Delivered via E-mail & Regular Mail Re: Carbon Black Industry Standard (Environmental Registry No.: 019-6492)

2 We are concerned that the proposed technical standard would permit the carbon black facilities to emit SO2 at a level that exceeds the WHO guidelines for another five years. [...] According to a report on air quality, facilities in Canada emit at a higher level than facilities in the United States.4 A Phillips 66 carbon black chemical plant in the San Francisco Bay Area Air Quality Management District (BAAQMD) near Rodeo, California, for example, reported 1,328 tonnes of SO2 emissions to the US National Emission Inventory in 2017. [...] The failure to consider cumulative effects means that the combined emissions from facilities could exceed the standard, even if each facility individually complies with the provincial standard, thereby causing harm to human health and the environment. [...] CELA therefore requests the Minister to exercise his authority under section 24 of the Environmental Bill of Rights (EBR) to enhance public participation by organizing public community meetings and opportunities for oral submissions regarding the Ministry’s proposal for a carbon black industry technical standard. [...] CONCLUSION CELA makes the following recommendations regarding the Ministry’s proposal to develop a technical standard for the carbon black sector: 1) Shorten the timeline for the carbon black facilities to implement pollution control technologies.