I have concerns about the…

I have concerns about the application for an amendment to the Evolve Recycling (“Evolve”) Environmental Compliance Approval (No. 3642-7XXQ9Q). The location of the facility is 321 Henry Street, Brantford. My concerns about the amendment application are as follows:

1. Storage Areas
The capability of Evolve to store tires on site should be closely assessed. This site has been used by many companies in the past and outdoor tire storage has always been an issue, especially with respect to fire code requirements.

Considering the limited outdoor storage at the Site and the restrictions for outdoor storage under the Ontario Fire Code, careful consideration should be given before granting this company the ability to expand its outdoor storage.

2. Fires and the Ontario Fire Code
There have been fire code violations at this site in the past as well as actual fires, in 2013, 2015, and in 2019 (see below).

Figure 1: Brantford Expositor File from June 9th 2019 at 321 Henry Street Facility
It is critical that the Ontario Fire Code requirements be enforced at this property. Arguably, the facility should go above and beyond the minimum required specified in the Fire Code due to the history of fires at this location.

3. Traffic Flow
The proponent should be required to do a traffic study for vehicles entering the Site, especially vehicles making a left-hand turn into the Site from Henry Street. This is likely the most common approach to the Site as the Greater Toronto Area is east of the facility and trucks from the GTA will arrive at the Site via Highway 403, Garden Avenue and then westbound on Henry Street.
Figure 2: Google Aerial View of Evolve Facility and Henry Street
Henry Street is a major east-west throughfare that handles lots of industrial traffic. There may be instances when a number of tractor-trailers arrive at the facility at the same time and backup traffic on Henry Street, potentially blocking access to Middleton Street and also backing up to Adams Boulevard/Empey Street.

4. Revolving Door of Ownership
Evolve Recycling is the latest in a string of companies that have processed tires at this Site. Previous owners have included Nexxsource, Liberty Tire, and High Tread International of Canada Ltd.

There should be some consideration given by the Environment Ministry on the operational history at the site. It could be argued that previous management teams had great difficulty operating the facility and keeping it in environmental compliance. A record of environmental compliance under the existing ECA should be required prior to any consideration of modification.