I am submitting this comment…

I am submitting this comment as a resident of Ward 3 in Hamilton, Ontario, and I strongly oppose the proposed amendment to ECA No. 6567-5ADLUE to expand operations to include a Class 1 excess soil management facility and a public drop-off station.

This expansion is not appropriate for Ward 3 due to the documented environmental vulnerabilities of the area, the dense residential population, and the already heavy burden of industrial and transportation-related pollution.

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1. Ward 3 is already one of Hamilton’s most overburdened neighbourhoods

Ward 3 has historically faced higher environmental and health burdens than other parts of Hamilton. Local data shows:
• According to the City of Hamilton’s Airshed Modelling Report, Wards 2 and 3 experience some of the highest concentrations of PM2.5 and NO₂ in the city due to industrial activity and traffic corridors.
• Ward 3 has higher rates of respiratory-related emergency room visits compared with the Ontario average (Public Health Ontario, Hamilton PHU Profile).
• The neighbourhood has a high population density, with many households located near truck routes and industrial operations.

Adding a facility that could receive up to 1,000 tonnes of soil/rock per day will only worsen existing environmental imbalances in a community already identified as at-risk.

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2. Traffic impacts will worsen safety and emissions in an already high-traffic area

The proposed receiving rate of 1,000 tonnes/day could easily translate into 80–120 additional heavy truck trips daily, depending on truck capacity.

Ward 3 has several known traffic pressure points:
• The Barton Street, Gage Avenue, and Kennilworth corridor already sees high truck volumes, which the City of Hamilton has acknowledged in traffic safety studies.
• Hamilton’s 2022 Vision Zero data identifies Ward 3 as having one of the highest collision and pedestrian injury rates in the city.

More heavy trucks will increase:
• diesel emissions
• dust from soil transport
• traffic noise
• safety risks on streets where children, cyclists, and seniors already navigate constrained sidewalks and narrow roads.

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3. Increased dust, noise, and airborne contaminants pose a direct risk to residents

The proposed operations include screening, blending, stockpiling, and resampling of soils, including materials segregated from construction and demolition debris. Even when non-hazardous, these activities generate:
• airborne particulate matter
• silica dust
• increased noise and vibration
• potential asbestos fibers from demolition-derived materials

Given the high concentration of older housing stock in Ward 3 and the community’s pre-existing respiratory vulnerabilities, this is not an acceptable addition.

Outdoor storage of 1,600 tonnes of soil/rock introduces further risks of wind-blown dust and stormwater runoff, especially in an urban area with limited buffers.

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4. The facility serves the entire province, while the burden rests solely on Ward 3

The application clearly states that this site is intended to serve the Province of Ontario, not just Hamilton.

This means:
• Ward 3 will absorb the traffic and emissions from soil hauled in from outside municipalities.
• Local residents receive no meaningful benefit, yet assume all environmental and quality-of-life impacts.

Ward 3 is already home to a disproportionate share of Hamilton’s industrial operations and waste processing activities. It is inequitable to add another provincial-level operation in the same community.

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5. The operating hours are incompatible with a dense residential neighbourhood

Proposed hours:
• Receiving & shipping: 7:00 a.m. – 7:00 p.m.
• Operations: 7:00 a.m. – 10:00 p.m., Monday–Saturday

Ward 3 is a community where many residents work shift schedules, care for young families, or rely on evening quiet hours.
Extending industrial activity to 10 p.m. six days a week is unreasonable in an area where homes sit close to industrial boundaries.

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6. The proposal conflicts with Hamilton’s city planning and environmental goals

Hamilton’s own planning and environmental documents emphasize:
• transitioning toward cleaner land uses near residential zones
• reducing truck traffic in vulnerable neighbourhoods
• improving quality of life in older, denser wards
• addressing historic environmental injustices in the lower city

This proposal runs counter to all these objectives and exacerbates conditions city council has already identified as problematic.

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Conclusion

For the reasons above—including compounded environmental burdens, increased truck traffic and emissions, health risks, and incompatibility with residential neighbourhoods—I do not support the expansion of this facility in Ward 3.

I urge the Ministry to reject this amendment and to consider alternative sites in appropriately zoned industrial districts that are not adjacent to vulnerable neighbourhoods.

Thank you for taking the time to review these concerns.