Comment
To the Ministry of the Environment, Conservation and Parks:
I am writing to express my strong objection to the proposed Environmental Compliance Approval (ECA) for Stubbe's Redi-Mix Inc. (ERO # 025-1424) in Harley, Ontario. As a resident of New Durham, I am deeply concerned by the removal of critical environmental protections present in the current approval (ECA # 9324-D3DPJS).
1. Omission of Respirable Silica
The current ECA (# 9324-D3DPJS) explicitly identifies respirable silica as a contaminant emission. However, the new proposal (025-1424) omits silica entirely. Respirable silica is a known carcinogen and causes irreversible lung disease (silicosis). Given the facility's plans for concrete crushing—a high-risk activity for silica dust—removing this contaminant from the list of monitored substances is a direct threat to public health.
2. Missing Fugitive Emission Sources
The new proposal fails to list "material handling," "storage piles," and "fugitive emissions" as primary sources, all of which are strictly regulated under the existing approval. Fugitive dust from these sources is a major concern for the surrounding hamlet. I request that the Ministry maintain the strict "30-meter visible plume" limit and the "minimum separation distance lines" requirement found in Condition 4 of the current ECA.
3. Concerns Over "Limited Operational Flexibility"
The proposal seeks "Limited Operational Flexibility," which may allow the facility to add new equipment or modify processes (like concrete crushing) without further public consultation. This flexibility is unacceptable given the proximity to residential areas and the sensitive nature of the local environment.
Conclusion:
I request that the Ministry reject this proposal until "respirable silica" is reinstated as a tracked contaminant and "fugitive emissions" from storage piles are explicitly included as regulated sources. The health of the New Durham community must come before operational convenience.
Submitted January 29, 2026 10:24 PM
Comment on
Stubbe's Redi-Mix Inc. - Environmental Compliance Approval (air)
ERO number
025-1424
Comment ID
182307
Commenting on behalf of
Comment status