On September 11, 2001 the Ministry of the Environment posted proposed revised Control Orders for the INCO Ltd. and Falconbridge Ltd. smelting operations in the Sudbury region, on the Environmental Bill of Right Registry. In response to this posting Mark S. Winfield, Ph.D., Director of the Pembina Institutes Environmental Governance Program submitted this letter Bill Cameron, District Manager, Sudbury District Office.
While the Pembina Institute welcomes the direction of the Ministry's proposal, this letter outlines a number of significant concerns Pembina has with their specific provisions as follows:
- The prposed reductions in sulphur dioxide emissions are inadequate;
- The Ministry's proposals fail to address other substances of concern emitted by the Inco and Falconbridge facilities;
- The relationship between the proposed Control Order limits for Inco and Falconbridge and the Emission Trading Scheme announced October 24, 2001 is unclear and;
- The Transfer of Responsibility for Operating and Maintaining MoE's Sudbury Air Monitoring Network makes no provision for Public Access to Information.
