Proposed Organic Waste…

Proposed Organic Waste Processing and Biogas Plant at 633 Coronation Drive

I am a resident of Highland Creek - Scarborough.

For all the reasons outlined below I strongly urge Minister Jeff Yurek to reject the proposal for an Anaerobic Digester plant at 633 Coronation Drive in Scarborough.

This submission that follows was prepared by a resident who lives close to the plant and who will be negatively impacted if the plant is allowed to go ahead. I strongly endorse these comments

I live just 600 meters from the proposed site, 500 meters as the crows fly. Our family has been subjected to unbearable noise from the current operations at 633 Coronation Drive, Optimum Environmental Corp., often well before 5 a.m. -- crashing, banging, dragging, pushing, loading and unloading of trucks and vehicle backup alarms from trucks, backhoes and bulldozers -- all of which is disturbing our sleep and affecting our health. I’ll get back to the current operations and their history of infractions a little later in my rebuttal.

Existing heavy truck traffic
The acoustic study provided by the proponent simply ignores this current level of disruption coming from this existing site, and has failed to consider the existing and ongoing noise from heavy trucks arriving and leaving the current location. If approved, the new processing plant, which would add 200 daily heavy truck trips directly through our residential streets, which includes no fewer than nine schools. Neighbours are currently complaining of cracked ceilings and damaged Argon Gas windows due to the rumbling and bumping of hundreds of heavy truck trips already going through our area. These trucks are servicing other industries within this zone, including the bulk of which is coming from the current recycling plant at 633 Coronation Drive, along with a massive Wastewater Processing Facility and a trucking company.

There is no place for this facility within a residential community. The massive scale of the facility itself has no other comparison to other plants of its kind. Reviewing the proposal for an anaerobic digestion facility at 633 Coronation Dr in Toronto, our team of advocates opposing this facility compared it to some of the biggest similar facilities in the GTA.

Nothing like it anywhere else
A document showing the differences is attached, but the summary is below:

The proposed site is to process 1240 tonnes per day, while the other 3 process 75, 205, 150 tonnes. That is almost 6 times the BIGGEST other facility in the assessment.
The proposed site will have approximately 220 truck trips per day while the other 3 have 4, 15, 12 (almost 15 times the number of trucks to the next closest facility)
The proposed site has trucks travelling 5.9 km through residential roads, while the other 3 sites do not travel through any residential areas to get to a major highway.
The proposed site is 6.4 km from a major highway, the other 3 sites are .6 km, .3 km and 1.2 km away from a major highway.
The proposed site is 250 m away from the nearest home, where the other 3 sites are 700m, and over 1km away for the other 2.
The proposed site is 350 m from the nearest school, the other 3 sites are at least 1km away from the sites.
The proposed site will operate 7/24, the other 3 sites operate 5/16

Harmful air emissions
Add to this ill-thought-out proposal, emissions from this massive biogas and waste plant will add to current high levels of air toxicants in our area. Data reported in 2019 by ChemTRAC, and from the National Pollution Release Inventory [NPRI), show chemical releases to air from six chemical companies in the area, including the Highland Creek wastewater treatment plant, to be the highest in Toronto. The health of residents should not be put further at risk from additional air pollutants from the bio-gas plant that will result in poorer local and regional air quality 24/7/365.

Risk of fire and explosion
It is critical that this proposal be rejected not only because it does not fit within a residential neighbourhood, far from a major highway, it needs to be rejected because an Anaerobic Digester facility clearly poses risks that are not captured with an ECA approval process. Many of these risks are outlined in the Canadian Government comprehensive guideline for municipalities titled "Technical document on Municipal Solid Waste Organics Processing" (attached). The risks of explosion from Methane is outlined in Section 7.4 of the document. Considering this facility would be the largest of its kind in Canada, it is of significant concern that an explosion and/or fire could occur, and the operation of an Anaerobic Digester facility within a residential neighbourhood would be considered extremely reckless.

In addition, the City of Toronto has a bylaw for propane facilities and restricts setback distances for residences to 500m, considering the similar combustible nature of methane, and the significant size of the amount of methane that will be stored on site, it must be considered a similar setback be utilized for this type of facility.

Of particular interest is the recommended setbacks found in table 8.1, in particular, at least a 300m separation from any permanent residence (which this proposal does not meet), at least 300m from a restaurant (which this proposal does not meet), at least 300m from a food processing plant (which this proposal does not meet), at least 300m from commercial/industrial occupancies (which this proposal clearly does not meet), and 15 to 50 m from the property line (which according to the site plans submitted - there are several different ones - this proposal does not meet).

City of Toronto noise bylaw infractions
It is also of particular time sensitivity that the current operations at 633 Coronation Drive are in violation of City of Toronto noise bylaws, as outlined in the attached ECA via a notwithstanding clause: In section 14.2 it states "Notwithstanding condition 14(1) (which is 7/24 operation), the Owner shall ensure that the operation of the Site conforms to municipal by-laws including any applicable noise by-laws."

Considering the existing City of Toronto noise bylaws related to construction equipment, and loading and unloading, I see no way that the proponent’s plan to operate the Biogas facility could be fulfilled through a 24/7/365 day operation. Here are those bylaws:

CONSTRUCTION EQUIPMENT - Any equipment or device designed and intended for use in construction, or material handling, including hand tools, power tools, air compressors, pile drivers, pneumatic or hydraulic tools, bulldozers, tractors, excavators, trenchers, cranes, derricks,
1 Editor's Note: By-law 878-2019 replaced Chapter 591, Noise in its entirety. By-law 878-2019 and this new Chapter comes into force October 1, 2019.
591-2 Date July 18, 2019

TORONTO MUNICIPAL CODE CHAPTER 591, Noise
loaders, scrapers, pavers, generators, off-highway haulers or trucks, ditchers, compactors and rollers, pumps, concrete mixers, graders, and any other material-handling equipment.

591-2.3. Construction.
No person shall emit or cause or permit the emission of sound resulting from any operation of construction equipment or any construction that is clearly audible at a point of reception:
(1) from 7 p.m. to 7 a.m. the next day, except until 9 a.m. on Saturdays; and
(2) all day on Sundays and statutory holidays.
591-5 Date July 18, 2019

TORONTO MUNICIPAL CODE CHAPTER 591, Noise

591-2.4. Loading and unloading.
No person shall emit or cause or permit the emission of sound resulting from loading, unloading, delivering, packing, unpacking, and otherwise handling any containers, products or materials from 11 p.m. to 7 a.m. the next day, except until 9 a.m. on Saturdays, Sundays and statutory holidays. [Amended 2019-07-18 by By-law 1102-2019

Call for an extension to the Environmental Registry deadline of Oct. 10
In light of Mayor Tory and Councillor McKelvie’s request for a public meeting, for which McKelvie’s office has repeatedly asked to no avail, if the proposal is not rejected outright in the coming days, we need a public meeting where the company can answer residents' questions and to allow your ministry time to assess some of the major concerns. I advocate for an extension by at least two months.

Signed by a local Westhill resident