To whom it may concern, Once…

To whom it may concern,

Once again, our neighbourhood is in a fight to protect our homes and quality of life. After successfully delaying (hopefully stopping!) the construction of a biogas facility in our residential area, we now have to fight for the air we actually breathe.

My husband has lived in our house since 1967, I've been in the neighbourhood since we were married in February 1992. It's always been a mostly quiet, peaceful neighbourhood. The noise pollution has definitely increased over the years, companies have come and gone on Coronation Drive.

Since Covid hit, I’ve been working from home full-time and go for walks at lunch. I don’t like walking along Coronation Drive, but it’s generally less congested than other streets and the public paths by the lake. It’s also safer for me when I’m out on my own.

I walk by Digital Specialty Chemicals Limited and have to cover my mouth and hold my breath as long as possible when passing by. I always thought it was just a bad smell polluting the air, I didn’t realize it was potentially toxic. That was until the community group who opposed the biogas facility got involved. Now I know the company has applied to expand its operations and install new equipment. So in addition to more noise pollution, and even more traffic up and down Beechgrove and Manse Roads, there’s potential for more toxins in the air.

We have serious concerns with the Air Quality Peer Review prepared by Pinchin Ltd. So much so, it forced our community group to conduct an independent review of its own (completed by Consulting Engineers and Scientists, RWDI for future reference). The issues RWDI identified include:

> We understand the new thermal oxidizer could potentially reduce some emissions from the expanded plant. However, the Emission Summary and Dispersion Modelling (ESDM) report doesn’t include sufficient detail to validate the expected emission rates and the mitigating effects of the thermal oxidizer.

> The method of calculating emissions from by-products of combustion from the thermal oxidizer weren’t provided.

> In addition to the main treatment process reactors, there are numerous references to other equipment and operations that are also ducted through the air treatment system, including material transfer operations, filtration, distillation, holding tanks, etc. No details were provided on how the contribution from these sources were considered in the emission calculations. This raises the possibility that emissions may be underestimated.

> Emissions from “Specific Future Processing” were simply listed as “Provided by Entegris” and couldn’t be validated.

> Overall, the calculation of process emissions doesn’t have sufficient information provided to allow RWDI to understand details on the process or the calculations involved, so Pinchin’s conclusions can’t be validated.

Another point of concern is that the company has applied to the ministry (MECP) regarding many contaminants with no POI limits, but with predicted impingement concentrations above MECP standards, and one above its benchmark (these are possibly still under review). Any proposed new concentrations must be health-based, and the health effects of the cumulative impact of numerous releases of pollutants should be considered in setting POI limits.

Like we experienced with the biogas facility application, one of my biggest concerns is the lack of transparency. While the Environmental Compliance Application from Digital Specialty Chemicals is publicly available, it’s heavily redacted. Neither the company for the MECP will provide us with an unredacted copy – that in itself raises a lot of red flags for our concerned community group.

In conclusion, all findings from the RWDI report need to be explored and answered before any decision is made regarding this application. The Ministry also needs to closely review and investigate the following before making any final decision on the company’s application:

> the company’s noise abatement plan, a two-phase process which may take up to six years,

> the transport of chemicals and substances via tanker and transport trucks through our residential streets, and

> the need for a federally-required Environmental Emergency Plan for this facility.

Thank you in advance for your attention to this matter.