Stubbe's Redi-Mix Inc. - Environmental Compliance Approval (air)

Instrument type: Environmental Compliance Approval (air)

ERO number
025-1424
Ministry reference number
5925-DNEHJZ
Notice type
Instrument
Act
Environmental Protection Act, R.S.O. 1990
Posted by
Ministry of the Environment, Conservation and Parks
Notice stage
Decision
Decision posted
Comment period
December 17, 2025 - January 31, 2026 (45 days) Closed
Last updated

This consultation was open from:
December 17, 2025
to January 31, 2026

Decision summary

An Environmental Compliance Approval with Limited Operational Flexibility (air & noise) was granted to Stubbe's Redi-Mix Inc., for the operating site located at 44 Muir Line Harley, Ontario.

The facility production limit is 515,000 cubic metres of ready-mix concrete per year.

Location details

Site address

44 Muir Line
Harley, ON
Canada

Site location map

The location pin reflects the approximate area where environmental activity is taking place.

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Proponent(s)

Stubbe's Redi-Mix Inc.
44 Muir Line
Harley, ON
N0E 1E0
Canada

Decision details

An Environmental Compliance Approval with Limited Operational Flexibility (air & noise) was granted to Stubbe's Redi-Mix Inc., for the operating site located at 44 Muir Line Harley, Ontario.

The facility production limit is 515,000 cubic metres of ready-mix concrete per year.

The application includes all emission sources at the facility, including:

  • aggregate material delivery, storage, and handling;
  • cementitious materials delivery, storage, and handling;
  • portable crushing and screening operations;
  • ready-mix concrete batching, pouring, truck loading, and shipping;
  • precast product delivery, storage, handling, and shipping; and
  • product finishing including welding, torch cutting, painting, and abrasive blasting

Emissions into the air from this facility include:

  • particulate matter
  • respirable crystalline silica (quartz)
  • portland cement
  • calcium carbonate
  • nitrogen oxide
  • butyl acetate
  • trace metals
  • glass
  • talc
  • fly ash

The Environmental Compliance Approval with Limited Operational Flexibility (air & noise) requires that the company demonstrate compliance on an ongoing basis with Ontario Regulation 419/05, applicable Ministry Guidelines for air and noise and other performance requirements as specified in their conditions. It permits modifications such as process changes, de-bottlenecking or addition of new equipment subject to limits on operational flexibility that include a production limit for the facility to be specified on the Environmental Compliance Approval with Limited Operational Flexibility (air & noise).

The Limited Operational Flexibility conditions will expire 10 years from the date of the Approval, unless this Approval is revoked prior to the expiry date. The company will be required to make application for amendment at that time to renew these conditions. Of specific public interest, one condition that is included with the Environmental Compliance Approval with Limited Operational Flexibility (air & noise) requires the company to make available, at all times, at the facility for inspection by interested members of the Public, a table (emission summary table) that documents the facility’s compliance with Ontario Regulation 419/05.

Comments received

Through the registry

12

By email

0

By mail

0
View comments submitted through the registry

Effects of consultation

A total of 12 comments were received for this proposal through the ERO submissions.

The following summarizes the main comment themes and the Ministry’s corresponding responses.

Category 1: Respirable Crystalline Silica

Comments:

Most comments stated that respirable silica, which was identified as a contaminant in the existing ECA, is not included in the proposed ECA despite ongoing concrete recycling/crushing activities. Commenters questioned whether respirable silica emissions were adequately assessed and requested that respirable silica continue to be identified in the approval.

Response:

The application included an assessment of respirable silica emissions from the facility. The assessment demonstrated compliance with the applicable ministry standards under Ontario Regulation 419/05.

Category 2: Fugitive Dust and Storage Piles

Comments:

Some comments related to fugitive dust from outdoor storage piles, material handling and concrete crushing/recycling activities. Commenters questioned how fugitive dust from these activities would be addressed under the proposed ECA and requested that dust control measures remain in place.

Response:

The ECA includes conditions respecting the implementation of a Best Management Practices Plan for fugitive dust control and the management of visible Fugitive Dust emissions from activities where material is dropped.

Category 3: Public Health

Comments:

Some comments expressed that emissions from the facility, particularly respirable silica and fugitive dust, could adversely affect the health of nearby residents, including children.

Response:

The application demonstrated compliance with the applicable ministry standards under Ontario Regulation 419/05 for contaminants emitted from the facility. The predicted concentrations at points of impingement are below the applicable ministry standards.

Category 4: Environmental and Agricultural Impacts

Comments:

Some comments raised questions regarding potential impacts of dust and emissions on nearby forests, wildlife, surface water, groundwater, crops, livestock, surrounding agricultural lands and nearby natural areas.

Response:

The application demonstrated compliance with the applicable ministry standards under Ontario Regulation 419/05. The ECA also includes conditions respecting the control of fugitive dust emissions.

Category 5: Proposed ECA Scope and Limited Operational Flexibility

Comments:

Some commenters questioned differences between the proposed ECA and the existing air approvals, including changes to the listed emission sources and contaminants. Commenters also requested clarification on whether the proposed ECA would replace the current approval and questioned whether the Limited Operational Flexibility provisions could allow future equipment or process changes.

Response:

Upon issuance, this ECA will replace the previous air approvals for the facility. The ECA provides Limited Operational Flexibility subject to defined terms and conditions. Any modification made under the Limited Operational Flexibility provisions must continue to demonstrate compliance with applicable ministry requirements. The ECA also requires the preparation of annual Emission Summary and Dispersion Modelling Reports.

Category 6: Compliance Monitoring and Regulatory Oversight

Comments:

A few comments questioned how the Ministry enforces existing ECA conditions, particularly those related to fugitive dust, and requested continued regulatory oversight.

Response:

Compliance with ECA conditions is subject to the ministry's compliance and enforcement program. Enforcement activities are outside the scope of the ECA approval decision.

Category 7: Land Use Compatibility

Comments:

Some comments questioned whether the proposed activities are appropriate in a rural area in proximity to residential and agricultural land uses.

Response:

Land use planning and zoning matters are outside the scope of the Environmental Compliance Approval review. The ministry's review of the application is limited to the requirements under the Environmental Protection Act and applicable regulations.

Supporting materials

View materials in person

Some supporting materials may not be available online. If this is the case, you can request to view the materials in person.

Get in touch with the office listed below to find out if materials are available.

Client Services and Permissions Branch
Address

40 St. Clair Avenue West
Floor 2
Toronto, ON
M4V 1M2
Canada

Office phone number

How to Appeal

This instrument decision can be appealed. You have 15 days from October 13, 2026 to begin the appeal process.

Carefully review the information below to learn more about the appeal process.

How to appealClick to Expand Accordion

Start the process to appeal

If you’re an Ontario resident, you can start the process to appeal this instrument decision.

First, you’ll need to seek leave (i.e. get permission) from the relevant appellate body to appeal the decision.

If the appellate body grants leave, the appeal itself will follow.

Seek leave to appeal

To seek leave to appeal, you need to do these three things:

  1. prepare your application
  2. provide notice to the minister
  3. mail your application to three parties

1. Prepare your application

You’ll need to prepare an application. You may wish to include the following things in your application:

  1. A document that includes:
    • your name, phone number, fax number (if any), and/or email address
    • the ERO number and ministry reference number (located on this page)
    • a statement about whether you are a resident in Ontario
    • your interest in the decision, and any facts you want taken into account in deciding whether you have an interest in the decision
    • the parts of the instrument that you’re challenging
    • whether the decision could result in significant harm to the environment
    • the reason(s) why you believe that no reasonable person – having regard to the relevant law and to any government policies developed to guide decisions of that kind – could have made the decision
    • the grounds (facts) you’ll be using to appeal
    • the outcome you’d like to see
  2. A copy of the instrument (approval, permit, order) that you you are seeking leave to appeal. You’ll find this in the decision notice on the Environmental Registry
  3. Copies of all supporting documents, facts and evidence that you’ll be using to appeal
What is considered

The appeal body will consider the following two questions in deciding whether to grant you leave to appeal:

  1. is there is good reason to believe that no reasonable person, with respect to the relevant law and to any government policies developed to guide decisions of that kind, could have made the decision?
  2. could the decision you wish to appeal result in significant harm to the environment?

2. Provide your notice

You’ll need to provide notice to the Minister of the Environment, Conservation and Parks that you’re seeking leave to appeal.

In your notice, please include a brief description of the:

  • decision that you wish to appeal
  • grounds for granting leave to appeal

You can provide notice by email at minister.mecp@ontario.ca or by mail at:

College Park 5th Floor, 777 Bay St.
Toronto, ON
M7A 2J3

3. Mail your application

You’ll need to mail your application that you prepared in step #1 to each of these three parties:

  • appellate body
  • issuing authority (the ministry official who issued the instrument)
  • proponent (the company or individual to whom the instrument was issued)

Issuing authority
Nancy Orpana
Manager, Air Approvals

Environmental Permissions Branch
135 St. Clair Avenue West
Toronto, ON
M4V 1P5
Canada

(613) 484-2675

Proponent(s)

Stubbe's Redi-Mix Inc.
44 Muir Line
Harley, ON
N0E 1E0
Canada


Appellate body

Registrar, Ontario Land Tribunal
655 Bay Street, Suite 1500
Toronto, Ontario
M5G 1E5
(416) 212-6349
(866) 448-2248
OLT.Registrar@ontario.ca

About the Ontario Land Tribunal


Include the following:

ERO number
025-1424
Ministry reference number
5925-DNEHJZ

This is not legal advice. Please refer to the Environmental Bill of Rights for exact legal requirements. Consult a lawyer if you need help with the appeal process.

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Original proposal

ERO number
025-1424
Ministry reference number
5925-DNEHJZ
Notice type
Instrument
Act
Environmental Protection Act, R.S.O. 1990
Posted by
Ministry of the Environment, Conservation and Parks
Proposal posted

Comment period

December 17, 2025 - January 31, 2026 (45 days)

Proposal details

This proposal is for an Environmental Compliance Approval with Limited Operational Flexibility (air) which replaces all the current Environmental Compliance Approvals for Air at this facility and includes the addition of new or historically unapproved sources for all emissions from Stubbe's Redi-Mix Inc., a facility that manufactures precast concrete products and ready-mix concrete, located in Harley, County of Brant, Ontario.

The emission sources from the manufacturing and associated processes that discharge to the air include:

  • natural gas-fired boilers
  • generators
  • torch cutting
  • welding
  • material handling
  • pre-cast production fabrication, and
  • finishing activities

Emissions to the air from this facility include:

  • chromium
  • nickel
  • fly ash
  • calcium carbonate
  • manganese
  • ferric oxide, and
  • nitrogen oxides

The Environmental Compliance Approval with Limited Operational Flexibility (air), when issued permits modifications to the facility subject to limits on operational flexibility that include a production limit for the facility to be specified on the Environmental Compliance Approval with Limited Operational Flexibility (air). The Limited Operational Flexibility conditions have an expiry date. The company will be required to make an application for amendment at that time to renew these conditions.

Supporting materials

View materials in person

Some supporting materials may not be available online. If this is the case, you can request to view the materials in person.

Get in touch with the office listed below to find out if materials are available.

Client Services and Permissions Branch
Address

40 St. Clair Avenue West
Floor 2
Toronto, ON
M4V 1M2
Canada

Office phone number

Comment

Commenting is now closed.

This consultation was open from December 17, 2025
to January 31, 2026

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