Comment
I would like to express my opposition to the granting of another ECA for this operation at 145003 Hilliardton rd.
This is based on the current ongoing operation at this location and the disregard for environmental regulations during the initial approval for an ECA and the subsequent day to day activities.
This applies to both the proponent and the ministry personnel involved in granting the original ECA.
That ECA was granted for a lagoon designed to leak , near an undeclared well and located in ground which has had field tile installed on 2 different occasions.
It also was granted without the required notification which in turn denied any comment opportunity to abutting property owners.
False and misleading information is deemed reason for some type of punishment.
The original application made no mention of a nearby well that came up through the burned barn floor; and was lower on the concrete pad which protruded into the lagoon.
When this was pointed out to the ministry after we learned that the lagoon existed; the landowner and ECA holder were questioned. They both denied the existence of the well.
Ministry personnel know the remainder of this story as some of them arrogantly stated that obviously no such well exists.
What was the penalty for this false information?
Who is more at fault , the person who originated the falsehood or the ministry person who wouldn't believe the neighbours who indicated the presence of a well?
Correspondence from the same ministry later said that they knew the lagoon would leak but it posed no threat by itself without the well.??
Accountability seems to be the main factor missing in the process.
The original application had a faulty engineering design; misinformation and no public notification but was approved by the ministry and then defended by ministry personnel in a" holier than thou " attitude.
The original ECA should have been rescinded and penalties imposed for false and misleading information.
The spreading operation which followed this ECA approval was filled with infractions of the ECA and the process continued.
This operation cannot be scrutinized by ministry personnel who are not located on site.
Now the ECA holder is applying for another ECA to replace the expiring one.
This new application uses very similar information to that used in the initial application.
It uses the same diagram for a leaky lagoon complete with protruding cement and refers to it as holding liquid manure.
I find this very shoddy engineering. . It obviously used a diagram blank for a manure lagoon.???
It also omits the existence of the nearby well which was a point of contention in the initial application and previously mentioned.
Once more False and Misleading information
The method of spreading the sewage has changed in the new application to surface spread. The original ECA had stipulated incorporation into the ground. This is totally unacceptable since even with incorporated sewage the runoff was excessive.
Another instance of False and Misleading information. The new application states that there is no other sewage facility within 50 KM that accepts hauled sewage. The New Liskeard lagoon is less than 30 km .
This application leaves much to be desired in truthfulness and quality engineering.
What evidence does the ministry have to show
i. the existing well is not contaminated and subsequently contaminating neighbourhood wells?
ii. the lagoon is not acting as a leaching bed as described in one of the applicants diagrams and draining into the field tiles leaving the test wells without contamination?
iii. the municipal drain which leaves the property is not carrying contaminated water through the living legacy lands to end up in the Blanche river?
iv. that the crops grown on the spread land have the appropriate paper trail?
v. The chemical composition of the lagoon contents?
vi. the names of all the current abutting landowners
vii. how many of the above landowners were notified prior to the start of this current application process
viii. that the runoff into these abutting landowners property does not exceed allowable limits after each spread.
ix. that the proposed spread map does not infringe on ravines and/or the portion of the land that the landowner has rented to a dairy farmer?
x. that the current method of requiring test wells and the neighbouring dairy farm well to be tested at certain intervals then no reporting of results is required until the end of a 3 year period is a reasonable requirement ?
Do ministry personnel have an understanding of the severity of approving an operation that creates air,water , land and crop contamination?
When the original ECA was approved ; no comments were posted as a result of no notification to neighbours. This was followed by many complaints after approval; some of these complaints after much discussion did cause the ministry to make changes . We are commenting now as a neighbour saw the application on - line. not because of notification which only took place on May 13 2024, and only to a few select people.
I am hoping these comments cause a refusal of approval and not have the ministry ask the proponent to make a lot of changes .
Of note here..it is difficult to justify the changing of a untruth or misinformation once it is in writing and the application provides evidence of many!
Hopefully the approvals branch does not repeat their lack of due diligence and will decline this approval and apply the appropriate penalties for supplying false information.
It seems a denial would not create a hardship for the ECA holder as the application not only gives a new location for the lagoon but states that it was last emptied in 2024.
This would mean a new start as the lagoon should now be empty and they plan on digging in a new location???
I believe this could all be an error in the application but it highlights the inaccuracies or lack of knowledge in all steps of the process from notification to the design and completion of a lagoon and the spreading of its contents.
In Conclusion From our experience since the first sewage arrived; I have no faith in the ability of the MECP to do due diligence in the approval of this application.
I also have no faith in their ability to supervise the operation if it were approved.
Therefore I once more emphasize my opposition to any thought of approving another ECA for this company at this location
Submitted May 24, 2024 8:56 PM
Comment on
9129-6509 Québec Inc. - Environmental Compliance Approval (waste)
ERO number
019-8483
Comment ID
99399
Commenting on behalf of
Comment status