To whom it may concern: Does…

To whom it may concern:
Does this site currently have any approval to receive and compost leaf and yard waste?

This ECA application, in particular the Design and Operations report (D&O), implies that this site is already operational.

To my knowledge, this site currently does not have an Environmental Compliance Approval (ECA). Further, this site, quite clearly, does not conform to O. Reg. 101/94 requirements (i.e., setbacks etc.) and cannot be operating on that basis.

It appears that this site is currently receiving upwards of 30,000 tonnes/year of leaf and yard waste. Thus, it appears that the proponent has failed to secure the appropriate environmental approvals for current site operations.

How can a site that allegedly appears to be operating illegally even be considered for an ECA while the allegedly illegal operation continues?

The ECA application includes communications from the MECP District Office expressing compliance concerns. The lack of adhering to regulatory and application requirements is concerning as to whether the proponent will adhere or meet their current and future environmental and regulatory responsibilities.

The Director can reject this ECA application or impose conditions based on historical non-compliance. Given this historical disregard, consideration should be given to refusal of the application or imposition of additional stringent conditions to ensure protection to the environment and human health is met. Finally, if the site is operating without environmental approvals, it should cease operations until such approvals have been received.