I have worked in…

I have worked in environmental consulting for approximately 25 years and landfill design, construction, and monitoring as been a large part of my career. As such, I am very concerned with the proposal to remove the environmental assessment (EA) requirements for the York1 Waste Disposal Site Project.

Key Concerns:

1. Risk to Water Resources: The site's proximity to sensitive watercourses, including Molly's Creek, the 4th Concession Drain, and the Sydenham River (known for its high number of species at risk), is a major worry. Without a detailed EA, the potential for leachate contamination or other impacts on these water bodies is a significant fear. This is especially pertinent as Dresden's drinking water, while sourced from Lake Erie, relies on the health of the broader watershed.
2. Impact on the Local Community: The York1 site is located just over 800 metres from the town of Dresden. Residents are concerned about potential impacts on air quality, noise pollution, increased truck traffic, and overall quality of life. The removal of the EA process limits the opportunity for their concerns to be fully addressed and mitigated through a rigorous study.
3. Loss of Public Input and Transparency: A key purpose of an EA is to ensure public consultation and transparency in major development projects. Removing this requirement significantly reduces the ability of the community and other stakeholders to have their voices heard and influence the project's development.
4. Insufficient Scrutiny of Environmental Impacts: The province argues that other regulatory approvals (like Environmental Compliance Approvals) will provide sufficient oversight. However, critics contend that an ECA is a more focused permit and does not provide the same broad and holistic assessment of potential environmental, social, and economic impacts as a full EA. An EA would delve deeper into potential long-term and cumulative effects.
5. Precedent Setting: Removing the EA for this project could set a concerning precedent for future waste disposal or other potentially environmentally impactful projects in Ontario. It raises questions about the government's commitment to environmental protection and community consultation.
6. Increase in Landfill Capacity: York1 is proposing a substantial increase in landfill capacity, aiming for an 8-hectare landfill cell with a potential capacity of 1.62 million cubic metres and a fill rate of 365,000 tonnes annually. This significant expansion amplifies concerns about potential environmental risks and the long-term implications for the region, which an EA would typically scrutinize.
7. Waste Importation Concerns: Given Ontario's reliance on exporting waste to Michigan (with recent estimates ranging from 2.7 to 3.5 million tonnes annually), there are concerns that this project, without a thorough EA, could exacerbate waste management issues in the province and potentially impact local ecosystems.

The main solution to this proposal is to reinstate the requirement for a full and comprehensive Environmental Assessment (EA).

If a comprehensive EA is not reinstated, the following should be the minimal requirements:
1. Detailed studies: Examining potential effects on water quality, air quality, soil, local ecosystems (including the Sydenham River and its species at risk), traffic, and community health.
2. Public consultation: Providing meaningful opportunities for residents, Indigenous communities, environmental groups, and other stakeholders to voice their concerns and provide input.
3. Consideration of alternatives: Evaluating other waste management solutions and alternative locations for the landfill.
4. Development of mitigation measures: Identifying strategies to minimize or avoid any potential negative impacts.
5. Comprehensive Study of Potential Impacts: Even if a full EA isn't mandated, a robust and independent study commissioned by the province or York1 could address the key concerns raised. This study should be transparent, involve public input, and be used to inform any approvals.
6. Stringent conditions: Imposing very strict operating conditions on York1 to minimize potential risks.
Independent monitoring: Implementing robust and independent monitoring programs for air and water quality, with publicly accessible data.
7. Strong enforcement: Ensuring rigorous enforcement of all regulations and permit conditions.

The Province should also consider the following:
1. Community Benefits Agreement: If the project proceeds, the community may seek a legally binding agreement with York1 that outlines specific benefits for Dresden, Chatham-Kent, and Lambton, as well as clear mechanisms for addressing community concerns and potential negative impacts.
2. Alternative Waste Management Strategies: Some advocate for a broader shift towards more sustainable waste management practices in Ontario, reducing reliance on landfilling altogether. This could include increased emphasis on waste reduction, reuse, recycling, and composting programs.
3. Moratorium on New Landfill Development: A more systemic solution proposed by some environmental groups is a moratorium on new landfill development in Ontario until a comprehensive provincial waste management strategy is in place that prioritizes waste reduction and diversion.

In essence, removing the EA requirement prioritizes expediency over environmental protection and community well-being, potentially leading to irreversible negative consequences that a comprehensive assessment could have identified and mitigated.

In summary, the immediate and most strongly advocated "solution" is to reverse the decision and require a full Environmental Assessment for the York1 Waste Disposal Site Project. Other potential solutions focus on ensuring rigorous study, stringent regulation, community benefits, and a move towards more sustainable waste management practices, or relocate the landfill to a more suitable area.