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July 18, 2003
To: Bruce McEwen
Fuels Division, Environment Canada
Re: Setting Canadian Standards for Sulphur in Heavy and Light Fuel Oils
Dear Mr. McEwen:
I am writing to you on behalf of the Ontario Public Health Association (OPHA), a volunteer, non-profit organization that represents many of the staff working in public health units across Ontario. Our members include the physicians, environmental health managers, epidemiologists, nurses, toxicologists, researchers, and policy analysts responsible for maintaining public health in their communities. As such, our members are deeply concerned about air quality and its impact on human health.
I am writing to provide you with comments on Environment Canada's proposal to align sulphur levels in heavy and light fuel oils used in stationary sources with the requirements set by the European Union (EU) as articulated in the discussion document, "Setting Canadian Standards for Sulphur in Heavy and Light Fuel Oils" (Env Can, 2003).
Aligning with EU Standards is an Important First Step
Let me begin by saying that we are very pleased that Environment Canada is moving to establish national standards for sulphur levels in heavy and light fuel oils that are comparable to those established by the European Union (EU). We understand that this would mean that the national average for sulphur levels in heavy fuel oils (HFOs) in Canada would be reduced from about 17,280 ppm to less than 10,000 ppm and that the national average for sulphur levels in light fuel oils (LFOs) would be reduced from about 2,010 ppm to less than 1,000 ppm (Env Can, 2003). While we would like to see these standards tightened further over time, we believe that this is a very important and significant first step.
EU Standards would Produce Significant Improvements in Air Quality
Applying EU standards to Canadian fuel oils would produce significant improvements in air quality in eastern Canada, particularly in the Atlantic provinces.
We understand that there is almost a linear relationship between sulphur levels in fuel oils and sulphur emissions. In other words, a 50% reduction in sulphur levels in the fuel can be expected to result in nearly a 50% reduction in sulphur dioxide emissions. Once in the atmosphere, we know that sulphur dioxide can be transformed into sulphates, sulphuric acid and other sulphur compounds (Env Can, 2002).
We also understand that reducing sulphur levels in heavy fuel oils can result in the reduction of a broad array of air pollutants suspected to be of concern to human health. Studies conducted by the U.S. Environmental Protection Agency (EPA) have demonstrated, for example, that when sulphur levels in HFO No.6 (i.e. with 16,600 ppm sulphur) were reduced by 70% to 4,900 ppm, emissions of total particulate matter, metals (i.e. vanadium, nickel, lead as well as others) and polycyclic aromatic hydrocarbons (PAHs)(ie. naphthalene as well as others) were reduced by 86%, 87%, and 77% respectively (Env Can, 2002).
Modelling conducted for Environment Canada suggests that ambient air levels of sulphates could be reduced by about 2 to 6% from Toronto to Montreal and by 8 to 28% in the Atlantic provinces (ARM, 2002). As sulphates represent a significant percentage of the fine particulate matter in the air in eastern North America (ie. up to 40% of PM2.5), and can be used as an indicator of ambient air levels of fine particulate matter, the modeling results suggest that the EU sulphur standards could produce substantial reductions in ambient air levels of fine particulate matter Ontario and Quebec (i.e. up to 2.4%) and even greater reductions in the Atlantic provinces (i.e. up to11%).
Air Quality Improvements could Result in Significant Health Benefits
The reductions in ambient air levels of fine particulate matter (PM2.5) suggested by the modeling indicates that EU sulphur standards could produce significant public health benefits in Canada, particularly in the Atlantic provinces.
Fine particulate matter poses a significant public health concern. The Ontario Medical Association (OMA) estimates that ambient air levels of fine particulate matter contribute to about 1,900 premature deaths per year in this province. And yet, it is well recognized that premature deaths represent only the tip of the iceberg. Numerous studies conducted in cities around the world, using widely varying study designs, have demonstrated clearly and consistently that short-term increases in air levels of fine particulate matter are associated with increases in the rates of respiratory infections, asthma symptoms, emergency room visits, hospital admissions for lung and heart diseases, as well as premature deaths.
 When the Federal Provincial Working Group on Air Quality Objectives and Guidelines examined the scientific literature related to fine particulate matter, it concluded that: "Clear and consistent increases in non-traumatic deaths and hospital admissions have been documented at daily PM10 and PM2.5 levels as low as 25 and 15 ug/m3 respectively" (Working Group, 1999). As indicated in Figures 1 and 2, these are air levels that are frequently exceeded in communities across Ontario (OPHA 2002).
 There is also a growing body of scientific literature which indicates that fine particulate matter also contributes to the development of chronic heart and lung diseases including lung cancer. For example, in a longitudinal study conducted by Pope et al. in which 1.2 million adults in the United States were followed over a 16-year period, demonstrated a strong and consistent association between air levels of fine particulate matter (PM2.5), sulphates and sulphur dioxide, and deaths from lung cancer, cardiopulmonary illnesses, and all causes. The researchers found that: "Each 10 ug/m3 elevation in fine particulate air pollution was associated with approximately a 4%, 6% and 8% increased risk of all-cause, cardiopulmonary and lung cancer mortality respectively" (Pope, 2002).
Regulations, Economic Tools and Flexibility
In the OPHA, we are very clear that we would like to see regulations used to reduce sulphur levels in fuel oils. We also feel very strongly that the definition of fuel oils should be drafted to include bitumen emulsions that are used extensively in the Atlantic provinces. We would like to see standards for both HFO and LFO adopted as soon as technically possible. After all, the compliance date for the 10,000 ppm sulphur standard for HFOs in the EU has already passed (January 2003). We do not believe that we should have to wait until 2008 if it is technically feasible to implement these standards before then.
We believe that economic tools such as tax differentials -- where higher taxes are levied on fuel oils that have higher sulphur content -- can be useful policy tools for LFOs but feel strongly that they should be used within a regulatory framework or as a supplement to a regulation to encourage early adoption of fuels with lower sulphur levels.
We understand that the European Union Directive (1999/32/EC), used to establish sulphur standards for fuel oils in Europe, allows some exemptions and flexibility. For example, we understand that it exempts power plants and certain industries from the 10,000 ppm sulphur standard for HFOs when they are equipped with technology such as flue gas desulphurization and keep sulphur dioxide emissions equal to or below 1700 mg/Nm3 (i.e. an emission rate considered equivalent to that which would be associated with the use of HFOs containing10,000 ppm sulphur)(Env Can, 2003).
We understand that, in the Canadian context, it may be cost effective to provide some flexibility to certain industries that use large quantities of HFO. We are concerned however, that by offering exemptions to plants that install exhaust treatment technologies, we may lose the public health benefits associated with co-pollutants, such as PAHs and metals, that can be reduced when sulphur levels are in HFOs are reduced.
While the OPHA recognizes that emissions trading, when conducted within a well-designed regulatory framework, can be an effective tool for reducing air emissions, we still have many reservations about its use. Our concerns are related to: local health impacts in the communities that "buy" credits instead of reducing emissions; the non-regulated co-pollutants that can be affected by emissions trading; and the unequal health impacts that can be associated with air pollutants released at ground level versus those released from stacks when a trading scheme allows reductions gained from mobile sources to be sold to stack emitters (as the Ontario emissions trading scheme does).
Conclusion
The OPHA is very pleased that the federal government is moving forward to establish national standards for fuel oils in Canada. While ultimately, we would like to see Canada establish fuel standards and energy policies that move us away from reliance on HFOs and LFOs because of their contribution to poor air quality, acid rain and global climate change, we believe that alignment with EU fuel standards represents a significant first step.
We thank you for the opportunity to provide comments at this early stage in the standard development process, and hope to see a concrete regulatory proposal in the very near future.
Yours truly,
Jack Lee
Executive Director
cc: David Anderson, Federal Minister of the Environment
Anne McLellan, Federal Minister of Health
Christina Mills, President, Canadian Public Health Association
Odette Comeau Lavoie, President, New Brunswick/PEI/CPHA
Susan McBroom, President, Public Health Association of Nova Scotia
Christina Mills, President, Newfoundland & Labrador Public Health Assoc.
Connie Utrecht, President, Ontario Public Health Association (OPHA)
Kim Perrotta, Air Quality Coordinator, OPHA
References
ARM Consultants, (2002). "Emissions-Scenario Simulations of Potential Sulphur-Content Reductions for Heavy Fuel Oils and Light Fuel Oils Using the Acid Deposition and Oxidant Model", Prepared by Dr. Jacek Kaminski for Environment Canada.
Environment Canada, (2003). "Setting Canadian Standards for Sulphur in Heavy and Light Fuel Oils", Discussion paper prepared by the Fuels Division, Oil, Gas and Energy Branch.
Environment Canada, (2002). "Research Strategies Relevant to Heating Fuel Oil Specification: Fuel Sulphur Aspects Literature Review", Prepared by CANMET Energy Technology Centre for Environment Canada.
Federal Provincial Working Group on Air Quality Objectives and Guidelines. Environment Canada (Working Group), (1999). "National Ambient Air Quality Objectives for Particulate Matter".
Ontario Public Health Association (OPHA), (2002). "Beyond Coal: Power, Public Health and the Environment".
Pope et al., (2002). "Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution", Journal of the American Medical Association.
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