RE: ERO # 025-1424 (Ministry…

RE: ERO # 025-1424 (Ministry Reference # 5925-DNEHJZ)

Notice Stage = PROPOSAL (posted December 17, 2025)
Applicant: Stubbe's Redi-Mix Inc. - Environmental Compliance Approval (air)
Instrument type: Environmental Compliance Approval (air)

Hello,

I live in the vicinity of Stubbe’s Precast, 44 Muir Line, Harley ON (although 44 Muir Line places it just north of the hamlet of New Durham ON). This facility is also home to Stubbe's Redi-Mix Inc. who are the applicant for an Environmental Compliance Approval (air) as per the above information.

I have noted that ERO # 019-7008 (Ministry Reference # 6060-CPYKRQ) is the current ECA (air) in force at Stubbe's Precast / Stubbe’s Redi-Mix. The "Decision Details" for ERO # 019-7008 includes the following:

"This application includes all emission sources from the facility that exhaust to the atmosphere including:
• material handling and storage piles,
• 5 material silos, conveyors,
• two weigh scales, load point,
• two natural gas fired boilers,
• touch cutting and welding,
• sandblasting,
• woodworking,
• 14 baghouse units,
• laboratory fume hoods, and
• fugitive emissions"

"Contaminant emissions to the air from this facility include:
• Portland cement,
• respirable silica,
• fly ash,
• potassium oxide,
• calcium carbonate,
• calcium sulphate,
• particulate matter,
• nitrogen oxides and other products of combustion"

I have also noted that the PROPOSED ERO # 025-1424 (Ministry Reference # 5925- DNEHJZ) lists the following in the “Proposal Details”:

"This proposal is for an Environmental Compliance Approval with Limited Operational Flexibility (air) which replaces all the current Environmental Compliance Approvals for Air at this facility and includes the addition of new or historically unapproved sources for all emissions from Stubbe's Redi-Mix Inc., a facility that manufactures precast concrete products and ready-mix concrete, located in Harley, County of Brant, Ontario.

The emission sources from the manufacturing and associated processes that discharge to the air include:
• natural gas-fired boilers
• generators
• torch cutting
• welding
• material handling
• pre-cast production fabrication, and
• finishing activities

Emissions to the air from this facility include:
• chromium
• nickel
• fly ash
• calcium carbonate
• manganese
• ferric oxide, and
• nitrogen oxides"

Additionally, the “Proposal Summary” for ERO # 025-1424 states, “This proposal is for an Environmental Compliance Approval with Limited Operational Flexibility (air) which replaces all the current Environmental Compliance Approvals for Air at this facility and includes the addition of new or historically unapproved sources for all emissions from Stubbe's Redi-Mix Inc.”

These are my comments/questions for the Ministry’s consideration regarding the above:

1. ERO # 025-1424 states that, “This proposal is for an Environmental Compliance Approval with Limited Operational Flexibility (air) which replaces all the current Environmental Compliance Approvals for Air at this facility and includes the addition of new or historically unapproved sources for all emissions from Stubbe's Redi-Mix Inc.”

For Ministry consideration: To be clear, if approved, will ERO # 025-1424 completely supersede the current ERO # 019-7008 as the “Proposal Summary” has stated?

2. It is my understanding that no production processes at Stubbe's Precast / Stubbe’s Redi-Mix have changed.

For Ministry consideration: Why, then, have the “emission sources from the facility” in the current ERO # 019-7008 been changed and/or reduced in scope compared to the proposed ERO # 025-1424?

3. Further to question # 2 above, the “emission sources from the facility that exhaust to the atmosphere” in the current ERO # 019-7008 includes “storage piles”.

The storage method for the recycled concrete material at the Stubbe's Precast / Stubbe’s Redi-Mix facility is in the form of outdoor uncovered piles which appear to have no ground-level barriers to contain contaminated water run-off from any of the storage piles into the nearby road ditches and/or adjacent bush area. Also, since the storage piles are uncovered, winds of any sort can disperse the respirable silica dust easily off-site onto the adjacent farmland and/or into nearby neighbourhoods. These “storage piles” still exist onsite, and as late as January 29, 2026, they could be seen being added to with new material.

For Ministry consideration: Why does the proposed ERO # 025-1424 omit specific mention of “storage piles”?

4. One of the most important omissions from the proposed ERO # 025-1424’s “contaminant emissions to the air from this facility” list is “respirable silica”. That specific emission exists in the current ERO # 019-7008. This is a very puzzling omission for two reasons:

(a) It is my understanding that concrete recycling continues to this day at the Stubbe's Precast / Stubbe’s Redi-Mix facility. Concrete recycling operations are well-known to release respirable silica in its dust.
(b) Stubbe's Precast / Stubbe’s Redi-Mix currently have an application in process with the County of Brant to rezone their Muir Road property (see Application Number: ZBA16-25-LG – 20-44 Muir Road South attached to this comments submission). One of the uses proposed as “permitted accessory to the primary use” of M2 – Light Industrial is “concrete crushing”. Based on my research, “concrete crushing” and “concrete recycling” are interchangeable terms. Whichever term that you choose to use (or the Ministry recognizes), the end result is the same: respirable silica dust is a fugitive emission of this process.

For Ministry consideration: Why has “respirable silica” been removed from the proposed ERO # 025-1424’s “contaminant emissions to the air from this facility” list?

5. Further to question # 3 & 4 above, we and several of our neighbours have easily observed visible signs of dust blowing off their outdoor storage piles of recycled concrete materials. Under the current ERO # 019-7008, Stubbe’s Redi-Mix were issued ECA # 9324-D3DPJS (dated Aug 27, 2024). This specific ECA outlines clear requirements for this company to manage their fugitive dust emissions. This includes preventing the fugitive dust emissions from reaching nearby residential areas and farms which could be harmful to the health of the residents, livestock and crops.

For Ministry consideration: How does the Ministry enforce the terms of ECA # 9324-D3DPJS, and further, are they indeed enforcing those terms consistently and rigorously?

SUMMARY
In summary, I hope that my comments are thoughtfully thoroughly considered prior to any approval of the proposed ERO # 025-1424. It is indeed concerning and disquieting that this type of industrial manufacturing operation generating harmful fugitive emissions is allowed to operate so near to residential and farm areas.