Ref. also ERO 019-1446,…

Ref. also ERO 019-1446, Ministry Reference No. 2032-BKDP63 SAME COMMENTS POSTED THERE.

1. Why is the referenced traffic study area so limited? The study area does not include any school areas, commercial areas or the majority of the residential areas that truck traffic must pass through on the way through the neighbourhood to the nearest highway.

2. Traffic count peak hours were outside school entry and dismissal times. Given the changes in school bus levels since the time of the referenced traffic counts, and resulting change in car trips and pedestrian traffic to and from schools, how does the added truck traffic due to this proposal impact children traveling to, from and around schools and community centres on the truck routes?

3. The traffic study impact analysis appears to be primarily concerned with vehicle delay times at immediately adjacent intersections, with no reference to the impact on intersections further along the route through the neighbourhood(s), or impact on pedestrians, including children attending the local schools and community centres on the route, despite the proponents' repeated claims that such a traffic study will analyze the full route taken by the associated trucks.

4. The traffic study references an expectation by the project proponent that approx. 90% of the incoming material will come from the GTA.
a) How did the proponent arrive at that expectation?
b) If this expectation turns out to be too high, will the proponent then cause additional pollution while trucking incoming organic material from further afield?
c) If not enough "benign" organic material is available locally, will the proponent seek to increase the level of hazardous organic materials such as human and animal waste in order to justify the project?

5. The referenced traffic study draws conclusions about truck traffic resulting from the proposed development with regards to impact on intersection delay times only, as if there was no difference between the proponent's trucks and any other traffic on the road. No consideration has been given regarding the characteristic of the neighbourhood(s) through which the trucks will pass; the negative impact on pedestrians or cycle traffic, especially around the schools and community centres on the routes; the negative impact of the type of vehicle; the noise levels of the added trucks and especially the negative impact of the type of cargo the trucks are hauling and the hazards resulting from any collision, spillage or spray of this cargo during travel.

6. Various pages on the proponent's website repeatedly claim that the traffic study would review the types of trucks involved, as well as the route they will take, and "the impact of these trucks on air quality, noise and safety".
The traffic study did not include these factors, but instead confined itself largely to an analysis of potential turning delays at a limited number of intersections close to the proposed development site.
No analysis was presented on the impact of air quality, noise or safety due to the increased truck traffic caused by the proposed development (including truck "back-up beeping" noise emanating from the site itself into the surrounding residential neighbourhoods), and no analysis of any factors including air quality, noise and safety was presented over the routes through the neighbourhoods surrounding the proposed development site.

7. The "Response to public concerns" page on the proponent's website claims that deliveries to the site will be made in closed trucks, yet the accompanying odour assessment acknowledges that deliveries will be made in three types of vehicles, including "roll off containers", which are typically open-topped. What is the mechanism to ensure that such open-topped containers do not emit any odour, spillage, leakage or spray while traveling through the commercial and residential neighbourhoods as necessary to reach the proposed site?

8. The proposal details on the ERO page reference a maximum of 1240 tonnes of non-hazardous waste and 1240 cubic metres of other liquid waste, however the proponent only references a maximum of 1240 tonnes of incoming waste. What is the daily 1240 cubic metres of "other liquid waste" and how is it transferred through the surrounding neighbourhoods?

9. The proponent's website claims that all trucks will be washed before leaving the site, but no provision is made for ensuring that trucks are in a clean condition while traveling through the adjoining neighbourhoods on the way to the site.

10. The proposal materials variously make reference to "organic material" incoming to the site to be used as feedstock. As written, this term could include potentially hazardous or toxic material, provided it is from organic sources (as vs inorganic). What restrictions are placed on the type and condition of this organic material as it travels through our neighbourhoods, and how will those restrictions be enforced over the lifetime of the proposed plant?

11. the "Response to public concerns" page on the proponent's website claims that "the location of this facility will result in less trucking of organic materials around Ontario (and sometimes further)" during the process from collection to use of any digestate on farm fields. There is no basis to this claim given that this proposed site is located in an industrial area reached by traveling through residential and commercial neighbourhoods, both incoming and outgoing, and is not located near any farms or potential end destinations for any digestate.

12. The proposal indicates that a large portion (half) of the material received at the site of the proposed development will be exported daily to other anaerobic digester sites. In contradiction to the proponent's claims of reducing truck travel and greenhouse gas emissions, these "double trips" will increase truck travel and greenhouse gas emissions in the surrounding residential neighbourhoods. It is inappropriate to locate such a site in this location.

13. Various pages on the proponent's website reference the methane-capture ability of an anaerobic digestion facility as compared to disposing of organics in an open landfill without methane-capture. No mention is made of carbon capture (of the carbon dioxide produced). As well, if the City of Toronto or other jurisdictions ban commercial organics from landfills in the coming years, then the argument isn't between anaerobic digestion and landfill disposal, but instead the focus will be on appropriate construction, management and location of permitted disposal facilities, such as anaerobic digesters. This proposed site is NOT an appropriate location for any such facility given the increase in truck travel required through surrounding residential and commercial neighbourhoods, the noise impact on these neighbourhoods from both the site and the truck travel, and the increased risk of spillage, leakage and odour during the travel through the surrounding neighbourhoods that include multiple community centres, schools, residential areas and commercial plazas all in close proximity.

Thank you.