MacGregor Concrete Products …

ERO number

019-4126

Comment ID

58503

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

MacGregor Concrete Products (Beachburg) Limited - Environmental Compliance Approval (waste)
Instrument type: Environmental Compliance Approval (waste)
ERO number: 019-4126
Ministry reference number: 7116-C25M9R

Regarding Ministry of Environment, Conservation, and Parks (MECP):

The application appears to meet the regulations of MECP however there are several areas that could be challenged, such as 200-250 distance to water. The area where the dumping/spreading takes place could be classified as marshland. During the spring run-off the area is subject to water pooling and there are various marshland aquatic plants. This pooling also occurs during heavy rainfalls during the summer months. This leads to the conclusion the runoff from the dumping/spreading area is contaminating the water which in turn drains into the waterways eventually ending up in the Ottawa River.

Another area that is suspect is the soil permeability which is indicated at 8 – 20 minutes; however there is no evidence provided proving this is accurate.

We contend that Ministry of Environment, Conservation and Parks (MECP) should insist the applicant/proponent provide studies from a licensed firm approved by MECP. We suggest there should be studies to ensure the safety of the environment at the Applicant/Proponents expense:

1) Record and evaluation of the site condition;
2) Environmental compliance which would confirm the soil permeability and the drainage factors.

We would think that MECP would require this as we are sure that MECP does not wish to be in a “Walkerton” scenario where there was an independent Commission set up under the Ontario Public Inquiries Act to examine the E.coli (human waste) contamination of the water supply, individuals that signed off were found negligent and punishments were handed out to the individuals that were negligent in their duties.

There is no indication the Applicant/Proponent requested approval from other Ministries such as Minister of Agriculture, Food and Rural Affairs or Ministry of Northern Development, Mines, Natural Resources and Forestry. To our knowledge the Applicant/Proponent did not contact either the Renfrew County or the Township of Whitewater Region. This lack of contact does not relieve the Applicant/Proponent of meeting the requirements of these Ministries and Local Authorities.

In terms of the Renfrew County and the Renfrew County official plan there are two areas where we believe the application is non-compliant. The Renfrew County official plan states:

- Specifies that sites shall be located so that pollution of any watercourse or ground water does not occur;

Comment: The location of the dumping/spreading site is located in a marshland area. This will lead to pollution from the site during the spring snow melt and during the year when several days of heavy rain occur. We feel this makes the application non-compliant.

- Requires that sites be adequately screened, fenced and posted including all open storage areas and disposal site operation.

Comment: The site is not screened, fenced or posted. The application is therefore not in compliance with the Renfrew County Official Plan.

Considering the Township of Whitewater Region zoning by-laws which are based on the Renfrew County Official Plan there are issues with setbacks. The Township of Whitewater Region zoning by-laws state:

i. Two hundred (200) metres of any dwelling on another lot;

• Comment: On the maps provided by the applicant/proponent there are two properties adjacent to the dumping/spreading area, 325 Pappin Road and a seasonal dwelling with a dug well not indicated. As the properties are not indicated on the maps provided but from local knowledge it appears the distance from the dumping/spreading area is less than 200 metres from the seasonal dwelling which would make the application non-compliant.

iii. One hundred fifty (150) metres of any uncased well;

• Comment: As the properties are not indicated on the maps provided but from local knowledge it appears the distance from the dumping/spreading area is less than 200 metres and could even be less than 150 metres from the seasonal dwelling with an uncased well which would make the application non-compliant. It is our understanding the seasonal dwelling owner has requested a site visit from the MECP office in Ottawa.

v. One hundred eighty (180) metres of any surface water;

• Comment: As the properties are not indicated on the maps provided but from local knowledge it appears the distance from the dumping/spreading area is less than 200 metres from the seasonal dwelling and the marshland which during the spring snow melt and during the year when several days of heavy rain occur ponding occurs which leads to pollution and the possibility of E-coli pollution. This would make the application non-compliant. It is our understanding the seasonal dwelling owner has requested a site visit from the MECP office in Ottawa.

Supporting documents