The question before the…

The question before the Ontario government and particularly the Ontario Ministry of Environment and Conservation and Parks with respect to York 1’s proposed use of the Dresden dump site must be addressed based on scientific evidence and not on political hyperbole-I.e. a response to what President Trump may or may not do with imposing any restrictions or additional fees on Ontario waste disposal to the United States.

It is well recognized that Ontario needs more landfill capacity within the Province but is the Dresden site suitable for landfill cell construction? Only properly designed studies with the ability to review and critique such studies will address that need.

That must be the overriding concern with respect to York 1’s proposal. Site suitability must be first and foremost. And the site is already known from prior Ministry of Environment enforcement actions to have been poorly managed in the past prior to York1 purchasing the property.

With the introduction of Bill 5 and the specific mention of York 1 to use the Dresden site for landfill operations and the sole reliance on only allowing York 1 the ECA- Environmental Compliance Approval pathway instead of a full Environmental Assessment that is normally used for landfill development in Ontario;

The question becomes does the ECA-Environmental Compliance Approval pathway provide adequate social-economic and environmental protections for the communities downstream of the site along the Syndeham River, given that Wallaceburg-pop est. 10,000 town water supply would be exposed to any leachate leaks along with the adjacent families depending on water wells near the site location?

Does Bill 5 in removing the previously ordered Full comprehensive environmental assessment by the Ontario Minister of Environment constitute a constitutional rights breech under section 2(b) in denying public involvement, particularly in the ability to access readily the environmental hearing process that the full Environmental Assessment process would ensure?

There is a constitutional obligation by the Ontario government in respect to section 2(b) that needs to be considered in this matter.

With respect, the Ministry of Environment must maintain the ability for proper study design to determine site suitability first, even for the construction of a single landfill cell.

Such a construction for even one landfill cell at the Dresden site should go through the full comprehensive Environmental Assessment process.

Contaminant characterization of the Dresden site has not been done by the Ontario Ministry of Environment to date- whether the construction of a landfill cell; even a single landfill cell by York 1 to remediate the contaminants on the site using a landfill cell will fail to address if the site is suitable to begin with.

This reinforces the need for proper study design and the ability to review and critique such studies and data and if required challenge them in a environmental hearing.

These are serious concerns that must be considered first and foremost and the risk to the environment and residents who are dependent on the adjacent water wells and townspeople of Wallaceburg by only selecting the ECA- Environmental Compliance Approval process can not fully adequately address these risks particularly to site suitability without the consultation and feedback that a full Environmental Assessment would provide and therefore should not be entered into.

It is for these reasons that a Environmental Compliance Assessment is inadequate and the Ministry of Environment and Conservation and Parks must continue with the full implementation of the comprehensive Environmental Assessment as the Ontario Minister of Environment previously announced.