I am a resident of Metcalfe…

I am a resident of Metcalfe Township; our family farm is about 5km north (upriver) of the proposed storage facility. Having reviewed the Land Tribunal Decision (OLT-22-003082) I have several concerns:
1. The volume of biosolids to be stored is unprecedented, almost triple the original proposal, and greater than any other facility known to the experts opining at the hearing. This mandates that the facility meet a much higher safety management standard (Guide to Field Storage of Biosolids, p. 41, below.) The onus to prove that a higher standard of safety has been achieved should be entirely on the appellant, who has barely met minimum standards in this case. Furthermore, in the management of similar, smaller facilities, the appellant has a reputation for poor environmental stewardship and locally is thought to be interested only in profit, and unconcerned about negative impacts on neighbours. Managing a biosolids facility of this size certainly requires careful attention to its effects on our rural communities.
2. There is insufficient evidence that the large piles of "pellets" can be protected from moisture. The tarps and tires method described is considered suitable only for small volumes (p.46, below):
"However, field experience has shown that tarps are not practical, except for very small stockpiles.
Biosolids stockpiles usually occupy a significant area; large tarps needed to cover them are expensive, difficult to anchor and handle. Spreading the tarp often requires workers to physically wade in biosolids. Furthermore, placing and removing tarps may lead to significant drag-out of biosolids and the soiled tarps themselves are a disposal problem." Exposure to moisture results in heating due to microbial action, and the tarps hold the heat inside and magnify the fire risk.
3. Surface runoff from stormwater is an extreme risk in this location. On August 23, it received 15 cm of rain in less than 3 hours. (That corresponds to 1.69 million litres of water hitting the tarps covering each of two piles.) This spring, the Sydenham and surrounding fields, including ours, upstream of the facility's proposed location, were inundated for weeks following torrential rains. Crop planting was severely delayed. These events can no longer be considered rare, given the cumulative effects of climate change. The proposal would store rainwater in two ponds, whose volume would have to be sufficient to contain an extreme rainfall, plus the average rainfall for however many weeks it might take for the flooding and soil saturation to subside (p. 54, below): "Storage facilities need to be large enough to provide adequate biosolids storage volumes during worst-case weather conditions (long periods of inclement weather when field application is restricted and the facility cannot be emptied). If the facility is not under roof, the design must provide for stormwater retention apart from the stored biosolids with sufficient volume for precipitation accumulation or provide other management measures that prevent accumulation."
The Sydenham River, into which surface runoff from the proposed facility would drain, is particularly important because of its biodiversity. Why put that at risk, or wait for MECP to nix the facility plan?
"In 2017, the East Sydenham River was designated one of 13 freshwater Key Biodiversity Areas (KBAs) in Canada by the International Union for Conservation of Nature (IUCN) because it supports a great diversity of freshwater species including five globally threatened mussel species: the Northern Riffleshell, Snuffbox, Round Hickorynut, Salamander Mussel, and Rayed Bean. Key Biodiversity Areas are areas contributing significantly to the global persistence of biodiversity." (https://www.sydenhamriver.on.ca/biodiversity/)
I feel that biosolids storage facility of this unprecedented size should have the safest possible construction, and this proposal has simply provided the bare minimum that would be adequate for a much smaller volume. Either the scale of the project must be vastly reduced, or a properly constructed, covered storage must be built. This would require soil mapping to determine stability of the floor or concrete pad, monitoring wells to regularly assess nutrient and contaminant levels, and many other safety features which are absent from this proposal.
Because of its size, this facility, if built, will establish a precedent across North America. Therefore, let it be built to the best current safety standards. We don't want Metcalfe Township to be famous for an environmental disaster, like Walkerton. I find this application reminiscent of the York1 dump expansion in Dresden that generated public outrage and led the Minister of the Environment to intervene and order a full environmental assessment. A small, ordinary facility that suddenly morphs into a mega-project, without careful planning and oversight. Let's not let that happen.