Comments re: Pefferlaw Peat…

Comments re: Pefferlaw Peat Products Inc. ECA application

A copy of the ECA application provided by the Ministry as the only supporting document, is heavily redacted, which compromises the ability to undertake a fulsome review and assessment of the ECA proposal. Information in an ECA application cannot be considered proprietary; the public has a right to see all information related to the application. Further, the ECA application fails to meet basic requirements by not providing all the required reports, documents and information.

How can an appropriate assessment be made and relevant comments provided without all information related to the ECA proposal? I am formally requesting the Ministry to provide a full and unredacted version of the ECA application and that the EBR comment period ending on September 1st, 2025, be extended to facilitate a valid public review.

The unredacted portions of the ECA application provide very limited information in terms of how the site will be operated and the assessment and mitigation of environmental impacts. In particular, the Design and Operations (D&O) report does not address how the operations will be designed and operated to meet the “Guideline for Production of Compost in Ontario and Compost Standard Quality” (Guideline). The information provided is very general and vague.

Specific comments:

1. The ECA application suggests that only a D&O report is required and that: stormwater management report, hydrogeological report, odour impact assessment and odour management and control plan are not required or optional. This is incorrect and the current ECA application should be deemed incomplete and rejected.
2. The D&O information does not adequately address the procedures and steps outlined in the Guideline (e.g. moisture, temperature, foreign content etc.). Information provided is vague.
3. Groundwater and surface water contamination from leachate is a major environmental impact and the lack of information is a critical failure of this application.
4. Odour mitigation. Additional details on odour mitigation and contingency plans are needed. Information provided is vague.
5. Litter control. There is no mention of actions to control litter, including litter pick up frequency or mitigation measures. Additional details are required.
6. Dust control. Indicated that they are in place on site, but do not provide details.
7. Noise control. Additional details on equipment that will be used is required to make this assessment. Has any modelling been completed to support statements? Information provided is vague.
8. Fire control. There is no reference to any equipment to support fire suppression nor any additional information on how it will be used across this large site?
9. Flooding. Details are redacted.
10. Contingency measures. No information provided.
11. Compost testing. Limited information is provided in Section 5 of the D&O. The language used implies the site is already operational although in the absence of a O. Reg 101 notification and documentation and with no ECA issued, the site appears to be operating illegally and therefore any reference to current site operations in this ECA application is not appropriate.
12. Drawings. There is a natural spring pond on the site. There does not appear to be any detail on how this will be protected.
13. Financial assurance. Relevant details are redacted but should be available for public review as an integral part of the EBR process