I feel the Land Use…

I feel the Land Use Compatibility Guideline is a set in the right direction in an effort to achieve consistency through the planning process across Ontario.

I have a few specific concerns.

1) I appreciate the AOI and MSD presented in Table 1 are based on a review of complaint history, but there seems that there may be inconsistency between the quantitative information presented in Table 1 and qualitative descriptions presented in Table 3 with respect to classifying a facility. It may be worthwhile to provide more context.

2) In Section 2.4, it is stated that the separation distance is 'typically' measured as the actual distance between the property lines. It may be worthwhile introducing the concept that it may not have to be property line to property line if there is a commitment in writing that either; sources of emission, or sensitive land uses will not be introduced within a planned buffer used to protect either the major industry or sensitive land use. I appreciate Section 3.4 discusses buffers, but a short note in Section 2.4 could help with tying it all together.

3) (My most significant concern). Being involved in a number of contentious land use planning projects, I have a concern that some feel that noise studies can be limited to the consideration of noise sources regulated by the MECP. It is my opinion that good land use planning should consider all noise sources associated with the facility. Based on my interpretation of the direction provided in Appendix B, the MECP is suggesting that compatibility studies can be limited to direction provided in NPC-300 which can, and have, been interpreted differently by some. I see this document as an opportunity for the MECP to put stronger wording that require compatibility studies to consider all sources of noise (or air and dust for that matter) from a facility and not just sources regulated under the EPA (e.g. back up audible warning devices, federally regulated activities directly associated with the facility (i.e. rail and ship), etc.).

Thank-you for the consideration