Executive Summary: This…

Executive Summary:

This report will analyse the submission material that was provided by the Ministry in response to ECA requests - 019-1444/019-1446 with reference numbers 8818-BKDPE7 and 2032-BKDP63 submitted by the numbered company 2683517 Ontario Inc.

As we will show, this submission is insufficient in many ways, there are some details that are deceptive and inaccurate, and some that are not included giving a wrong overall picture of the environmental impact of this proposal.

We will show that this submission will actually negatively impact climate change, will impact Ontario's natural resources (including Lakes, rivers, community parks, residential neighbourhoods). It will break the ministry environmental emissions limits, exceed noise limits and exceed odour allowances.

We also request the Ministry take into account the other governments requests (both municipal and federal levels) in rejecting this site for this proposal, and relocating to a more applicable location away from schools, residences, churches, parks, lakes, rivers and many other urban structures.

As of this writing, there is a petition at http://www.change.org/westhillhealth that has in excess of 7,500 concerned citizens opposing this location for this project. There are well in excess of 250 detailed comments and concerns. These have been shared with the various elected officials within the municipality, the province and the federal agencies.

Finally, regarding this ECA approval, the site plans and zoning diagrams included in the various submission documents include a large site that is called '633 Coronation Drive' and includes a site map that goes from Coronation to the rail tracks. This site includes an existing office facility, an existing recycling facility, and other active facilities. None of these other facilities are included in the submission, no emission data, no noise data, no odour data, even though approval is being requested for the entire site. We believe this is a significant concern and should immediately require a redo of this submission. We are not sure how you can ask for ECA approval for the entire site, only put in data for a ¼ of the site, yet plan construction and use of the rest of the site (ie: storage facility, new road builds, weigh stations etc)

Finally, the proponent has confirmed that the proposal is more than a waste transfer facility, that it is in fact a site that takes incoming organic waste materials, using anaerobic digestion and creates a biogas that they call RNG (or Renewable Natural Gas). This is a renewable energy project. It is very similar to the City of Toronto - Disco Road Organics Processing Centre only significantly larger in size (75,000 tons vs the proposed over 450,000 tons). https://www.toronto.ca/services-payments/recycling-organics-garbage/sol… The City of Toronto, in getting approval for their facility completed an REA approval and with that precedent feel that an REA is more applicable for this facility, especially considering the ECA does not accurately reflect the entire site where approval is being sought.

By allowing/encouraging an REA, it will ensure that the value (if any) of RNG is actually properly reflected, as this forbes article shows RNG may not be as good as preached that many RNG sites are not truly saving carbon emissions, but are manufactured to ensure that methane/carbon are 'harvested' to produce the gas required, rather than salvaging it from material that would emit it naturally. Adding to this process the huge carbon footprint of over 200 heavy truck trips per day, the cutting down of over 100 mature trees on the site, the environmental benefits proposed are non-existent, and the emissions from this site are aggregated to an already overly polluted neighbourhood.