Mr. Dwayne Andrew Wilson…

Mr. Dwayne Andrew Wilson operating as The Stool Bus is proposing to use the property at 6953 Falconbridge Road in Melbourne as a hauled sewage (i.e., raw human waste) disposal site. The intent is to dump waste material from portable toilets, sewage holding tanks and septic systems on the land. We are deeply concerned about the contamination implications that the dumping of raw, untreated sewage will have on us and on our neighbouring environment and waterways.

The goal of the Environmental Registry of Ontario and Ministry of Environment, Conservation and Parks is to protect our province’s water, land, and wildlife, and therefore it is your responsibility to prevent this ill-conceived proposal from being implemented.

There are many concerns why this proposal should not see the light of day. It would not be stewardly to allow this raw sewage disposal site to be implemented. Here are several reasons why:

The Drinking Water Source Protection interactive map https://maps.thamesriver.on.ca/gvh/?viewer=tsrassessmentreport shows that the location in question (6953 Falconbridge Drive in Melbourne) is a designated vulnerable area (i.e., activities may be moderate and low threats), but it also shows under the “Ground Water Recharge and Aquifer Vulnerability” that it is a significant ground water recharge area, and is surrounded by highly vulnerable aquifers. This alone should be enough for the ERO/MECP to realize that a hauled sewage site is unacceptable in this location under these circumstances. This proposal should not have been entertained by the ERO/MECP in the first place.

The proposed disposal site is not zoned for disposal of raw septic waste. It is zoned A1 Agricultural which means it is for agricultural purposes, and there are cattle grazing on adjacent lands. At no time should large amounts of raw untreated sewage be spread on a parcel of land. It should be disposed of at a sewage treatment facility with proper procedures, equipment, testing and oversight. To dump waste on your own property with no arm’s length third party continued oversight would seem to be a conflict of interest.

The proposed property is situated in a floodplain and has 2 creeks (the Augerman Drain and the Pierce Drain) running through it and through adjacent properties. These creeks spill out into the Government Drain No. 1 Extension. The waste could run off into it and contaminate the water, not only on the proposed site but on all the properties adjacent to and downstream from it, especially after heavy rains. In the decade that we have lived in this community the creek has flooded at least twice, covering significant areas of the proposed site and adjacent properties, including cropland. As of April 1, there is water sitting on the land of the property and draining into the creek.

We are also concerned that the depth of the drainage system is too close to the soil surface and the depth of the water table too shallow.

We as people living in rural communities rely on our drinking water from dug water wells, which will most surely be negatively affected. We believe that this proposal is a drinking water threat. The main consideration for reducing or eliminating drinking water threats, as stated by the MECP is to make sure that septage does not enter surface water and/or ground water. With the loading of this property with septage (based on our calculations, 15 liters of raw sewage application per week per square meter on 4.46 hectares of land which equals a total of 44,600 square meters, that would equal 669,000 liters a week X 32 weeks = 21,408,000 liters of raw untreated sewage per year) it seems impossible not to have run-off/seepage into our waterways and should not be allowed. Our ponds, downstream wetlands and waterways, reservoirs and marshes will most surely be polluted as well. These are also the waters that grazing cattle in adjacent and nearby fields drink from. And wildlife (e.g., fish, turtles, deer, and birds) will suffer.

We know that the adjacent property is used for cattle grazing, therefore the proposal would not meet the guidelines of waiting periods for grazing, relating to public health and pathogens. The cattle on adjacent fields will most likely be eating dumped materials (wipes, condoms, feminine hygiene products, prophylactics, etc.) and may get hardware disease. In the end, responsible farmers will take the heat for a non-farmer dumping untreated, raw human waste. If the public knew that the protein they eat or milk they drink is from animals grazing on land that just 3 - 6 months before was used for raw sewage disposal, they would have a fit! The public has a right to know where their food comes from and that it is safe. We personally would not knowingly eat animal protein which grazed on such a site ever after waste application has stopped.

To clarify, this proposal is not the same as a farmer spreading manure on his land, which is limited by volume and done maximum twice a year. The dumping of raw septic human waste here will be continuous (except for winter months), and would also contain a rash of other chemicals, pollutants, pathogens and heavy metals which will accumulate. This is not applying sewage to agricultural land for nutrient management for crop production, this is untreated raw sewage. This is not applying nutrients before or after crop production. This is over-applying raw untreated sewage. This is not agricultural. This is applying raw untreated sewage to dispose of.

The rate of application is also much larger than manure from animals used for nutrient management of fields for crops. This sewage will have pathogens and toxins (such as heavy metals). To give an idea of what the proposed pollutant land application may look like, based on similar proposed disposal sites allowed to spread up to 15 litres per square meter per 7 days between April 1 and November 30 (32 weeks), 32 weeks X 15 litres = 480 litres per square meter by our calculations. Therefore, the volume of allowable raw sewage dumped could be 480 liters per sq. meter, which is equal to 48 cm. deep per year. You would be hard pressed to find a farmer applying (if allowed) more than 10 liters of manure (not portable toilet, sewage holding tank and septic system waste material) per square meter per year (most farmers would spread less than 10 liters per square meter of manure every other year which equals 1 cm. deep).

This whole scenario of bypassing a sewage treatment facility and dumping untreated septage directly on land (not to mention land where creeks are flowing through) seems most absurd. This is comparable to a scenario of going to an oil change/lube shop, having them drain the oil pan carefully into a container and carefully transferring it to a holding tank for proper environmentally sound disposal recycling or treatment, so not to pollute. Then a disposal tanker truck picks up said product, does nothing to it, and instead dumps it on a field somewhere else.

Areas for the recent new housing developments in nearby Mt. Brydges were only granted permission after a full municipal water supply and sanitary sewage disposal service was put in place (maybe even at the directive of the MECP). Part of the reason was that pollutants were found in the water quite far from the town, but were believed to have come from the town itself.

We have come to the point where we as a Strathroy-Caradoc community are trying to reduce the negative impact of sewage affecting our water supply, just to see a proposal that may put raw sewage in our waterways. Dumping of raw sewage negates all efforts that Strathroy-Caradoc has implemented to reduce pollutions of our freshwater systems and aquifers. Will this also not set a precedence where anyone with a septic system would be able to dump their raw sewage on their land?

This type of dump has no place in our municipality or in any other for that matter. There are much better sustainable and environmentally responsible ways to handle this raw sewage since we have treatment facilities readily available that can handle this raw untreated human waste in an environmentally conscious manner, with proper procedures, equipment, testing and oversight.

The MECP recommends the handling of septage in treatment facilities as long as the capacity to treat sewage is available. In making decisions affecting planning matters, municipalities must ensure that their decisions are consistent with the Provincial Policy Statement. The province discourages the application of untreated septage to land if the hauled sewage can be treated or disposed of at an approved treatment facility. Four of the local septic waste companies that were contacted said that they have no problem sending their septic waste to treatment facilities, and have not been denied. It is believed that amendments to RRO 1990, Reg. 347 General – Waste Management, under Environmental Protection Act, RSO 1990, c. E,19 https://www.ontario.ca/laws/regulation/900347 have prohibited land application of untreated waste from portable toilets and septic tanks. The Stool Bus has stated that their profit margin is too small when they properly dispose of waste at a treatment facility. They should charge the customer more, and not bypass treatment facilities.

If the organizations do not perform their fiduciary duty to deny this proposal for the well-being of the environment and the site has problems or becomes contaminated, who will be responsible for cleaning it up? Will you have a strong responsibility agreement with the company? Will you verify adequate liability insurance for future environmental issues (and long after they are gone)? It should not be assumed that in the end the remediation of the site will be done through tax payers’ dollars. There are no positive benefits to the environment or to anyone else (other than financial gain for The Stool Bus), only a slew of negative consequences.

On a personal note, as residents of the Melbourne area community we enjoy our daily walks around our home and property. This proposed dump site will surely ruin this due to odour, pollutants, debris and particulates. This will deeply affect our way of life and our enjoyment of nature and our home, as it will affect everyone in the community. We did not move here to live beside a dump. This will not be close to our regular way of life. The incessant odour (by NASM odour data it would be considered OC3 or higher!) and pollution will ruin our enjoyment of our natural surroundings and home. The environment itself will take a negative turn and we will be reminded every day that our environment and wildlife is being harmed by such an irresponsible plan.

You will also be aware that this type of sewage disposal sites is banned in other progressive areas of Canada.

Please do not enable circumvention of proper environmentally responsible disposal procedures. Let’s not normalize a bad situation. Again, A1 zoning does not extend to this extensive dumping of untreated human waste containing pathogenic bacteria, viruses, heavy metals, etc. As in the proposal, this is a “hauled sewage disposal site” operation; this is not spreading of sewage biosolids from a municipal waste water treatment plant for nutrient management. As a representative of the public, you have the means to put a stop to this, and in the interest of the environment now is the time to act. On behalf of all residents and future generations please ensure that this ill-conceived proposal and others similar in nature do not see the light of day. And please ban future undertakings like these anywhere in Ontario where there is a sewage treatment plant available within a 200 km radius.

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Please look at these excerpts from different ministries and organizations:

St. Clair Region Conservation Authority’s Section 28 Wetland Policy as derived from the Conservation Authorities Act and Ontario Regulation 171/06 https://www.scrca.on.ca/planning-and-regulations/st-clair-region-conser…
“1.1.2.(1) … no person shall undertake development or permit another person to undertake development in or on the areas within the jurisdiction of the Authority that are:
(d) wetlands, or…
(e) other areas where development could interfere with the hydrologic function of a wetland, including areas within 120 meters of all provincially significant wetlands, and areas within 30 metres of all other wetlands;
1.1.3.(1) The Authority may grant permission for development… if the control of flooding, erosion, dynamic beaches, pollution or the conservation of land will not be affected by the development.
1.1.5. … no person shall … change or interfere in any way with a wetland.”
Pollution means: “… any deleterious physical substance or other contaminant that has the potential to be generated by development in an area…”.
Interference in any way is interpreted as: “any anthropogenic act or instance which hinders, disrupts, degrades or impedes in any way the natural features of hydrologic and ecologic functions of a wetland or watercourse”.

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Ontario’s Provincial Policy Statement https://www.ontario.ca/page/provincial-policy-statement-2020
“- IV Taking action to conserve land and resources avoids the need for costly remedial measures to correct problems and supports economic and environmental principles.
- V.1.0 Efficient land use and development patterns support sustainability by promoting strong, liveable, healthy and resilient communities, protecting the environment and public health and safety, and facilitating economic growth.
- 1.6.6.1 Planning for sewage and water services shall (b.) ensure that they are provided in a manner that (4.) protects human health and safety, and the natural environment.
- 2.2.1 Authorities shall protect, improve or restore the quality and quantity of water by (b.) minimizing potential negative impacts, (f.1) protect all municipal drinking water supplies, and (f.2) protect, improve or restore vulnerable surface and ground water features and their hydrologic functions.
- 2.3.1 Prime agricultural areas should be protected for long-term use for agriculture.
- 3.1.2 Site alterations shall not be permitted within a floodway regardless of whether the area of inundation contains high points of land not subject to flooding.”

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Statement of Environmental Values: Ontario Ministry of Agriculture, Food, and Rural Affairs http://omafra.gov.on.ca/english/about/state-env-values.htm
“Purposes of the Act are:
-To protect, conserve and where reasonable, restore the integrity of the environment by the means provided in the Act;
- To provide sustainability of the environment by the means provided in the Act; and
- To protect the right to a healthful environment by the means provided in the Act.
These purposes include the following:
- The prevention, reduction and elimination of the use, generation and release of pollutants that are an unreasonable threat to the integrity of the environment.
- The protection and conservation of biological, ecological and genetic diversity.
- The protection and conservation of natural resources, including plant life, animal life and ecological systems.
- The encouragement of the wise management of our natural resources, including plant life, animal life and ecological systems.
Its environmental values and principles strive to:
- Encourage stewardship of healthy rural ecosystems.
- Build the capacity of rural communities to enhance their environmental, social and economic quality of life.”

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Statement of Environmental Values: Ministry of the Environment and Climate Change https://ero.ontario.ca/page/sevs/statement-environmental-values-ministr…
“1. Introduction
The Ontario Environmental Bill of Rights (EBR) was proclaimed in February 1994. The founding principles of the EBR are stated in its Preamble:
• The people of Ontario recognize the inherent value of the natural environment.
• The people of Ontario have a right to a healthful environment.
• The people of Ontario have as a common goal the protection, conservation and restoration of the natural environment for the benefit of present and future generations.
While the government has the primary responsibility for achieving this goal, Ontarians should have the means to ensure that it is achieved in an effective, timely, open and fair manner.
The purposes of the Act are:
• To protect, conserve and where reasonable, restore the integrity of the environment;
• To provide sustainability of the environment by the means provided in the Act; and
• To protect the right to a healthful environment by the means provided in the Act.
These purposes include the following:
• The prevention, reduction and elimination of the use, generation and release of pollutants that are an unreasonable threat to the integrity of the environment.
• The protection and conservation of biological, ecological and genetic diversity.
• The protection and conservation of natural resources, including plant life, animal life and ecological systems.
• The encouragement of the wise management of our natural resources, including plant life, animal life and ecological systems.
• The identification, protection and conservation of ecologically sensitive areas or processes.
2. Ministry vision, mandate and business
The Ministry of the Environment and Climate Change’s vision is an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations.
3. Application of the SEV
• The Ministry considers the cumulative effects on the environment; the interdependence of air, land, water and living organisms; and the relationships among the environment, the economy and society.
• The Ministry considers the effects of its decisions on current and future generations, consistent with sustainable development principles.
• The Ministry’s environmental protection strategy will place priority on preventing pollution and minimizing the creation of pollutants that can adversely affect the environment.”

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Ministry of Environment, Conservation and Parks https://www.ontario.ca/page/ministry-environment-conservation-parks
Your own Made-in-Ontario Environment Plan https://www.ontario.ca/page/made-in-ontario-environment-plan states the following and confirms why disposal sites such as the one proposed by The Stool Bus should not come into existence:

“1. Protecting our air, lakes and rivers
Ontario’s water and air are life support systems for nature and people. Pollution in our air and water increases healthcare costs, reduces enjoyment of the great outdoors and contributes to lost economic opportunity. We will protect these critical systems by using water more sustainably and keeping our water and air clean while growing our economy. We will also improve municipal wastewater and stormwater management and work with municipalities to increase reporting to protect the public and our lakes and rivers.
3. Reducing litter and waste in our communities and keeping our land and soil clean
To keep our land and water clean, we will also take strong enforcement action to ensure waste, including hazardous waste, is properly stored, transported, recycled, recovered or disposed. (…!)
We are looking at proposed ways to:
• reduce the amount of waste going to landfills or becoming litter
• manage excess soil and hauled sewage
• redevelop brownfield sites to better protect human health and the environment.
4. Conserving land and greenspace
We will protect and enhance our natural areas, support conservation efforts, continue to conserve species at risk, develop adaptation strategies, and promote the importance of healthy natural spaces for future generations to use and enjoy.”

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Here is also a link to the Municipality of Strathroy-Caradoc Official Plan: 2014-2034 to remind you how and why we pursue healthy communities: https://www.strathroy-caradoc.ca/en/city-hall/Official-Plan.aspx

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You can access comments posted on The Stool Bus’s previous application in 2021 at https://ero.ontario.ca/notice/019-3689 (which should still be relevant concerns for this 2023 application).

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We urge you to reject The Stool Bus’s proposal to deposit raw, untreated human waste on land on the property at 6953 Falconbridge Drive in Melbourne. This type of dump has no place in our municipality or in any other for that matter. There are much better sustainable and environmentally responsible ways to handle it since we have treatment facilities readily available that can take on raw untreated human waste in an environmentally conscious manner. As stated in the proposal, this is a “hauled sewage disposal site” operation; this is not spreading of sewage biosolids from a municipal waste water treatment plant for nutrient management. And to do so on/in an environmental sensitive area seems very irresponsible.

Thank you for letting us voice our concerns. Please take action to stop unnecessary environmental harm.

Here are the links we mentioned once again:
https://maps.thamesriver.on.ca/gvh/?viewer=tsrassessmentreport https://www.ontario.ca/laws/regulation/900347
https://www.scrca.on.ca/planning-and-regulations/st-clair-region-conser…
https://www.ontario.ca/page/provincial-policy-statement-2020 http://omafra.gov.on.ca/english/about/state-env-values.htm
https://ero.ontario.ca/page/sevs/statement-environmental-values-ministr…
https://www.ontario.ca/page/ministry-environment-conservation-parks https://www.ontario.ca/page/made-in-ontario-environment-plan
https://www.strathroy-caradoc.ca/en/city-hall/Official-Plan.aspx
https://ero.ontario.ca/notice/019-3689

Note:
At this time, we also need to voice our disapproval over the way proposals such as this one is being dealt with by the ERO/MECP. Concerned neighbours need to be notified of developments that can have major impacts on the community. Notifications should be sent out to all surrounding neighbours in a timely manner to allow for plenty of time for them to respond, and a notification needs to be posted on the proposed site letting the public know of its intent. To go to the ERO website every day and search out for proposals detrimental to our environment, community and health is ridiculous. The community should have a say without proposals sneaking past public scrutiny (which is the way it seems to be set up). Thank you.