Newsletter, October 10, 2023

October 10, 2023

Key Points Inside:

1. Comments on 2023 Implementation Review of Toronto Noise Bylaw

2. Use the Template Provided to Submit Your Own Comments

Dear Fellow Gasbusters,

As promised in our last newsletter, we're back with our comments on the Noise Bylaw Review in Toronto which is presently being conducted by Municipal Licensing and Standards (MLS).

Gasbusters is dedicated to reducing the adverse health, safety and environmental impacts from gasoline-powered leaf blowers and related lawn care equipment. These are included in the Noise Bylaw Review under Power Devices. We offer the following comments on noise regulation for such equipment. We support the comments of groups such as No More Noise Toronto and Toronto Noise Coalition which address other areas such as amplified sound and vehicle noise.

1. General noise in Toronto has become progressively worse in the last four years.

2. Urban noise is not just a nuisance issue. Urban noise in Toronto is negatively impacting the health of Toronto residents. As far back as 2017, if not before, Toronto urban noise levels exceeded ambient noise limits set to prevent health effects.

Toronto urban noise levels average 63 dBA (24-hour average), with a range from 50 to 78 dBA at specific sites as reported by Toronto’s Medical Officer of Health in the 2017 report, Health Impacts of Environmental Noise.

Recommended ambient noise limits to prevent health effects are:

• 55 dBA average through the day and evening, and 40 dBA at night according to the World Health Organization.

• 55 dBA average during the day, 50 dBA average at night. Ontario Ministry of Environment and Climate Change.

3. Gas-powered leaf blowers are an example of power devices that require regulation to control excessive noise emissions.

Leaf blowers have other negative impacts beyond noise which include emissions of toxic and carcinogenic compounds, harmful airborne particle pollution, pollinator destruction, water pollution, and worsening of climate change.

4. In the Noise Bylaw review's proposed options for greater regulation, we support refinement 3 to Bylaw 591-2.6. Power devices: “Amend definition and add decibel limits.” This is the best option to reduce noise to levels which protect the health of Toronto residents.

5. The main criterion for a bylaw decibel limit for power devices and other sources of noise must be protecting the health of residents, not whether it seems reasonable or practical. Accordingly, any acoustical consultant review must advise on decibel limits which protect the health of Torontonians.

6. We suggest a multi-pronged approach to determining decibel limits for power devices:

• Power devices used in Toronto must meet safe decibel limits defined in relevant manufacturing specifications.

• Restrictions on time, day, and season of use.

• Decibel limits at point of reception where point of reception is defined in terms of where people live (anywhere in their home or on their property) and/or work.

7. Comprehensive, ongoing enforcement of well-crafted noise laws is the only way that urban noise can be reduced sufficiently to protect our health. Enforcement must include adequate and timely inspection by bylaw inspection staff, and significant fines to ensure compliance. Enforcement should not require complainants to testify in court.

8. The noise bylaw should require City of Toronto staff to record all noise complaints received from residents, not just noise complaints which are out of compliance with existing laws. Current laws do not adequately address all unacceptable noise situations. The bylaw should require Staff to provide Councillors with a report summarizing these complaints, on request.

Below is a link to a form that you can download and use to reinforce our message to MLS with your own feedback. Please submit it to mlsfeedback@toronto.ca by October 15, 2023 (this coming Sunday).

https://mcusercontent.com/385430d82a0b1b6115b08219f/files/ebac6734-f730-31c6-0e59- 9e29f6fd26ce/MLS_Feedback_and_Suggestions_Oct._11_2023.04.docx

If you have any questions regarding our submission, please contact us at gasbusterstoronto@gmail.com

Sincerely, Gasbusters Organizing Committe

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