air management initiatives. As Tom Peters, the management guru has said "what gets measured gets done".

We therefore suggest that the MOE not get side-tracked initially into issues like revising legislation and regulations or setting up ineffective community initiatives that will not advance the implementation of the Balsillie Action Plan. These will, of course, have to be dealt with in the fullness of time – when experience has been obtained in developing an AMS pilot.

Instead, we recommend that together we initially focus our efforts and collective resources on a joint Ministry and community task force to develop a protocol and supporting system for measuring, reporting and monitoring air quality (on a cumulative impact basis) in defined air sheds starting with the OCA. Such a protocol must be cost effective, relevant to the needs of various stakeholders, and produce accurate, reliable information on a timely basis.

We think this is a very practical first step towards implementing Dr. Balsillie's Action Plan. It should also produce a "best practice" that can be used in managing air quality in other air-sheds or air-zones across Ontario or across Canada and serve as the basis for future decisions related to implementing the Balsillie Report. C4CA believes that a firm commitment to developing a measurement protocol and supporting system is a critical first step in moving forward with the recommendations contained in the Balsillie Report, and accordingly, we would support such an initiative.

A new form of governance is needed

After a lost decade of study and debate, it is clear that a new form of governance is required to hold the MOE's feet to the fire and ensure that action is taken to implement Dr. Balsillie's Action Plan. C4CA suggests that there are at least three broad models for "The Oakville-Clarkson Airshed Action Committee" set forth in recommendation one:

  • A technical oriented advisory committee that would provide the Minister and the Ministry, with advice and guidance on scientific, technical or other issues related to the operation of the pilot.
  • A stakeholder engagement/communications committee that would communicate with, educate and engage a variety of stakeholder groups in air zone management issues (e.g., reducing car emissions, planting trees etc.)
  • A governance board or committee that will help ensure that the objectives of the pilot are achieved, the success of the pilot fairly evaluated and the key learnings and recommendations from the pilot fairly presented.

C4CA strongly favours a governance board approach, and believes it is consistent with the thinking in the Balsillie Report. This approach would significantly enhance the credibility of the AMS Pilot, ensure that the AMS Pilot achieves an appropriate balance between a "bottom up" and "top down" focus, and will provide the best support to the Ministry, the Minister and the MOE executives leading the AMS Pilot. But most important, it would ensure that action is taken – and hold people to account if it is not.

Whether this governance board is reconstituted as a permanent feature of an operational AMS system, is one of the factors to be assessed in the evaluation of the AMS Pilot.

Where do the parties stand?

C4CA calls on all parties and all candidates to declare their support for a pilot project led by the MOE to take the first critical step to cleaning up our air. Read the Balsillie Report here. We believe that establishing an appropriately structured Oakville-Clarkson Airshed Action Committee and focusing on the development of a measurement protocol and supporting reporting and monitoring system are practical first steps in implementing this recommendation.

We cannot endure another lost decade of study and debate. The time has come to act. The electorate will accept nothing less.

Air Quality Resources