HIEA would like to make the…

HIEA would like to make the following comments on the proposed guidance document:
• MECP has used data gathered from its internal databases to inform the content and
policy direction for the Odour Guidance document. The policies and direction including
setback requirements are based on this experience. HIEA is concerned as odour,
especially in heavily industrialized areas such as North Hamilton, are difficult to identify
and properly attribute and as such may be misleading.
• HIEA, from practical experience, is concerned that facilities in heavily industrialized
areas are often mistakenly identified as the source of odour complaints by residents.
From past knowledge, larger facilities are typically targeted for odour complaints due to
their size and ultimately their visibility. As such, using number of complaints against a
facility as a “trigger” within the guidance document will lead to unnecessary work and a
distraction from achieving environmental outcomes.
• It is noted that the guidance document has an expectation that odour must be included
in ESDM reports unless the odours discharged are negligible.
o No quantitative measures have been established for this baseline.
• The Guidance document indicates that technical bulletins will be used to provide
guidance, direction and ensure consistency in the application of odour requirements.
There are no final bulletins available. HIEA is concerned that these bulletins will be
produced 1) on an ad hoc basis, 2) not on a timely basis, and 3) to address the issue of
the day rather than as the foundations for a comprehensive framework.
• It is noted that the odour screening form for Environmental Compliance Approvals
identified in Section 3.1 is not available for review and comment as a part of this
proposal. HIEA is concerned that this document will not be made available for review
until after the guidance document is finalized and published.
• HIEA is concerned that the land use compatibility provisions outlined in the Guideline,
when applied in heavily industrialized areas such as north Hamilton, may have unintended consequences in hollowing out the industrial core. New or existing companies
would likely not be able to meet set back distances due to the abutting of residential
areas on the industrial core. This would likely lead to more greenfield developments
away from residential areas