Dear Mr. Coelho: As an…

Dear Mr. Coelho:

As an investor in Ontario innovation and contributor to Ontario’s cleantech community, Anaergia DB Inc. (“Anaergia”) welcomes the opportunity to comment on the Ministry of the Environment, Conservation and Parks’ (MECP) Draft Land Use Compatibility Guideline (ERO Posting 019-2785).

Anaergia recognizes the effort required by the MECP to develop technical guidance for the land use planning process. We also support the MECP in making changes to modernize regulations in keeping with the province’s commitment to red tape reduction. Effective land use planning and the streamlining of the approvals process can support business continuity and growth while protecting the autonomy and quality of life in our surrounding communities. Regulatory changes, however, that are ambiguous and those that diverge from being science and/or evidence based, unnecessarily increase risk for project developers. Unpredictability will impede innovation and investment.

As private sector investors in waste recovery innovation and project development, developers of clean technologies, and builders of critical waste infrastructure, we have some concerns regarding the draft Land Use Compatibility Guideline and how it will be interpreted and applied. Our three (3) predominant and specific concerns are summarized in the list below.

1. The Land Use Compatibility Guideline may negatively impact the ability for new projects to be incorporated onto existing sites or waste facilities, such as the incorporation or expansion of anaerobic digestion (AD) at wastewater treatment plants (WWTPs).

2. The majority of the burden of mitigation measures may be placed on the major facilities rather than the sensitive land uses, even in cases where sensitive land uses are proposed near existing major facilities.

3. In highly populated areas where it may be more likely for sensitive land uses to be placed within a major facility’s AOI due to a higher likelihood of demonstrating need for those locations, major facilities will most likely get more complaints from nearby residents.

Prior to finalizing and adopting the Land Use Compatibility Guideline, Anaergia requests that the MECP consult with industry and the private sector on the Land Use Compatibility Guideline. If this is not possible, Anaergia would appreciate an opportunity to meet with MECP Environmental Policy Branch staff to better understand the Ministry’s position in advance of Anaergia consulting with local stakeholders on a project-by-project basis.

We thank you for providing Anaergia the opportunity to present this letter to the MECP. We trust the foregoing will be of interest to you and if you have any questions with respect to the information contained herein, please do not hesitate to contact the undersigned.

Sincerely,
Deo Phagoo, P.Eng.
Senior Vice President, Business Development
deo.phagoo@anaergia.com