2) Major Industry Definition…

2) Major Industry Definition
The definition of Major Industry is provided in the Glossary as:
Major Facilities(y): facilities which may require separation from sensitive land uses, including but not limited to airports, manufacturing uses, transportation infrastructure and corridors, rail facilities, marine facilities, sewage treatment facilities, waste management systems, oil and gas pipelines, industries, energy generation facilities and transmission systems, and resource extraction activities (PPS).
Based on this definition, the Ministry of the Environment, Conservation and Parks (MECP) has provided an additional list of facilities in Table 1; therefore, the definition of Major Facility has two parts: the description and examples.
The description is “facilities which may require separation from sensitive land uses”
Unfortunately, the description of a Major Facility is a circular definition. How do we know a particular facility is a Major Facility? It needs separation from sensitive land uses. How do we know whether it needs separation from sensitive land uses? We do studies to figure out whether there are impacts that exceed criteria. As a result, we can’t know whether a facility is a Major Facility unless we do the studies needed to show whether it is or not.
The remainder of the definition is a list of examples that while helping in some circumstances, is not sufficiently clear to figure out the dividing line between being and not being a Major Facility.
For instance, I used to work at a Metal Parts Manufacturing facility (listed in Table 1). We produced metal parts that another company used in their electricity generating turbine. With just this description, someone using the Land Use Compatibility Guide would read Table 1 and decide that the facility would have an Area of Influence (AOI) of 600 m, be Class 2 and have a minimum separation distance (MSD) of 300 m.
However, the facility was 160 m2 (17,000 ft2). It received 1 transport truck of steel once a month. It shipped product out of the facility once a week using an F-350 pickup truck. It had 1 fork truck that left the building once or twice a day to store empty pallets outside. Nothing else was stored outside. Staff in the facility did not need hearing protection because the CNC machines on the shop floor did not generate enough noise to warrant hearing protection. The work activities were never audible in the office or off-property. There were no exhaust stacks so no point sources. The parking lot was paved so there were no fugitive dust sources. There were no vibration sources. A shipment was 130 parts or less and we never shipped more than 300 parts in a week. Large parts were 0.5 m long and 0.2 m wide (12/shipment). Small parts were 0.15 m by 0.1 m (130/shipment). The facility operated 7/24 with up to 5 people on afternoon shift and another 5 people on night shift.
Requiring a 300 m MSD for this facility is not appropriate.
By contrast, I have a client who makes paper bags. Their work is not listed in Table 1. Table 2 has the same circular definition problem as seen in the definition of Major Industry. They have many transport trucks a day for both shipping and receiving of product. They have large exhaust fans that are noisy, so they have had difficulty showing compliance with noise criteria in the past. They now show compliance with noise criteria but if residences were to be sited closer to the building, that would make showing compliance difficult again.
Please provide a clearer definition that provides the ability to classify industries as Major Facility or not.
3) Table 3 usage
Table 3 is intended to help with the classification of an industry but there are only three descriptions for five categories. With text like “Sounds occasionally audible off property” (Class 3) and “Sounds frequently audible off property” (Class 5), what kind of facility gets a Class 4? A similar problem exists with Hours of Operation: if Class 3 is “Shift Operations permitted at times” and Class 5 is “Daily or 24 hour shift Operations”, what is Class 4? Please provide finer guidance for assigning class.
Table 3 has 11 rows of impacts. Once I’ve assigned a value for each impact, how to I decide which Class applies to the facility (assuming only 1 applies)? Do I average the values? Do I select the most common? Do I select the highest?
For the Metal Parts Manufacturing facility I mentioned in Comment 1, the values were respectively (1, 1, 1, 1, 1, 1, 1, 1, 4 or 5 (night shift), and 1).
Another option might be to provide direction that each row should be considered as a continuum so I can assign a 3.5. If the intension is that every impact is to be considered a continuum from 1 to 5, then that needs to be explained along with the complete description of how to use the data in Table 3 to make a Class assignment.
Please provide a step by step set of instructions on how to take real world situations and determine the appropriate class.
4) Will the MECP be preparing some example (ACME) assessments?
5) If Major Facility is a defined term, please capitalize the term throughout the document.
6) The previous document was very clear that vacant lands must be assessed for the worst case of industries for which the land is zoned. This document is less clear that “could be permitted” is intended to handle the “vacant lot” of the previous guidance. Please increase the clarity that the assessment should include what was formerly called vacant lands.