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Letter
to Minister Laurel Broten
April 23, 2007
The Honourable Laurel C. Broten
Minister of the Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5
Dear Ms. Broten,
Re: Query submitted about process employed to
decide on used oil burning ban
On Friday, April 20, I sent you an e-mail, a copy of
which is attached to this cover letter. I am forwarding
that communication to you today via courier to ensure
that it is not lost in the large volume of e-mail submissions
you undoubtedly receive.
As part of our newly launched “Science Audit Centre”
campaign, the Natural Resources Stewardship Project certainly
look forward to hearing back from you concerning the process
that was employed to come to the decision to ban used
oil burning. As explained in my e-mail, we are concerned
that a potential exists that such a ban may have a net
negative impact on the environment when one conducts a
comprehensive life cycle analysis of the different options
for handling used oil. That is why we would like to learn
about the full environmental assessment process that was
employed in this case.
Sincerely,
Tom
Harris, B. Eng., M. Eng. (mechanical)
Executive Director
Natural Resources Stewardship Project
P.O. Box 23013
Ottawa, Ontario K2A 4E2
Phone: 613-234-4487
Fax: 613-234-3325
e-mail: tom.harris@nrsp.com
Web: www.nrsp.com
April 20, 2007
The Honourable Laurel C. Broten
Minister of the Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5
Dear Ms. Broten,
On Wednesday, April 18, the Natural Resources Stewardship
Project launched its Science Audit Centre and issued the
following news release to describe our programme: http://www.cnw.ca/en/releases/archive/April2007/18/c6514.html.
I sent the release to your office shortly after it appeared
on the CNW wire.
While we will be addressing a range of issues over the
coming months, there is one that concerns your ministry
that we would like to enquire about, please.
In your speech of January 11, 2007, the text of which
is now on the MOE Web site at http://www.ene.gov.on.ca/en/about/minister/speeches/011107.php,
you asserted that banning used oil burning will result
in a reduction of pollution emissions. A decrease in such
emissions is clearly a laudable objective if the evidence
shows that such a reduction is expected to occur at a
reasonable cost to the taxpayer. However, you also said:
“Banning the burning of used oil will also help reduce
Ontario’s greenhouse gas emissions by almost 500,000 tonnes
annually — that’s the equivalent of taking nearly 100,000
vehicles off the road. Reducing greenhouse gas emissions
is critical as we face our next great environmental challenge.
Global climate change has been called the defining issue
of our generation. How we deal with it will determine
the kind of world our children will inherit from us. We
need to take concrete action to reduce greenhouse gas
emissions that are contributing to global warming. We
also know that taking on global warming will require a
massive adjustment in the way we live and how we do business.”
As you probably know, NRSP and the many scientists we
work with do not believe that reduction in carbon dioxide
(CO2), the greenhouse gas of concern in most climate change
schemes, is a worthwhile goal. While sensible energy conservation
and pollution reduction is indeed an important objective,
modern climate science findings shed serious doubt on
the hypothesis that anthropogenic CO2 emissions are a
significant cause of global climate change. We believe
that an undue focus on CO2 reduction diverts attention
from the important task of reducing real pollutants. In
some cases, actions to reduce CO2 emissions are taken
at the cost of increasing the emission of pollutants such
as particulates, sulfur dioxide, nitrous oxides, ozone,
etc. and so is clearly a mistake. With your very strong
focus on reducing CO2 in the above quote, we are concerned
that the decision to ban used oil burning may be based
primarily on the alleged greenhouse gas reduction, with
the resultant impact on pollution emissions of secondary
concern.
Consequently, we request that you share with us the answers
to the following questions concerning the process by which
the decision to ban used oil burning was arrived at by
MOE officials:
- Was a full life cycle environmental analysis of the
various methods for handling used oil conducted? If
it was, who conducted the analysis and how was it conducted?
Could you share with us the process used and the results
attained, please? What efforts were made to seek independent
verification of the analysis from disinterested third
party scientists and engineers to this life cycle analysis?
- Were public hearings held before this decision was
made? If hearings were held, could you please share
with us the identities of those who testified, and how
their testimony was taken in account in the final decision
making process? If a report followed the hearings, we
would appreciate it if you could send us a copy a soon
as possible.
- What input was sought from affected parties? What
responses did you receive and how was this input handled?
We request that we be sent a description of the complete
public and private consultation process that was conducted
before coming to the decision to ban used oil burning,
please?
NRSP believes that any new approach to the handling of
used oil must have a net positive impact on reducing environmental
damage. Otherwise it is not worth the financial cost such
a transition will undoubtedly cost the taxpayer – monies
that could be spent on other environmental and social
issues. To feel confident that the decision to ban in
situ used oil burning will indeed benefit the environment,
we request that you share with us the answers to the above
questions.
We look forward to hearing back from you or your representatives as
soon as possible.
Sincerely,
Tom Harris,
B. Eng., M. Eng. (thermofluids)
Executive Director
Natural Resources Stewardship Project
P.O. Box 23013
Ottawa, Ontario K2A 4E2
Phone: 613-234-4487
Web: www.nrsp.com
Cc: Timothy F. Ball, PhD
Chairman, Natural Resources Stewardship Project
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