A FULL Environmental…

Commentaire

A FULL Environmental Assessment needs to be done now if the ministry will not revoke the proposal or license of York1 to reopen a 40 year old dormant landfill piggy backing off an old out dated E. A number that was never set up to allow the amount of waste and landfill that is proposed on a twenty four hour, 7 day a week basis

When Bill 197 was Passed in 2020, it required that, prior to commencing an environmental assessment, a landfill proponent obtain a copy of a local municipal council resolution indicating that the council supports the project.
Our local mayors and council members of at least 2 counties that are too close to this site do not support this project.

If the site is located within 3.5 kilometers of a border with an adjacent municipality, the proponent needs to obtain a separate resolution from that council as well. Dawn Euphemia Council also doesn't agree with this proposal, nor does Sarnia Mayor and their council support this proposal either.

Dresden understood that opening a new landfill was no cakewalk. Decades ago, the province introduced standards on groundwater protection, air emissions, leachate control, buffer areas – all issues that must be addressed during the environmental assessment process. York1 has submitted 3 applications for environmental approvals without any advanced notice, let alone consulting with residents or the community or getting environmental assessments done.
The first was November 30 2023 which nobody knew about.
It was their second proposal we found about and started to voice our concerns February 8th 2024
Then February 26 2024 came their 3rd proposal and our voices grew louder with support from many unions, mayors, city councilors, and a list of many other organizations who stand with Dresden

Since at least 1979 local zoning regulations have not listed a waste processing facility or landfill as permitted use at the property York1 purchased.
This property is zoned M2-365 and under the present zoning, waste processing, storage, transfer and landfilling are not permitted uses on this subject property.
One reason is because this property as well as Dresden is in a flood plain and they will have leachate ponds and storm drains, draining directly into Molly’s creek and then into the Sydenham River and is in contrast to the Clean Water Act, 2006.

This property is located on flood plain which is 800 meters north of Dresden and is framed by a provincially significant Carolinian forrest woodland that is encompassed by Molly’s Creek and the 4th concession drain that are tributaries and empty into the Sydenham River which is naturally recognized for its high numbers of endangered and species at risk. A portion of this site is located within the regulated area of St Clair Region conservation authority

The subject property is zoned Extractive industrial M2-365 with permitted use for
Agricultural use with no structures
Asphalt and concrete batching (measuring ingredient /materials to prepare concrete mix.
Building and structures related to asphalt concrete batching
Open storage
Pits and quarries
Processing extracted materials from the site
With a special Zone provision for storage of asphalt and concrete for crushing

The property was subject to a 1980 Ministry environmental compliance approval for an 0.8 hectare landfill which was used for fly-ash from a decommissioned incinerator which Dresden once had starting in 1967.as well it included local commercial waste which this landfill is no longer active to accept.

In 1992 a waste disposal certificate of approval was granted to permit the processing of scrap wood on this property
In 1998 an amendment to this waste disposal site processing permission was granted to store, transfer and process solid non hazardous waste within a 0.8 hectare approval on this property with a maxim acceptable rate of 75 tonnes per day with a total maximum capacity of only 75 tonnes and this was never changed

York1 is proposing on this site to be established in conjunction with a brand new landfill site with a capacity of 1.6 million cubic meters and 365,000 tonnes per year without even consulting impacts on the existing aboriginal and treaty rights of the aboriginal peoples of Canada as recognized and affirmed in section 35 of the Constitution Act, 1982.

The potential impacts of the York 1 waste facility proposal to nearby residents, the surrounding communities, as well as natural heritage and water resources have never been examined and are unknown presently including the native reserve of Walpole island, who holds water right under the aboriginal and treaty constitution act 1982

There is potential for substantial noise, and air quality impacts, impacts to surface and ground water resources and natural heritage features and functions and a substantial increase in truck traffic and truck emissions with impacts on pedestrian and traffic safety, road capacity and municipal infrastructures.
NO studies to assess potential impacts have been presented by York1 to the municipal council or residents of Dresden.
These applications have been prepared without the benefit of any information or comments from the community, local residents or even the municipality

Local residents who would be directly impacted if this proposal were approved had only learned about the proposals after the fact, late January, so when myself and Stefan Premdas brought together the town in a spur of the moment town meeting February 8 2024 to discuss what we could do to stop a landfill from opening up so close to town, we were left to scrounge for information to understand the potential implications.

However when York1 heard about our town's first meeting and how upset this town was, did York1 finally decide to open up their initial February 10th meeting that they were supposed to have with only the 12 of closest neighbors, to include another 90 of our town residents that then reached building capacity of 100.

York1 has never provided a clear explanation of the scope and nature of this proposal.
Lambton-Kent district school board has already raised serious unaddressed concerns related to the safety and well being of students attending nearby schools given the potential impact of the proposal including traffic safety issues impacting school bus routes and other potential impacts because the closest school is less than 1 km from York1’s most southern property border. The absence of a traffic study is a glaring oversight considering trucks will carry two and a half million tonnes of waste and recycling materials per year to this proposed site.

Other crucial areas requiring study are socio-economic impacts, land use planning, cultural heritage impacts and human health risks since they intend to run this property 24 hours 7 days a week with a 106 million meter landfill that can be expanded, as all other landfills are presently being expanded in the province.

WE expect this requested FULL Environmental Assessment to include
A traffic study
A noise impact study
Emission study from all the trucks going thru Dresden
Air quality and dust impact study
The ecological impact assessment of the natural heritage system which included land animals and Aquatic mammals, plant life and human life) in the vicinity of the subject property including the adjacent watercourse and municipal drain.

To support the landfill proposal there are missing studies.

A geotechnical study
A detailed hydrogeological assessment
A detailed assessment of volume, extent and characteristics of existing waste to support the proposal to move existing onsite waste to the new landfill
An air quality, dust, odour and landfill gas impact assessment

Given the information gaps and missing information, both ESA applications are incomplete and it is premature for the ministry to begin review of the ECA applications.

Key environmental impact assessments have not been completed under this new amendment application - A full Environmental Assessment is needed to determine the overall environmental impact associated with the proposed undertaking.

The EA act requires that a traceable and methodical assessment to support a decision to approve an undertaking.
A systematic evaluation of all reasonable alternatives as required by the E.A Act is essential for the York1 proposal given its extensive scale and implications for this entire community.

According to Ontario regulations 101/07 As amended in the Landfill Designation Regulation, a full environmental assessment of the related York1 landfill proposal automatically should be triggered and should have a full environmental assessment done prior to any approvals.
A FULL Environmental Assessment IS NEEDED if the minister will not revoke this proposal or allow Bill 197 to stop this landfill dump transfer station facility

York1 is relying on a speculative calculation of an existing small landfill capacity to avoid a full environmental assessment study process.
York 1 is effectively trying to mischaracterize a major new landfill proposal to make a 1.6 million cubic meter facility to serve this entire province on a 24 hour, 7 days a week schedule.
This will make it the largest operating facility / Landfill in the entire province and will have the capacity to expand larger without further approvals because of the extra land they have been purchasing.

By mischaracterizing the York1 landfill proposal in this manner, it flies in contrary to the specific provisions and the purpose and intent of the designated regulation, which establishes a requirement that major new landfill proposals or expansions to existing sites are to be subject to a full environmental Assessment under the E.A act.

These last 2 ECA applications amount to a combined interrelated waste facility and a NEW landfill operation.
These cumulative and interrelated potential impacts of this proposal on the environment, the local community and municipal infrastructure triggers the need for a comprehensive environmental assessment study process pursuant of the E.A act.

However because our group Dresden C.A.R.E.D has already proven this site would be a new expansion of a 40 year old closed fly ash landfill and not existing landfill, we urge this government to stand by their Bill 197 which states no landfill can be opened or expanded with a 3,5 km from any town

In 2020 the government of Premier Doug Ford changed the province’s Environmental Assessment Act, introducing a new provision that granted municipalities the power to veto landfills. Bill 197 (also known as the COVID-19 Economic Recovery Act) represented one of the biggest changes to waste management practices in Ontario’s history. As long as the Bill 197 veto remains in place, opening new landfills is virtually impossible.

We are very happy our voices are finally being heard and the minister of environment has triggered this full Environmental Assessment.
However we also feel this should trigger Bill 197
6.0.1 (1) In this section “landfilling site” means a waste disposal site where landfilling occurs (NOT Occured present not past tense.)
6.0.4 that is located within a 3.5 kilometre distance, or such other distance as may be prescribed, perpendicular at each point from the property boundary of the property on which the proposed landfilling site would be situated.

York1 is seeking to reply on outdated historical waste approvals for a small scale local landfill and processing area granted decades ago with minimum studies to justify a stripped down environmental and planning approval process for a major waste facility with a province wide scope and broad range long term implications for the surrounding communities of Dresden and the Dawn Euphemia settlement

Dresden CARED is happy we triggered an full Environmental Assessment pursuant to section 2 of Ontario regulation 101/ 07, but we would be happier to see that these 3 proposals to have triggered Bill 197 which states new or expanding landfills are not allowed within an area of settlement,
(iii) that is located within a 3.5 kilometers distance, or such other distance as may be prescribed, perpendicular at each point from the property boundary of the property on which the proposed landfilling site would be situated.
This is LESS than 800 meters from their farthest most southern / western boundaries