Public Letter Regarding Proposed Changes to Open Burning Smoke Control Regulation

Dear Mr. Kellerhaus:

My name is Jay Gilden and I am from Smithers. Yesterday, I attended the webinar that your office held about the proposed changes to the OBSCR rules. I am part of a group here called Clean Air Now.

As the Town of Smithers and others here have expressed to your office on a number of occasions, area residents are concerned about the apparent weakening of the rules that is contained in the various recent proposed OBSCR changes as they apply to so-called low sensitivity zones. Under those changes, these zones start, as a rule of thumb, approximately 20 kms. from towns such as Smithers. Yet, our air is affected by slash burns taking place as far away as 100 kms. or more. In fact, very little industrial slash burning is occurring within 20 kms. (let alone within the 10 kms. radius that is set out in the proposed changes for the high sensitivity zones) because logging within that radius is rare. Notwithstanding this distance between the town and the burns, each autumn, we experience serious smoke pollution events due to industrial slash burning.

You stated during the webinar that the actual locations of the zone areas will depend on air sheds and that maps identifying the locations of the zones will be released at some point in the future. It seems to me that we cannot possibly determine whether the proposed changes will do further harm to our air pollution problems until we see the maps. In the unlikely event that the high sensitivity zone around Smithers is set broadly enough to control most of the slash burning affecting our air quality, the proposed changes will at least make matters slightly better by reducing the burn duration limit. If not, the proposal will lead to no improvement and perhaps a worsening of an already bad situation. We can tell you with certainty that a 20 km. radius limit for our high and medium sensitivity zones will result in serious adverse consequences.

I did ask during the seminar, as did another participant, when the maps will be available, but you did not have an answer. Since you state that comments on the proposed changes should be submitted within 6 weeks, we hope that the maps will be released as soon as possible. Otherwise, we will be without sufficient information to be able to evaluate the likely impact of the rule changes.

Jay Gilden