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September 25, 2014

Proposed Changes to Toronto’s Pollution Prevention Program will Introduce New ‘subject pollutant’ Threshold Reporting List

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Commercial and industrial stakeholders in Toronto will soon have an opportunity to review proposed changes to the city’s Pollution Prevention (P2) Program and Sewers By-law, Municipal Code Chapter 681.

The proposed changes, which are expected to be implemented in late 2015 or early 2016, include:

  • the creation of a subject pollutant threshold reporting list;
  • changes to the dental office submission requirement;
  • changes to the grease interceptor requirement;
  • the creation of a best management practice (BMP) for the automotive refinishing sector; and
  • the creation of a BMP for mobile washing business operations.

The most controversial proposal relates to the creation of a subject pollutant threshold reporting list.

The City’s P2 Program is currently based on 39 subject pollutants comprising 12 heavy metals and 27 organic compounds. Currently, every subject sector industry and every industry that discharges any amount of a subject pollutant must submit a P2 Plan to the City acknowledging the discharge of that subject pollutant and steps to reduce or eliminate that subject pollutant.

If the proposed changes take effect, some industries may not have to submit a P2 Plan for subject pollutants that are below proposed thresholds. During consultations held during the first part of 2014, environmental groups, such as Canadian Environmental Law Association (CELA), voiced concerns that "establishing thresholds may weaken/undermine the city’s program to promote pollution prevention". CELA advises that the city not proceed with the proposed threshold reporting list at this time "without providing additional rationale and public consultation on why such thresholds are required or which pollutants would be appropriate to target thresholds".

Commercial and industrial stakeholders in Toronto will be able to review proposed changes later this Fall. The amendments will then be reviewed by the Public Works and Infrastructure Committee next year, when a staff report outlining the changes will be submitted to City Council.


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