R. W. Tomlinson Limited - Environmental Compliance Approval (air)

A total of forty-nine (49) comments were received by the ministry on this proposal. Thirty (30) comments were received through the Environmental Registry and nineteen (19) comments were received by email. Comments received were reviewed and, where appropriate, were considered in the ministry’s decision whether or not to proceed with this proposal. The following concerns were raised:

1. Concerns about air emissions including dust and odour and concerns about the quality of the data in the application.
   
   Ministry’s response: The application has demonstrated that the operation of the facility complies with the ministry’s applicable air requirements including but not limited to the air discharge requirements in Reg. 419/05: Local Air Quality Regulation.
   The Environmental Compliance Approval includes an Operation and Maintenance condition to require the facility to implement operating procedures to minimize the emissions of dust and odour from the facility.
   A Dust Best Management Practices Plan and an Odour Management Plan were submitted as part of the application. Conditions 6 and 7 have been included to require the company to implement the plans and update them.


2. Concerns about the scope of Limited Operational Flexibility and whether it will allow the addition of a permanent ready-mix concrete plant.
   
   Ministry’s response: The Environmental Compliance Approval defines an operating envelope for the facility in Condition 2. Any changes at the facility outside of this operating envelope would require an amendment to the Environmental Compliance Approval. These include changes to increase the Facility Production Limit, or the addition of processes not included in the Description Section.
   The application did not request approval for a permanent ready-mix concrete plant and an amendment to the Environmental Compliance Approval would be required prior to installing one.


3. Concern about the cumulative effects of pollutants emitted from the facility and other industry in the area.
   
   Ministry’s response: The Cumulative Effects Assessment in Air Approvals Policy decision was posted to the Environmental Registry in April 2018 and came into effect on October 1, 2018. This policy strengthens and clarifies the consideration of cumulative effects when making decisions related to environmental compliance approvals and indicates when additional measures may be needed beyond current regulatory requirements.
   Under this policy, no further action is required for the facility at this time. The Ministry will continue to look at other contaminants, sources and geographic areas and consult with public and stakeholders as we expand the cumulative effects policy over time.


4. Noise concerns about truck activities, facility/equipment heights, equipment manufacturers' information, points of reception, noise control measures, and cumulative impacts.
   
   Ministry’s response: Truck speed will be restricted to 30 km/h and compression braking cannot be used. Equipment and facility information has been reviewed, and the selected points of reception and noise control measures are deemed adequate. No further action is required for the facility at this time regarding cumulative impacts.


5. Concerns about:
   1. municipal zoning;
   2. increased traffic; and
   3. soil/water pollution.
      Ministry’s response: These concerns are beyond the scope of section 9 Environmental Compliance Approval and the air and noise application review process.