Posted by: energyblogwalter | October 26, 2009

Oakville Power plant pollution?

Dear MOE,

Unfortunately not two words mentioned in your email reply helped
answer my questions.  I’ve rewritten them below in hopes of a clearer
answer.  As well, I included the OPA representative mentioned in your
post to this email in hopes of a broader opportunity for answers and
perspectives.

Basically in a nutshell consider :

Item:  What are the local or Ontario equivalent tree planting
abatement amounts for the pollution that will be created by this new
power plant?

Item:  If you are not using the planting of trees to offset the
pollution created, why not?  Is another abatement method used?  MOE
has a tree planting program to cut pollution.  Can it not be put to
use here?  Again, I don’t understand why the dots are not connected,
directly, with specific projects that cause pollution.  Please
explain.

Item:  If you create pollution in the community you have to remove it.
Thus actually using trees to remove pollution would reduce the cries
from residents that you’re polluting their homes and not listening to
their pollution concerns wouldn’t it?  I don’t understand why this is
a challenge.

Item: No matter the technnology, pollution is an inevitable result in
mostly all industrial processes.  What is your pollution abatement
policy ie: 1 tonne of emissions  = x number of trees?  State it for me
please or whichever abatement process you have.  If none, just say
none, but explain why it is so.

Please reply via human being, not misdirected copy-paste.  Pray tell
me you can answer these simple points, on topic, or redirect to some
other human who would be willing to try.

Thank you
Walter

On Mon, Oct 26, 2009 at 2:48 PM, MOE CCU (ENE) wrote:
>
>
> Thank you for your e-mail to the Minister of the Environment regarding
> concerns about a proposed power plant in Oakville.  I am pleased to reply on
> behalf of the Minister.
>
>
>
> First, let me assure you that the Ministry of the Environment (MOE) is
> committed to a healthy environment for all Ontarians.  Clean air is a key
> component of that commitment.  The MOE’s role is to ensure the environment
> is protected in the planning, development and operation of electricity
> projects through requirements under the Environmental Assessment Act (EAA),
> the Environmental Protection Act (EPA) and the Ontario Water Resources Act
> (OWRA), where applicable.
>
>
>
> As you may already know, the Ontario Power Authority (OPA) administers the
> South-West Greater Toronto Area (South-West GTA) procurement program.  The
> OPA was established under the Electricity Act as the province’s planning
> authority for electricity supply.  Under the South-West GTA procurement, the
> OPA received proposals for the supply of up to 900-megawatts of new, natural
> gas-fired generation to be located in the South-West GTA.
>
>
>
> On September 30, 2009, the OPA announced that TransCanada Corporation was
> the successful proponent to build and operate a proposed 900-megawatt power
> plant, to be located in Oakville.
>
>
>
> For further information about the OPA’s procurement process, I encourage you
> to contact […]  Director of Procurement, Electricity Resource Division,
> OPA […]
>
>
> In addition, all natural gas-fired generation facilities must be planned and
> developed in accordance with the Environmental Screening Process (ESP) under
> the Environmental Assessment Act (EAA).
>
>
>
> The ESP is described in the “Guide to Environmental Assessment Requirements
> for Electricity Projects”.  The guide can be found on the MOE web site at
> www.ene.gov.on.ca/envision/gp/4021e.pdf.
>
>
>
> The ESP requires that proponents evaluate the project against screening
> criteria set out in the guide to identify the potential for any negative
> environmental effects that may be caused at any stage in the project life
> cycle, as well as describe mitigation measures and net effects of the
> project.  Several of the screening criteria address issues which you are
> concerned about, including the potential for the project to have negative
> effects on health and the environment.
>
>
>
> TransCanada must finalize the required Environmental Review Report and make
> it available for public review and comment for a minimum 30-day period.  The
> company will be required to provide adequate notice through measures that
> may include newspaper advertisements, notice on its web site and letters to
> adjacent property owners.
>
>
>
> In addition to the EAA requirements, the facility will also require a
> Certificate of Approval from the MOE.  TransCanada cannot apply for approval
> until it has fully completed the EAA process.  Before a Certificate of
> Approval can be issued, the company must demonstrate that the facility can
> meet or exceed provincial standards and be operated in an environmentally
> responsible manner.  I would like to assure you that TransCanada Corporation
> will also be required to address the potential cumulative impacts of its
> proposal.
>
>
>
> I have attached a fact sheet which also summarizes the environmental
> assessment and approvals processes.
>
>
>
> On September 30, 2009, the MOE announced that it will establish a Task Force
> to develop, with a community advisory committee, an action plan for
> improving air quality in the Clarkson-Oakville Airshed.  The Task Force has
> a mandate to report back to the ministry by the end of June 2010 on an
> action plan that includes targets, timelines, strategies and reporting
> requirements that address local industrial, vehicular and residential
> sources of air pollution.  Further details on the Task Force will be
> announced in the near future.
>
>
>[…]
>
> Sincerely,
>
>
>
> Name Omitted
>
> Director, Central Region

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Responses

  1. The oblivion that is government bureaucracy continues. The above exchange between Oct 3 and Oct 26th!

    But I want to know why not just plant trees when anything pollutes, and to do so with obvious purpose and benefits.

  2. Followup Reply Received::

    Subject: Response to Your E-mail About the Proposed Power Plant
    Date: Tue, 10 Nov 2009 11:38:33 -0500

    I have received your e-mail of October 26, 2009, in which you indicate that the October 26, 2009 response to your October 3, 2009 e-mail does address the specific questions and concerns you have raised.

    I’m sorry you feel the response does not speak to your original e-mail. I reviewed your e-mail of October 3, 2009, and note that you are questioning whether the emissions from the power plant that is proposed for the Town of Oakville will be offset by the planting of trees.

    In order to operate, the proposed power plant will require approval from the Ministry of the Environment. Before a Certificate of Approval can be issued for the power plant, the company must first demonstrate that the facility can meet or exceed provincial standards and be operated in an environmental responsible manner. TransCanada will also be required to address the potential cumulative impacts of its proposal.

    The Task Force that will be established by the Ministry of the Environment will have the mandate to develop an action plan for improving air quality in the Clarkson-Oakville Airshed. It would be premature to say what role tree planting will play in the action plan, as the Task Force will have until the end of June 2009 to report back to the Minister of the Environment.

    With respect to your suggestion that planting trees will benefit the environment, the Ontario government is working with partners to plant as many as five million trees per year in southern Ontario, to reach 50 million trees by 2020. The initiative will cost $79 million and help remove 3.8 million tonnes of carbon dioxide from our atmosphere by 2054, equal to 172 million car trips from Toronto to Barrie. The following link will provide you with a copy of the news article on this program: http://www.premier.gov.on.ca/news/event.php?ItemID=3842&Lang=EN

    This tree planting program is being administered by the Ontario Ministry of Natural Resources (MNR) and not the Ontario Ministry of the Environment. The following link will provide you with information about the MNR Plant a Tree challenge and how municipalities and individuals, such as yourself, can become involved:

    http://www.mnr.gov.on.ca/en/Business/ClimateChange/2ColumnSubPage/STEL02_200789.html

    Should you require further information on this program, please contact ……

    Thank you for writing and please accept my best wishes.

    Yours truly,

    District Manager

    Halton-Peel District Office

    Ministry of the Environment

    4145 North Service Road

    Suite 300

    Burlington ON L7L 6A3

  3. Alrightie….so basically they need a task force to define if the planting of trees will offset as determined by committee, but its not a specific requirement. Even though they are planting trees. Proof that one is not connecting to the other!

    The powerplant should be paying for the tree planting to offset their pollution, and be mandatory without a perverication taskforce. A mitigation plan, thus Ontarians do not pay twice. Once for the emissions and again for the trees.

  4. Thank you for your reply and links. First a reply on the links, then
    a followup on your email.

    What I don’t understand is why you cannot connect the dots, and make it a mandatory function of any proposal that a power plant proposal also include their 110% pollution mitigation plan? Equal or exceeding for each tonne of emissions? I do not find equality of mitigation to tonnes of emissions in your links or documents or newspaper articles. Please correct me if I missed this. What is the exact amount of mitigation expected for compliance?

    In your link, McGinty is quoted as saying “we need Ontarians to work with us and do their part.” and goes on talking about mitigation yes, but it does not tie it directly into the power plant proposal process for Oakville or any other power plant for less cost to the taxpayer. This remains a total disconnect and is in need of remedy.

    The need for trees and carbon sinks for mitigation creates a carbon farming industry in Ontario not seemingly addressed by government nor industry, nor your task force or links.

    I don’t see why I have to pay twice. First, for the pollution, and secondly for the trees, both in separate processes, both at my expense through various ministries who can’t see each other. This should be
    included in the cost to the power plant proposal thus removing an expense to the taxpayer also twice. First in air pollution illnesses and deaths, and secondly in the cost of planting trees from another ministry. Since carbon sinks would be needed throughout the life of the power plant, this would also create jobs. A total win-win-win.

    This puts mitigation directly costed to those who pollute. A mitigation plan can then be asked to be implemented alongside operations from the proposal stage itself. On day one PRIOR to certification as a requirement before task force compliance and before the proposal can go ahead. This did not happen, is not in your policies, and is making the words of the Premier only words, not action.

    The Oakville example compared to his UN press release catches the Premier in a lie although this is not intentional. The ministries don’t know what they’re doing. This is why I write again and again and again. Until action occurs.

    I don’t mind a Premier asking for Ontarians to do their part, but when the left hand of gov’t doesn’t know what the left hand is doing, let alone the right, this is a missed opportunity for administration correction and to really meet goals the Premier is talking about. The bureaucracy is falling down on us right now, and people with weak
    respiratory issues will continue to suffer and die because of it.

    Now then,

    In your email you mention that a company “must meet or exceed provincial standards”. Why do those standards include allowing for effluent without a 100% (or even 110%) mitigation plan? You mention
    tree planting but you don’t connect the reasons for tree planting to effluent emissions at all as per McGinty’s UN speech. This is an error and needs to be corrected. That is your reason to act. To prevent more egg on his face.

    Look at it this way; You have one process in a ministry whose job it is to combat climate change. You have another process in another ministry whose job it is to approve of power plants. That’s fine. But one helps the other. Just put the two together please.

    So unfortunately the questions remain unanswered, and why I must ask again these two questions;

    1) Why are trees not directly included in your power plant operations acceptance certification planning as a specific item for compliance prior to task force?

    2) Why have another ministry plant trees when the cost should be offset directly by the polluter for 100% or more, at their expense?

    For a province in massive debt, facing possible Dalton Days and reduced capabilities and with a Green Act in place, this makes perfect sense. You can protect your ministry by finding savings in tree planting and 100% mitigation. That I need three emails telling me otherwise is quite weird and not acceptable. I realize you have
    processes, but you’re not answering either yes or no. This is also not in line with the Premier’s comments and actions. Thus a failure of recognition of the requirements of process change.

    Your processes are not in line with the comments made in links and the policies do not reflect this understanding of climate change, as they have unlikely changed.

    3) What was the date of your last policy change in your certification process, and if before the plan presented by McGinty to the UN regarding climate change, why hasn’t it been updated?

    Action is required and action is expected. All I want to do is merge two processes into one, save you a lot of money, not to mention serious community grief. I want to have obvious pollution immediately offset and recognized directly as such within the initial proposal process before task force. People’s health are directly affected and this should not be such a quixotic journey, but an appreciated epiphany.

    With Best Regards,
    Walter


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