Dear Client Services and…

Dear Client Services and Permissions Branch,

I am writing regarding ERO notice 025-1350, the proposed amendment to Environmental Compliance Approval No. 6332-A2GNRY for NRK Holdings Inc.'s soil processing facility in Ramara Township. I offer the following comments and concerns regarding this proposal.

1. The increased truck traffic on Monck Road and Highway 169 in Ramara township will result in negative impacts to the community. Increasing the daily capacity from 3000 to 6000 tonnes will result in an increase of 150 to 300 trucks per day (approximately 20 tonnes per tandem dump truck). The result is more traffic congestion, noise, dust and wear and tear on township roads.

2. Expanding the service area to include all of Canada is concerning. Trucking/transporting contaminated soil hundreds to thousands of kilometers across the country will result in unnecessary fuel consumption, greenhouse gas emissions, and increased commercial vehicle traffic on provincial roads. This is especially concerning given the recent spike in commercial vehicle traffic/accidents and deaths on our provincial roads. It is unclear why individual provinces are not responsible to treat their contaminated soil within their own provincial boundaries.

3. It appears the site will now process "liquid soils" although it is not clear in the summary proposal if this is a change to the operation. Although "liquid soils" are not defined in the proposal, I assume these soils would include contaminated soil that is saturated with groundwater/surface water/fuel to the point where the soil would have a slump greater than 150 mm as per O.Reg. 347. Liquid soils are considered liquid industrial waste class. Does the current ECA allow for liquid industrial waste? What provisions are being made to ensure these "liquid soils" are managed in an environmentally protective manner (ie. dewatered liquid treatment/disposal, runoff controls, prevention of liquid leakage from haul trucks, emergency response in event of haul truck spillage/accident)? How will liquids collected during dewatering that are contaminated with contaminants that are not amenable to treatment at the bioremediation facility be dealt with?

4. A recent local newspaper article in Orillia Matters (January 11, 2026) refers to additional changes to the operation that are not outlined in the ERO notice. As per the newspaper article these changes include:

“The inclusion of a transfer station, the acceptance of soil not contaminated with hydrocarbons and/or the acceptance of soils that are not treatable are not permitted in the current Official Plan and zoning for this property,”

Why would untested contaminated soil that may not be able to be treated at the facility be transported across township roads creating unnecessary risk and increased commercial vehicle traffic in the community? Contaminated soils should be tested before being hauled to the facility to ensure that treatment can be achieved at the facility. The inclusion of a transfer station will result in increased commercial vehicle traffic and resultant negative impacts in the township.

Thank you for your consideration of these comments and concerns.