June 28, 2021 Comments…

June 28, 2021

Comments regarding:

Submission by Dwayne Wilson of The Stool Bus, Environmental Compliance Approval (waste)
(taxonomy/term/376)
ERO: 019-3689
Ministry Reference Number: 9451-BYCS9G
Proposal
Comment period: May 20, 2021 to July 4, 2021

To Whom It May Concern:

Thank you for considering my concerns about this proposal to spread raw untreated human sewage on a property in Strathroy-Caradoc Township.

These are my concerns:

1. There is no Environmental Assessment planned within this proposal to ascertain:

the water table height,
the slope of the property toward the existing drain,
the highest high water mark of the drain which crosses this property, or
the types & distribution of soils that make up this property.

Having lived beside a drain, as recently as January 2020, I have witnessed the water level go up by 6 feet with an unexpected & heavy series of rainstorms. This overflow caused massive puddling on the lawns of our dwelling.

Raw human sewage being spread upstream from our location would undoubtedly at some point cause contaminated fluids to be deposited onto our property during flooding.

2. Currently there are herons, ducks, muskrats, beavers & other wildlife drinking & swimming in the drain adjacent to our property. Untreated sewage has the potential to endanger the health & lives of these creatures, even in small concentrations.

3. The proposal states that “no unnecessary off-site effects, such as vermin, vectors, odour, dust, litter, noise or traffic, result from the operation of this site”. There has recently been a pond dug right by the road on the property in question, and presumably this will be the dumping site to assist in making the manure spreadable. Truck traffic will increase absolutely for the neighbours who live across the road & directly east of the property on both sides. Odours will also undoubtedly develop as a result of having the pond right at the road, for neighbours established nearby.

Who defines the word “unnecessary” in the above quote?

4. Another concern is that the approval appears to be something that is given before the procedures for operation of the site are developed. The proposal uses very vague language, which I would assume is already defined elsewhere with the Ministry of the Environment. Examples of the vagueness that concerns me are:

- “spills of a pollutant that cause or may cause an adverse effect are to be reported to the Ministry’s Spills Action Centre…”
- how quickly is such reporting expected to occur?
- how is the compliance with such a plan monitored?

- “…and the company shall take appropriate remedial action to limit the impact”
- who determines what is appropriate remedial action?
- who ensures that the action is timely?
- limiting the impact is one aspect of responding to a spill. What about restoration of damaged areas/natural settings? Planning to spread untreated sewage comes with risks which the business should bear totally when failure occurs, in my opinion.

5. The proposal does not appear to limit who uses the property as a dump site. Is the site to be used exclusively by The Stool Bus?

6. There is a clause which states “the approval sets out a maximum spreading rate…” however it doesn’t define if a dump pile will be held on the property awaiting spreading. Seepage of a dump pile is a concern as well.

The land in this region of Southwestern Ontario is low, with drainage ditches all over the place. The water table is quite near the surface in some areas, with clay in some areas as well. Like ourselves, most people get their drinking water from wells, which could be polluted by the practice of spreading untreated human sewage. Yes, individuals with wells are using various methods to purify their well water, but we have no idea what bacteria & pollutants we might have to contend with in this situation.

Who will inform us & protect us but the environment ministry?

I hope that you’ll do a detailed & thorough environmental assessment before allowing this proposal to proceed. The site is far from towns & cities, but allowing untreated sewage to be spread on low lying ground with a drain running across it has the potential to risk the health & comfort of people & nature that have lived in the area & downstream from the site for eons.

Thank you again for considering my concerns.