This letter was sent to The Globe and Mail in response to the following article:


Air Pollution! Water pollution! Traffic Horrors! Impact on Wildlife! Noise!

There is no positive reason to allow a quarry of this magnitude to be developed in this area. It will be of no benefit to area residents nor to any of the cottagers or tourists who frequent this area. The carnage it will have on the environment will be irreparable. Despite claims by the proponents and their paid advisors, no one person can be sure that this pit and quarry will not have significant environmental impact on the water quality of Skeleton Lake. Shouldn’t our goal be to try to preserve this unique area for generations to come so that they can interact with nature, recreation, and history in a positive way. Our ancestors had the foresight to classify this area as environmentally sensitive. That is the way it should remain.

Personally, we have owned property on Long Point Road, Skeleton Lake since 1952. Our cottage , built in 1979, is on a small, shallow bay. The stream that feeds into this bay has its beginnings at the proposed quarry site. Any pollutants-airborne or by water- from this site will have detrimental effects on the water of this bay, and the fish , turtles, ducks, herons , loons and the people who make their home here.

In addition, given the expected increase in the massive trucks using Muskoka Road3, we will cease to be able to enjoy the peace and quiet. Already, the sound of traffic is clearly heard as the vehicles contend with the hills on the road directly across the bay. What happens when you have an extra 100 trucks a day? This proposed quarry (less than 2 km distance) will not be just gravel pit but a quarry where there will be blasting of bedrock that will make the ground shutter and the non-stop noise of huge machines grinding it into small pieces. The proposal states that this operation will be seven days a week from May to November for the next 50+ years.

For over 60 years , we have paid mega taxes to enjoy our cottage and property. Is it going to be destroyed by greed and lack of empathy for our environmental gifts?

The proponents of the Lippa Quarry would be transporting their material on Muskoka Road 3 going west through Rosseau and 21 km east towards Huntsville. This is a two way road with curves, hills , blind corners , hidden driveways and gravel shoulders. Large trucks ride the yellow line . It is intimidating for any drivers let alone seniors to continually meet these deadly machines. This road is classified as a “scenic” route. Who will have time to look at the scenery?

Situated about halfway between the pit and Huntsville is the Aspdin Community Centre-originally S.S.# 2 built in 1893. It is a central gathering place for dinners, potlucks, social events, weekly card parties, senior groups, programs for children etc. When large trucks pass , the building rattles making it impossible to hear. What happens when there is a constant flow of huge trucks passing?

The economic gains of one company should not be allowed to cause permanent harm to residents , wildlife and the local tourism industry which has flourished here for decades. This is tourist country not mining country.


Ted & Irene Turner

Huntsville, Ontario




This letter was sent to The Globe and Mail in response to the following article:


To the Editor of the Globe and Mail,

Re:Residents, cottagers in Ontario’s Muskoka region fight quarry proposal near unique Skeleton Lake

We live close to the proposed quarry site in a modest house living a simple life. How will this quarry impact our quality of life, our health and well being? What is the human cost to the many families living nearby?

I do not want health problems from breathing silica dust. I do not want my house shaking and damaged by the blasting. I do not want the animals to disappear. I do not want my well water poisoned. I do not want my peace disturbed by the constant rumbling of gravel trucks by my door.

Perhaps the people who want to build these quarries should be made to live next door to one and experience firsthand the devastating impact it would have.




This letter was sent to The Globe and Mail in response to the following article:


Thank you to John Lorinc for writing an excellent article about the fight to stop the development of a quarry near Skeleton Lake, Muskoka. I just want to elaborate on several of the issues that Mr Lorinc identified in his piece.

My grandfather, Harry Newman, built a cottage on the north shore of Skeleton Lake in 1934, and members of my extended family have been cottaging there ever since. I personally have been visiting this area for more than sixty years, and in this time have seen many changes.

While the water still appears to be exceptionally clear, large blooms of algae have become increasingly common in recent years. A significant increase in phosphorous levels if the quarry goes ahead, as predicted by Gord Miller, would cause this algae problem to escalate rapidly, and to get out of control.

Muskoka Road 3, is proposed as the principal haulage route for the trucks from the quarry, and it runs within 100 metres of the shoreline at Newman’s Bay, where the trucks must climb a steep hill. Truck noise is already a serious problem for permanent residents and cottagers in this area, and the sound travels unimpeded across the lake, and can be heard clearly by cottagers on the southern shore.

Muskoka Road 3 is also designated as a Scenic Corridor in the Official Plan of the Township of Muskoka Lakes. It is a popular route for tourists in cars and buses, on motorcycles, on bicycles, and on foot. The proposed quarry would increase traffic by over 100 trucks per day during the height of the tourist season, a recipe for disaster.

Tourism is a sustainable industry that creates jobs and wealth in Muskoka, and this quarry proposal has very little upside, and a whole lot of downside.

Tom Newman



This letter was sent to The Globe and Mail in response to the following article:


Re Residents, cottagers in Ontario’s Muskoka region fight quarry proposal near unique Skeleton Lake (April 1st):

Imagine a postcard perfect Ontario wilderness lake in front of you. You can drink the water, loons call and swim by in the early morning. How is it possible that one could be so lucky to enjoy such a place, and it still exists? Then a ten or twenty ton gravel truck rumbles down the road behind you, a road categorised as a scenic route through what Muskoka Tourism says is “consistently named as one of the best places to visit in Canada and the world by publications such as National Geographic, Frommer’s and Reader’s Digest. Discover what makes Muskoka so amazing.” Those trucks are already rolling by every day, but for now mostly for a few peak hours in the mornings and evenings, less frequently on the weekends. The proposed quarry near Skeleton Lake would turn up the volume to a constant flow seven days a week, dawn to dusk and beyond. Traffic noise levels now exceed 80 decibels while sitting on the shore. Unfortunately, planners with a lack of foresight never imagined trucks using this scenic route as a shortcut between highway 11 and 400 and placed the road extremely close to Skeleton Lake on the north side. It passes less than 100 feet from many dwellings and the lake. Now they risk making the same mistake again. More than 100 trucks a day could be rumbling by. I don’t think the loons would like that. It might be a bit difficult to discover what makes Muskoka so amazing once phosphorous and mercury levels rise and pollute first Skeleton Lake and then Lakes Muskoka and Rousseau. Oh, but you might never get near the water as the noise and dust from the gravel trucks would scare you (and the loons) away.

I thank you for your excellent article and putting a spotlight on this issue.

Kent Bonkoff
Utterson, ON
(Skeleton Lake)



This letter was sent to The Globe and Mail in response to the following article:


On June 16th at Port Carling, Mr. Frank Lippa, applied to the council of the Township of Muskoka Lakes for permission to open a rock/gravel quarry and pit on Butler Mill Road. This operation would take 200 000 tonnes of material out of the pit annually. This application was unanimously turned down in an open vote by the council of the Township of Muskoka Lakes. Mr. Lippa has applied to go to the Ontario Municipal Board to request that his application for the pit and quarry be accepted as is. If this application is accepted by the OMB, that would mean more than 100 heavy gravel trucks a day would travel on Aspdin Road, (one every 4 1/2 minutes). Some of them would be going east to Huntsville, some would be going west to Rosseau.

There are so many reasons why this application should be turned down.

1. A major concern is for the safety of vehicles, pedestrian and bicyclers on the roads. Heavy gravel trucks are not able to stop on a dime. School buses that are stopped on the road would not have a chance if a gravel truck came around a corner and was not able to stop. There are already a huge number of heavy trucks using this road on a daily basis, such as logging trucks, Muskoka Containerized Services trucks, Panolam trucks, Hutcheson Sand and and Gravel pit trucks, to name a few that use this road. Aspdin Road is not a provincial road and was not built for such heavy traffic. An extra 100 trucks a day would wreak havoc with the road, with visitors, with residents and with the wild life. Not acceptable.

2. Residents, through their taxes, would have to foot the bill for repairs to the road and would have to live with the dangers of living on a road with such heavy truck traffic. Not acceptable.

3. Another major concern is that this pit will be operating below the water table. The water and the pollution from that operation will flow into Skeleton Lake and then on to Lakes Rosseau, Muskoka and Joe. This is simply not acceptable.

4. It is the belief of the directors of the Rosseau Farmers’ Market that this amount of heavy truck traffic will pose a serious risk to pedestrians in the village of Rosseau. The major economic engine in Muskoka is tourism. Rosseau Farmers’ Market draws an average of 3000 visitors on market days. The market is located on Highway 141, which is one of the roads that those huge gravel trucks would use. As it is, Rosseau has very heavy traffic congestion on market days. It is our belief that additional heavy truck traffic would result in accidents and deaths. We very strongly urge the Ontario Municipal Board lakes to deny this application.

Lynnis Royea, Founder of the Rosseau Market

The directors of the Rosseau Farmers’ Market.



The following letter was published here:

An application for a zone and official plan change was made to open a quarry on Muskoka Road 3 between Huntsville and Rosseau.

It was unanimously defeated by the Muskoka Lakes Council and their decision was also unanimously endorsed by the Huntsville Council.

Consequently, Frank Lippa has taken this decision to the Ontario Municipal Board in a bid to have it overturned.

His plan is to put a gravel pit and a rock quarry on Lots 3 and 4, Concession 4 in Cardwell Township.

The quarry is to be allowed to excavate below the water table and to “dewater” the pit into the creek and directly into Skeleton Lake at Long Point, just off MR3.

The quarry will operate 17 to 24 hours a day, seven days a week. He will be crushing granite on the site and stockpiling it for truck removal daily.

This project, if successful, has many serious ramifications for local residents as well as the Muskoka area.

The estimate is for up to 100 truckloads per day going east toward Huntsville or west toward Rosseau. MR3 is the prime road for residents, businesses and school buses as well as for cottagers, tourists, cyclists and walkers with their pets.                                                                               

The quarry is only 1.7 kilometres from Skeleton Lake. The Official Plan for Ontario designates quarries to be close to major highways.  This quarry location is 21 kilometres from Highway 11 at Huntsville and 14 kilometres from Highway 141 at Rosseau, then 20 kilometres more to Highway 400 in Humphrey/Seguin, (a total of 34 kilometres as in Lippa’s report.

The provincial recommendation concerning crushing is that the crushing is to be over two kilometres from a designated shoreline. There are three lakes closer than two kilometres:
Skeleton 1.7 kilometres, Lamberts Lake 0 .8 kilometres and Mudd Lake 0.6 kilometres.

We will only live to regret treating our pristine area as if we were a Third World country. We will pay the cost to repair MR3. This, I believe, will leave the Muskoka taxpayer on the hook because it is a district road.                                         

It is now time for concerned citizens to show their support by attending the meeting at Port Carling on Feb. 21 at the municipal office at 10 a.m. Your appearance will help support those who are fighting to prevent this industrial development in tourist country and our homes.

If anyone would like to have more information or is willing to help with our cause please do not hesitate to call.


Ross Earl,



John Earl,


January 18, 2018

To: SLCO Members

Re:  Status Update #2 – Proposed Lippa Pit and Quarry

With 2018 underway, I wanted to send you an update on the actions the SLCO Board and our lawyer, David Donnelly, have taken with respect to opposing the proposed Lippa pit and quarry.

We have retained a number of experts to help us prepare our case for the OMB hearing.  We have already received a preliminary report from a traffic safety expert, who has identified a number of issues that would arise on Aspdin Road as a result of the heavy truck traffic that would be generated by the quarry operations.

We are also meeting this week with David Pink, Director of Planning for the Township of Muskoka Lakes.  As you know, Township Council unanimously rejected Lippa’s re-zoning application for the quarry, and we are working with David to co-ordinate our opposition.  

A reminder that a pre-hearing conference will be held on Wednesday, February 21, 2018.  The purpose of this conference is to determine the issues, parties, and participants prior to the actual Ontario Municipal Board (OMB) hearing, which is expected to take place later this year or early 2019.  As David has advised, a strong turnout from residents and cottagers who are opposed to the proposed pit and quarry is important at the pre-hearing conference.  Thus, please mark Wednesday, February 21, at 10:00 am at the Township of Muskoka Lakes Council Chambers in Port Carling on your calendar, and plan to attend if possible. 

In the interim, we encourage all members to go to the SMP website ( and sign the petition opposing the Lippa quarry.  The petition represents the voice of many in the community.  There are now almost 2,000 signatures on it!

As communicated last month, SLCO has sufficient funds to meet both the legal and expert costs it is currently incurring, up until the pre-hearing conference.  However, substantial additional monies will be required if we are to succeed at the subsequent OMB hearing.  Our intention is to launch a fundraising effort over the next few months. 

We will continue to keep you informed on this important issue.  We appreciate your ongoing support as we work hard to keep Skeleton Lake the special place we all enjoy.

As always, please feel free to contact me with any questions you may have.


Scott May, President

Skeleton Lake Cottagers Organization


c:   416 559 2839



December 17, 2017

To:  SLCO Members

Re:  Status Update of Proposed Lippa Pit and Quarry

A brief note to keep you informed on the status of the proposed Lippa pit and quarry:

As many of you are aware, SLCO and the “Stop Muskoka Pit” group have been working together to oppose a 200,000 tonne/year pit and quarry that Frank Lippa is proposing to develop at a site 1.7 km from Skeleton Lake.  In June of this year, the Township of Muskoka Lakes Council voted unanimously to deny Mr. Lippa’s rezoning application, in response to concerns raised about the impaired water quality, noise, and traffic that would result from such an operation.  Mr. Lippa subsequently filed an appeal to the Ontario Municipal Board (OMB).  In response, SLCO has retained external counsel (David Donnelly) and various experts to assist us in opposing Mr. Lippa’s appeal.

Last week, we received some new information about the OMB Lippa appeal hearing.  Specifically, a pre-hearing conference will be held on Wednesday, February 21.  The purpose of this conference is to determine the issues, parties, and participants prior to the actual OMB hearing, which is expected to take place next summer.  As David advises, a strong turnout from residents and cottagers who are opposed to the proposed quarry will be important at the pre-hearing conference.  Thus, please mark Wednesday, February 21, 10:00 am at the Township of Muskoka Lakes Council Chambers in Port Carling on your calendar, and plan to attend if possible. 

Fortunately, SLCO has sufficient funds on hand to meet the legal and expert costs it is incurring, up until the pre-hearing conference.  However, substantial additional monies will be needed if we are to mount a successful opposition at the subsequent OMB hearing.  Our intention is to launch a significant fundraising effort in the New Year. 

We will continue to keep you informed on this matter, and are confident of your ongoing support as we fight to maintain the pristine water, along with the peace and quiet, that are so central to our enjoyment of Skeleton Lake.

As always, please feel free to contact me with any questions you may have.


Scott May, President

Skeleton Lake Cottagers Organization


c:   416 559 2839



The following letter was submitted by Cathy Malcolmson who was kind enough to share her support for our cause and offer some advice from the “Save the Bala Falls” campaign.


It is so impressive that your community has taken the stand to oppose the proposed quarry at Skeleton Lake. I believe we all have a responsibility to protect our Muskoka environment and ensure development doesn’t occur in locations that will negatively impact our ecosystem.

Over the past 11 years I have been involved supporting Save The Bala Falls in trying to stop the development of the Hydro Generating plant at the Bala Falls. Our community rallied together to stop this plant and it was very disheartening to see construction trucks roll into Bala in August. We fought hard, and continue to do so, but I wonder if we would have had a different outcome if the urgency we felt in 2016 had of been the same in 2006. Many people felt the plant would never be built as common sense would prevail. That doesn’t seem to have been the case. Because of being such a small community, we needed every voice to be heard and we needed everyone to be loud.

Every signature, letter, telephone call and dollar helps. We wanted everyone in the community to take a vested interest, and take action to stop the generating plant. That truly does take all residents – permanent or seasonal, and every friend you can acquire from outside the community.

Our community activities were developed over time. If all of these had been implemented from the start, it may have caused a better outcome. Call on the community to share their expertise – engineering, environmental expertise, legal, public relations, government contacts, public speaking, and fund raising. Send letters, sign petitions and make phone calls. Consider hosting fund raising events, running public awareness booths and selling merchandise such as T-shirts. Car stickers and lawn signs at home will help to bring awareness outside the community.

I hope your community is successful in stopping this quarry. All the best!

Cathy Malcolmson


















July 10. 2017



Ministry of Natural Resources and Forestry​​​
Parry Sound District, Bracebridge Field office​​​
Ministry of Natural Resources and Forestry
1350 High Falls Road,​​​​​​
Bracebridge, ON, P1L 1W9

Attention: Jeff Schosser, Aggregates Inspector/Specialist​​


Frank and Elizabeth Lippa
c/o Skelton Brumwell & Associates Inc.
​​​93 Bell Farm Road, Suite 107
Barrie, Ontario
​​​​​L4M 5G1

Attention: Caitlin Port, RPP


Letter of Objection Regarding: Proposed Quarry
1089 Butler Mill Road, Rosseau, ON
North Half of Lot 4 and Part of Lots 4 and 3, Concession 4, Geographic Township of Cardwell,
Township of Muskoka Lakes, District of Municipality of Muskoka

I have several concerns regarding the proposed quarry, but here I will focus primarily on releases to air and to water.
The limits that the province will apply to releases from the quarry are not known to us at this time, but are to be established after the current application has been approved by MNRF. Limits for releases to water will be part of the Environmental Compliance Approval (ECA) for industrial sewage works, and the Permit to Take Water (PTTW), both issued by MOECC. Air emissions may be controlled under Ontario Regulation 319/05, implemented by MOECC, and procedures, but not limits, for control of dust emissions are stipulated in the Aggregate Resources Act.
It is my belief, in fact my knowledge, that these limits to releases will fail to protect the local environment and the health of those living there. How can I say this when I have not yet seen these limits ?
I say this because I spent much of my career, spanning more that 30 years, as a professional engineer with Environment Canada, developing standards for releases to air and water from a range of industrial activities. Over that time it became increasingly clear that the way these release standards, best practices etc. were developed precluded them being adequately protective of the environment and health. Let me be clear, it is not just some particular type or group of release standards that is flawed, it is the way they are developed, and in fact their very nature that is flawed. And this applies not just to release standards in Ontario, or Canada, but also in the U.S. and generally in the western world.
A summary discussion of how and why release standards are flawed is presented in the addendum to this note.
The “bottom line” on release standards is that we should not fall into the trap of believing that because any particular enterprise will meet “all the appropriate environmental standards”, it will necessarily be safe for the environment and for health. This problem with release standards is not meant as a criticism of my former colleagues at the MOECC, MNRF, Environment Canada or any other regulatory organization. The problem is the way western society as a whole deals with protection of the environment and health.
Should it seem that I wish to stop all industrial development in order to protect environment and health, I can assure you that the truth is vastly different. My opinion is that much of the industrial development of the past could have gone ahead without major problems to the environment, health or the economy if we had “gotten it right” on controlling releases. And much of the development foreseen for the future could go ahead if we get it right starting now. We need to do this to protect our future and that of our children and grandchildren.
And “getting it right” is not a matter of dream or fantasy. Many of the aspects of “getting it right” have been thoroughly researched, debated and largely agreed upon for many years by scientists, engineers, economists and legal experts. Some of these aspects include the precautionary principle, cumulative effects assessment and full life-cycle cost accountability. What is lacking is primarily the political will to put these into effect at the senior political and ultimately global level.
So what to do about the proposed Lippa Quarry ?
I expect that others have addressed or will address the potential, not quantified as yet, but likely present to some degree, for releases of suspended particulate matter, heavy metals, phosphorus and perhaps other contaminants in the mine dewatering releases, and the releases of very fine respirable particulates including PM 10 and PM2.5, in the fugitive dust emissions from the quarry. PM 10 and PM2.5 are known carcinogens that have well-documented health impacts, no safe exposure levels, and can be transported long distances in the atmosphere. Where there is potential for such harmful releases and there are sensitive environments such as Skeleton Lake and human populations nearby, there are only two reasonable options:
1. At the very least, make approval contingent upon the implementation of exemplary controls on releases. These controls should go far beyond achievement of current release standards and be accompanied by rigorous monitoring to ensure that releases are in fact being kept to “at background” levels in all conditions, including off-standard or unexpected circumstances. Failure to achieve such control on releases should be grounds for withdrawal of permission to operate. If it is not possible to ensure such control, then approval should be denied.
2. Deny the application outright, based on its proximity to sensitive environments and populations.
I submit to you that option 2. is the more appropriate option for MNRF.

Geoff Ross


Why are release standards not adequately protective of the environment and health ??
1. Release standards are most often based on the premise that the concentration or quantity of releases can be reduced to levels at which there is no clear evidence of damage to the environment or health. This premise is flawed in at least two important ways:
a) The rigour of scientific methods is such that it usually takes a very long time to develop conclusive evidence that some level of releases will in fact cause damage. Strong (but not conclusive) evidence of damage may exist, but this is rarely enough to result in limits to releases. The stringency of any release limits to be implemented will, at best, be subject to the scientific certainty supporting them. This usually develops in stages, supporting more stringent release limits as the science becomes more conclusive over time. Our society has been reluctant to embrace the precautionary principle, which would support more stringent release limits where it is likely, but not conclusively proven, that damage will occur. So release limits based on rigorous science are associated with serious time delays in responding to problems.
The following are just some of the more prominent of the many examples of where this approach has allowed problems to become serious before greater control of releases is required.
Atmospheric deposition of acidic pollutants, commonly known as acid rain, has caused countless billions of dollars worth of impacts on health and the environment, and has resulted in industry and society as a whole spending many billions to try to correct the problem. Much of this could have been avoided had we gotten releases of acid gases effectively under control in the early days. We could have, but we didn’t. And though we now have release standards that have reduced the severity of the problem, we haven’t solved it. The release standards approach is not good enough. New manifestations of the acid rain problem, such as calcium depletion in soils and lakes, are becoming apparent and will likely continue to impose severe costs on society.
Ozone and fine particulates in the air we breathe, commonly known as “smog” continue to cost billions of dollars per year in health damage alone in Ontario. The pollutants that cause smog, their sources and ways to control them, have been known for a very long time. Standards to control these emissions have been a more recent development, and emissions from some sources have declined by as much as 99%, but the problem is still far from solved. The health damage continues. The standards approach is not good enough.
Mercury releases from chlor-alkali plants associated with pulp and paper led to such severe problems with mercury in fish, and the consequent health impacts on those eating fish, that the plants were ultimately shut down. This is one example of where it was actually recognized that release standards were not going to suffice; shut-down was the only answer. The river systems are still seriously damaged. But mercury in fish is currently a problem in waters not touched by chlor-alkali plants. The mercury is in large part coming from power plants and smelters throughout North America and in fact the world. Emission standards for such plants have not, at least until very recently, even addressed mercury.
b) Some substances have no threshold for impacts on the environment or health. That is to say, there is no level at which the substance has no impact. Silica dust, in the form of respirable particulate matter such as is released from quarrying operations, is one of these substances. Releases of silica dust are commonly referred to as “fugitive emissions”, meaning that they have escaped whatever control measures are in place, often because they come from a number of dispersed and difficult to control points. Very small particles can be transported substantial distances . Thus, control measures, such as water sprays, or point of impingement standards at the quarry boundary, do not ensure safety for the environment or health in areas adjacent to points of release. The only thing that can reasonably be done is to ensure that points of release of such substances are separated by substantial distances from sensitive environments and human populations.
2. Where release standards have been developed they have rarely been developed based on environmental or health impacts. Generally they have been based on applying a degree of control that has been demonstrated to be technically and economically feasible. In other words, “we know how to do it and it won’t cost too much”. Thus, the release standards are not necessarily related in any way to impacts on environment or health. Without solid data on the environmental or health costs of releases, the release standards and the technology necessary to achieve them can be seriously compromised by arguments that they are too expensive. And so, if they exist at all, the release standards are likely to represent what is felt to be a “reasonable” level of effort to control releases. Our experience has been that in nearly all cases this level of effort has over time been found to be not enough. Note that this trend is unidirectional, i.e. it is always found that we need to further reduce our releases; I know of no examples of the reverse for major environmental issues.
3. Where release standards have been developed for a substance they are nearly always applied to one source at a time and fail to address the cumulative environmental and health impacts of releases of the same substance from other sources. A number of sources, each of which may be controlled to the point where their impacts are too small to measure, may in total be causing serious problems.
4. The release standards in nearly all cases fail to deal with the fact that the costs of controlling releases are not the same for all sources. As a result some individual sources will face much higher control costs than others. These will generally become the reference point for not requiring further control in order to avoid “excessive” costs. But overall costs could be reduced and greater control of releases achieved more efficiently by going beyond release standards. The closest Ontario has come to this has been in the “Countdown Acid Rain” program, where emission caps were placed on smelters and power plants, leaving Ontario Hydro (at that time) to determine where (at which plants) releases could be reduced to meet the overall cap at least cost. But even this program failed to provide any monetary incentive to reduce beyond the level of the Ontario Hydro cap. The U.S. went a step further with their system of SO2 emission caps for power plants, but even it failed to provide incentives for reductions below the overall cap. Ultimately, Ontario phased-out coal-fired power generation in recognition of the environmental costs of its acid gas, smog precursor, mercury and CO2 emissions. But this came after spending $billions on the release standards approach.
5. Release standards are never developed for all sources of a substance, but usually only for the major and most “visible” sources and those most amenable to source control. The fact that there are no release limits for a source does not indicate that it poses no threat to the environment and health.