Comments and Response Tables Comments Received from Non ...€¦ · landfill sites, and that waste...

Appendix F Comments and Response Tables

Comments Received from Non-Governmental Organizations

Niagara-Hamilton WastePlan Comments Received from Non-Governmental Organizations on Draft “Alternatives to” Report

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Appendix F – Page 1

RESPONSE TO COMMENTS FROM THE COMMENT PERIOD TO BE CONSIDERED DURING EVALUATION OF “ALTERNATIVES TO”: NON-GOVERNMENTAL ORGANIZATIONS

Stakeholder/Agency

Comment Received

Response

Non-Governmental Organizations

Gracia Janes

(St. Catharines District Council of Women)

• We support Option 1 over 2B • Comment noted.


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Stakeholder/Agency

Comment Received

Response

Gracia Janes

(St. Catharines District Council of Women)…cont’d

• Do not believe landfills should be placed on farmlands, but rather in industrially-zoned areas, and would recommend the addition of a leachate collection system, with the potential for co-generation projects such as that planned for the former Glenridge landfill.

• The Joint Working Group commissioned a Stabilized Landfill Study and retained the services of Gartner Lee Limited (GLL), in association with Golder Associates Limited, to conduct the study. A copy of the full study report dated March 2007 is provided in Appendix IV of the Addendum to Evaluation of “Alternative to” and Selection of a Preferred Disposal System.

• The land area requirements for landfill operations of the scale being contemplated by Niagara and Hamilton are large relative to other processing facilities typically incorporated in municipal waste management systems. In addition, due to the outdoor nature of operations, landfill sites present a range of potential off-site impacts/nuisances which may only be managed by additional land forming a buffer for surrounding receptors. Even with a recognition that ‘farmland’ resources/designations are not intended for landfill sites, and that waste management generally represents an inappropriate use of farmland, the respective landfill area requirements combined with the need for some remoteness established by buffer lands has historically led landfill siting processes to rural/agricultural areas.

• The success of a landfill siting process looking at industrially-zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities. Landfilling on designated industrial/employment lands would be inconsistent with applicable Provincial policy and land use planning principles intended for the prevention of urban sprawl. Notwithstanding, the availability of vacant industrial lands in Niagara and Hamilton has been reviewed and is discussed in Section 4 of the Addendum to Evaluation of “Alternatives to” and Selection of a Preferred Disposal System..

• Also recommend remediation of existing landfills be a part of any long term plan, with similar end-results as those at Glenridge and on William Street on Niagara-on-the-Lake.

• Comment noted.


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Stakeholder/Agency

Comment Received

Response

Gracia Janes


• Incineration is undesirable because it will add considerable pollutants such as mercury, cadmium, and fine particulate matter to our air which will exacerbate the already poor air quality in Niagara/Hamilton and existing health problems.

• Emission factors established from a range of modern EFW facilities were considered and input to the lifecycle analysis where applicable and in all cases, emission levels were found to, at a minimum, meet the emission standards applicable in Ontario. Notwithstanding, at the siting stage, the impact of potential sites on surrounding air sheds will be evaluated at an increasing level of detail as the choice of sites is narrowed. For the preferred site, detailed air modeling and a site specific health and ecological risk assessment will be undertaken to ensure that all air quality standards are achieved and that there would be no unacceptable risks posed to human or ecological health.

• Incineration is undesirable because it will pollute our fruit lands, prime farmlands, natural areas, lakes and streams, and these pollutants will collect in our soils regardless of where an incinerator is placed, due to the unique air drainage systems in Niagara i.e. the Escarpment/Lakes effect and the prevailing south-westerly winds.

• Emission factors established from a range of modern EFW facilities were considered and input to the lifecycle analysis where applicable and in all cases, emission levels were found to, at a minimum, meet the emission standards applicable in Ontario. Notwithstanding, at the siting stage, the impact of potential sites on surrounding air sheds will be evaluated at an increasing level of detail as the choice of sites is narrowed. For the preferred site, detailed air modeling and a site specific health and ecological risk assessment will be undertaken to ensure that all air quality standards are achieved and that there would be no unacceptable risks posed to human or ecological health.

• Incineration is undesirable because it will run the risk of leach-out of concentrated heavy metals from the landfills (needed for bottom ash), and wherever the stack ash is stored – near or far away – in someone’s backyard.

• Please see response provided in Section 3.4 of Substantive Issues Discussion Paper (March 9, 2006) under Thermal processes produce ash which is contaminated and which must be managed appropriately (pg 11).


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Stakeholder/Agency

Comment Received

Response

Gracia Janes


• Incineration is undesirable because it will draw away from the optimization of producer and public stewardship and waste reduction, reuse, recycling, and reclamation, and encourage the continued, and even accelerated, production and use of difficult-to-destroy products such as plastics.

• Thermal facilities are not a barrier to diversion when they are sized and operated appropriately and where diversion has been accorded priority in the municipal waste management system as is proposed for Niagara and Hamilton.

• Please see response provided in Section 3.5 of Substantive Issues Discussion Paper (March 9, 2006) entitled Relationship of Recommended System and Waste Diversion (pg 12).

• Both Niagara and Hamilton intend to continue to participate in initiatives to lobby provincial and federal levels of jurisdiction on initiatives such as industry stewardship.

• Incineration is undesirable because it will be much less flexible and unable to adapt - as new producer responsibility laws come into effect; new renewable and less environmentally damaging hydro sources come on stream; markets open up for recyclable goods; and laws change to introduce higher 3R targets.


• Incineration is undesirable because it will be more expensive, particularly as predetermined/fixed waste quotas are required for efficient operation of the incinerator.

• Please see response provided in Section 3.7 of Substantive Issues Discussion Paper (March 9, 2006) entitled Consideration of Costs and Affordability (pg 15).


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Stakeholder/Agency

Comment Received

Response

Gracia Janes


…cont’d

• Incineration is undesirable because it will risk Niagara/Hamilton being the incineration centre for other municipalities in this part of the Great Lakes (particularly if we can’t meet our waste targets due to increased recycling efforts).

• This study is being completed to address disposal requirements for Niagara and Hamilton following at-source diversion programs.

• Over the course of the study, it may be apparent that opportunities exist to provide excess capacity in the early stages of the planning period to neighbouring municipalities provided it would benefit the proponents and the broader environment. Municipal solid waste originating from outside the study Area, particularly from smaller neighbouring communities, would offer a potential waste stream that could be managed by surplus capacity incorporated into the undertaking, should this be determined to be beneficial.

• Incineration is undesirable because it will risk Niagara/Hamilton being the waste disposal centre for international air flights, as per a request of the Hamilton International Airport, of the City of Hamilton.

• Management of international waste requires a special disposal permit. Inclusion of this special waste will be determined while undertaking EPA level studies.

• There are currently other facilities in close proximity to the Hamilton International Airport that take this type of waste.

• Incineration is undesirable because it will be a private/public partnership, where corners may be cut to save money, and ‘proprietary rights’ are used by the private sector to keep certain information away from the public domain; and where there is a risk that companies may run into financial trouble.

• No decision has been made regarding the ownership of the facilities required to implement the preferred system. This decision will be made as part of the competitive process used to implement the system as part of the evaluation of “Alternative Methods”, which is the next major step in the EA study.


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Stakeholder/Agency

Comment Received

Response

• Incineration is undesirable because it will draw funds away from Niagara/Hamilton into other municipalities areas where industry and the government will invest their waste diversion money.



Gracia Janes


…cont’d

• Incineration is undesirable because it will set a bad precedent, as an incinerator in Niagara/Hamilton will be the first one in Ontario since the early 1980’s (with the exception of an addition on the Peel plant).

• Comment noted.

• In choosing Option 2b the consultant has downplayed the considerable benefits of Option 1 (outlined in its own reports) which state that is has, for instance: o The lowest net global air impacts o The highest potential for diversion from

disposal o The lowest net acid gas emissions o The lowest net heavy metal and organic

emissions

• Further, Option 1 is one of the lowest net smog precursors; and is the most flexible option, able to ensure that Niagara/Hamilton’s 65% waste diversion target is met.

• In accordance with Step 1 of the alternatives evaluation methodology, the preferred system was identified as the one exhibiting the preferred balance of advantages and disadvantages considering the significance of a broad range of environmental categories and criteria (natural environment, social/cultural, technical and legal as well as economic/financial) established by the public.


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Stakeholder/Agency

Comment Received

Response

Gracia Janes


…cont’d

• Option 1 will also, among other things: o Encourage more citizen, government,

retailer and producer stewardship o Enhance our economic base, through the

creation of more value added products and jobs

o Bring government and industry investment into Niagara/Hamilton through waste diversion program funding

o Allow for a much higher diversion target than 65% as new producer responsibility laws come into effect and markets come open for new post diversion products.

• One of the advantages identified for System 1 was a potential increase in diversion through the recovery of recyclables inappropriately discarded by the public in the disposal stream.


• The majority of the points provided in this comments are valid with regards to steps necessary to achieve and exceed a diversion target of 65%. They are not, however, believed to be influenced by selection of the system for disposal of the materials that are not diverted.

• Option 2b was apparently chosen on the basis that it may face fewer legal hurdles (a lowly ranked criteria for the public involved in the consultation); and, is the “preferred system for the majority of natural environmental criteria”. Council of Women could accept this decision, if the evidence was there to back it up.


• The background and supporting rationale for identification of the natural environmental advantages associated with the preferred system are fully documented in the draft report and appendices. The Addendum Report further considers the natural environmental attributes of the various systems given different background assumptions and reconsiders the preferred system recommendation in light of this additional information.


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Stakeholder/Agency

Comment Received

Response

Gracia Janes


…cont’d

• We cannot understand why the region would choose to release any contaminants such as mercury or cadmium, into the air, if by choosing Option 1 they could avoid this. Why add to an already overloaded area?

• Please see response provided in Section 3.4 of Substantive Issues Discussion Paper (March 9, 2006) entitled Nature and Fate of Contaminants from Recommended System (pg 8).

• Study states that we have “good air quality”, yet this is countered by the Regional Health Department’s web site, which states that “In southern Ontario communities that are prone to high smog levels, such as the Niagara Region, poor air quality poses a serious risk for the most vulnerable members of our society – including young children and elderly people, and those who suffer from respiratory and cardiac problems. In fact, smog can also have adverse health consequences for Ontario residents who are normally quite healthy.”


• In an attempt to prove Niagara/Hamilton has good air quality, the consultant uses the Provincial air-pollution index, but is has been known for years that the index understates the problem.



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Stakeholder/Agency

Comment Received

Response

Gracia Janes


…cont’d

• The consultant’s non-precautionary analysis method reflects a superficial attitude towards public health. Council of Women sees a definite need for Niagara/Hamilton Councils to closely consider the overall maintenance of their citizen’s health as an important factor in this project before making a final decision.

• In the consideration of “Alternative Methods (i.e., sites) relative potential health impacts will be considered via other community specific indicators such proximity to residential areas and number of residents within these neighbouring communities, again with the understanding that established regulations and guidelines have been set at an appropriate level to protect public health.

• Following the approval of Thermal Treatment as the preferred “Alternative To” by Council, a comprehensive review of the potential human, economic and ecological impacts of Thermal Treatment, specific to the Hamilton/Niagara Study Area would be undertaken as part of the siting process. Input received from the analysis of the potential for human, economic and ecological health impacts will represent an important component of the siting of a long-term waste processing facility.


• Health Canada’s request that health be an “exclusionary” criteria reflects this same concern, but was rejected by the consultant as unnecessary, until a preferred technology and site were chosen. To add weight to this answer, the consultant also repeated a much-stated response to any questions regarding environmental or health impacts, that any technology would have to abide by “established regulations and guidelines” We note that to date, all information as to this satisfactions of requirements comes from the vendors.



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Stakeholder/Agency

Comment Received

Response


…cont’d

• Our concerns that air drainage patterns will cause incinerator air emissions to negatively impact Niagara fruit lands was echoed by the Niagara Escarpment Commission. The consultant ignored the problem of Niagara fruit lands being a particularly sensitive agricultural area, preferring to refer the Commission to mitigative work, once a site and technology was chosen.



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Stakeholder/Agency

Comment Received

Response

• Annex D-2 Environment Potentially Affected: Terrestrial and Aquatic Environment has the following errors: o Fonthill is left out as a fruit growing area. o No mention is made of the inter-

relationship of the Escarpment and Lakes Ontario and Erie that allows for the very successful growing of tender fruit and grapes.

o This is no connection made between the list of features in the terrestrial and aquatic environment and the wonderful Carolinian habitat and fruit land resources we have that could well be impacted by fallout from an incinerator.

o Some of this latter information is contradicted by Annex D-3, where the Escarpment/Lake inter-relationship is well explained, but Hamilton’s 65 acres of tender fruit land is lumped in with Niagara’s 15,000 acres of tender fruit land and 15,000 acres of grape land, which is quite misleading.

• Annex D-2 has been revised. Gracia Janes


…cont’d

• Annex D-3, Environment Potentially Affected: Agricultural, condenses its description of the Greenbelt, so that we are left with the impression that there are 100,000 acres of fruit land “permanently protected by the Greenbelt”

• Annex D-3 has been revised.


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Stakeholder/Agency

Comment Received

Response

• The consultants have jumped to the conclusion that incineration will have less impact on the terrestrial and aquatic environment. They have omitted from the calculation that: o Bottom ash must be tested for toxicity and

some securely managed. o Incineration actually increased the toxicity

of the stack ash and bottom ash and hence its danger if it leaches out of a landfill into terrestrial or aquatic ecosystems.

o The fugitive stack ash emissions (when the operation is interrupted or not operative efficiently) will emit more toxic pollutants e.g. mercury etc. than predicted.

o Incineration has far more potential to impact the environment – both near at hand and much farther away, while pre-treated waste, combined with a very secure landfill will impact the aquatic and terrestrial environment to a lesser degree.


Gracia Janes


…cont’d

• The consultants rely on the A-7 Air Quality Standards that they have insisted are very strict, when in fact until recently they were 30 years out of date, relying on “point of impingement” measurements and “dilution is the solution to pollution”, and still do not account for the accumulation of pollutants.

• Please see response provided in Section 3.4 of Substantive Issues Discussion Paper (March 9, 2006) under Overall concern with air emissions and health related impacts (pg 8).

Dr. John Bacher

(PALS) • Support Option 1 over 2B. Agree with the

elimination of the other six options. • Comment noted.


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Stakeholder/Agency

Comment Received

Response

• Disagree with combining combustion and gasification technologies for the thermal options. The impact for instance, of combustion in producing heavy metals would be different than under gasification. Concerns about gasification are primarily not concerning heavy metal emissions, but about the reliability of the technology and its costs, which the Task Force indicates, very little data is currently available.

• Combustion, gasification and pyrolysis produce essentially the same results and are subject to the same regulatory requirements, they have been deemed to be functionally similar and considered as a single alternative under the description of “Thermal Processes”.

• An RFP process will be used to select a vendor of the preferred technology following the selection of a preferred Niagara-Hamilton site. The preferred vendor would have to prove the reliability of their technology in their RFP submission.

• The consultant’s report did not examine a specific gasification option, but linked them in with four thermal options. Part of the impact of this combination was to legitimate the use of the term “Thermal” option.


• If in the future, a gasification process was adopted, the cost of following Option 2b could be greater than is now being considered.

• Comment noted.

Dr. John Bacher

(PALS)…cont’d

• A period of one year needs to be set aside for further study. The highly focused nature of the discussion on two clear alternatives should generate more public input. The review should seek to determine why the various thermal options combined combustion and gasification technologies in terms of specific data. The year long study period should not examine eight possible alternatives, rather it should review Option 2b and Option 1, with 2b being divided into a combustion and incineration alternative.



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Stakeholder/Agency

Comment Received

Response

• Option 1 needs more public exposure. General public doesn’t know much about it. Much of the support for incineration is because of the lack of familiarity with the reality of alternatives to conventional, unstabilized landfills and a backlash from problems arising from the existing landfills in Niagara. Also, meetings over the past few years have been geared towards the strong recommendation of the consultants that landfills are the “do nothing’ approach and from the political attitude that there should be no more of these.


• During the course of the EA study, there will be numerous opportunities for public consultation during which the public can learn more about the options being considered. Additional information is also available at www.wasteplan.ca.

Dr. John Bacher

(PALS)…cont’d

• Positive feature of the study is that it clearly spells out that there is an alternative to conventional landfills. A previous study by the consultants points out that Halifax, Nova Scotia, has such a stabilized landfill and that it has the best record in waste reduction in Canada.

• Comment noted.

• Would be beneficial if the consultants were to prepare an additional report that would give more information on the operation of stabilized landfills from around the world, in addition to the one which it detailed in the City of Halifax.

• The Joint Working Group commissioned a Stabilized Landfill Study and retained the services of Gartner Lee Limited (GLL), in association with Golder Associates Limited, to conduct the study. A copy of the full study report dated March 2007 is provided in Appendix IV of the Addendum to Evaluation of “Alternative to” and Selection of a Preferred Disposal System..


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • The consultant should examine how Hamilton-

Niagara’s proximity to major industries, which could use some of the materials recovered from the waste stream, could cause our region to have the potential for a better record in reduction than the City of Halifax.

• Comment noted.

• The year long study can also examine other jurisdictions that have a similar approach to waste management as Halifax e.g. San Francisco.

• The Joint Working Group has had an opportunity to visit the Otter Lake Facility in Halifax and will be evaluating waste management systems in other municipalities.

• Reasons given for Option 2b to be considered superior to Option 1 have serious flaws. E.g. if we are serious about reducing air pollution, which the consultants admit, is best addressed through Option 1 then Option 2b is a non starter. The consultants also agree that Option 1 has the best potential to encourage waste reduction. Option 1 would also produce more energy savings (from the reduced need to use virgin materials), than the electrical production achieved from incineration.


• Much of the data regarding Option 2b is questionable and could be based on picking between two very different gasification and combustion technologies.



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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Much of the justification for Option 2b over 1 is

based on the alleged superior “legal” benefits. If should be pointed out that this category, is considered the least significant by the general public. Despite this insignificance, it was given a big role in the preference of Option 2b.


• The basis of the superior legal criteria for Option 2b over 1 is the assumption, based on the pattern of regional landfills around the world (not cited by in the study, but stated in response to a question from PALS in the press conference), that the landfill associated with Option 1 could not be located on a site which would be appropriately industrially zoned since it would consume, “hundreds of acres” of land. Stabilized landfill would only require about 49 hectares. Such a facility, could be located on rural land, which is not industrially zoned, eliminating the rationale for the “legal option”. Also, the amount of land to be saved from preferring 2b over 1 is only 22 hectares.

• The Joint Working Group commissioned a Stabilized Landfill Study and retained the services of Gartner Lee Limited (GLL), in association with Golder Associates Limited, to conduct the study. A copy of the full study report dated March 2007 is provided in Appendix IV of the Addendum to Evaluation of “Alternative to” and Selection of a Preferred Disposal System..

• The comment implies that the impact of a landfill operation on rural lands is more acceptable from a legal standpoint compared those lands designated agricultural. From a legal standpoint, Official Plan amendments would be required on lands with either designation. It is agreed that the amendment on rural lands would present a greater degree of approvability compared to agricultural lands which are protected by Provincial Policy.

• In the alternative, waste processing facilities are considered more consistent with industrial land designations and, due to their indoor nature, more compatible with surrounding industrial uses.

• Although both landfill sites and thermal processing facilities may present challenges with regards to land use compatibility and approvability under the Planning Act and related Provincial Policy, the later remains preferred in this regard.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • A comment by one of the consultants at the press

conference that those who place a higher value on protecting land rather than air would prefer Option 1 is highly offensive to PALS. Our mandate is to protect land.

• Comment noted.

• There is a large buffer category of 178 hectares which might possibly be disrupted by an Option 1 facility, which would not be needed for an actual landfill site. This is less than the 193 hectares needed for a conventional landfill. 58 hectares is potentially disrupted by Option 2b. This large zone, could encourage the location of the facility outside of industrial zoning, again dissipating the “legal” rationale for preferring Option 2b over 1.

• Acknowledged. However, with System 2B the primary component of the disposal system being located in a compatible land use designation (i.e. industrial) combined with the substantially lower landfill area requirement maintains the preference over a landfill based system (1 or 3).


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • The ease of locating Option 1 within a suitably

industrial zoned site is increased if the landfill is located in different areas.

• The success of a landfill siting process looking at industrially zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities. Landfilling on designated industrial/employment lands would be inconsistent with applicable Provincial policy and land use planning principles intended for the prevention of urban sprawl. Notwithstanding, the availability of vacant industrial lands in Niagara and Hamilton has been reviewed and is discussed in Section 4 of the Addendum to Evaluation of “Alternatives to” and Selection of a Preferred Disposal System.

• Although the search for two or more smaller landfill sites may increase the likelihood of finding suitably sized land parcels, based on the above, the success of a landfill siting process looking at industrially zoned lands only would continue to be challenged and is considered an unreasonable assumption for use as a basis for selecting a landfill based disposal system.

• If a stabilized landfill could be located in an industrial zoned site, then the land and legal jurisdictions for preferring incineration would be eliminated.

• Agreed. However, the success of a landfill siting process looking at industrially zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities (see response to comment 92 in Table 6-1). An assumed industrial site for a stabilized landfill is considered an unreasonable assumption for use as a basis for selecting a stabilized landfill disposal system.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Annex D-4, p. 10, says “Hamilton has an

abundance of land that is zoned to permit heavy industry and outside storage”. Such areas would be well suited for an Option 1 facility. The extent of these areas are detailed in the listing of Business Parks in Annex D-5, p.3-7.

• The success of a landfill siting process looking at industrially zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities (see response to comment 92 in Table 6-1). An assumed industrial site for a stabilized landfill is considered an unreasonable assumption for use as a basis for selecting a stabilized landfill disposal system.

• The study underestimates the Business and Industrial Parks in Niagara – completely omitting for instance, unserviced industrial areas such as Pelham’s Webber Road industrial park, and all industrial lands in Fort Erie.

• Section 3.1.4 of Annex D-5 has been revised.

• Large parcel of land in the vicinity of Lyons Creek, is currently being re-zoned from industry to tourist-commercial. The site, like most of the 11,000 vacant acres in Niagara, has a significant Carolinian forest, surrounded by a large area or regenerating scrub. It would be appropriate for a stabilized landfill, with the scrub being the landfill site and the forest the buffer.

• Comment noted.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • PALS is also concerned about the potential loss

of valuable Carolinian forests, which include rare Pin Oak Swamp communities, in the large industrial parks of the southern part of Niagara. One of the best ways to protect some of this area is to incorporate these forests into a buffer around a landfill in an industrial park. In the process the forests could actually be expanded and buffered – resulting in a net increase in bio-diversity from Option 1 and a beneficial impact on sensitive habitats.

• Comment noted.

• Annex D-3, Environment Potentially Affected: Agricultural exaggerates the legal difficulties in getting a re-zoning of agricultural land. For instance, on page 5-2 it states that “All Prime agricultural areas, as designated by Hamilton and Niagara’s Official Plans, are “permanently protected.” This is inaccurate.

• Annex D-3 has been revised to provide details on exceptions for redesignating prime agricultural areas in municipal official plans for non –agricultural uses.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • One prudent way to obtain a site if, it is accepted

that a zone can be found within the current zoning envelope for Option 1, would be to locate it within a corner of the much larger 1,200 acre Aerotropolis development if its re-zoning is approved. It is simply nonsense to say that farmland would be saved by Option 2b, if the site was located on land that would be lost for industrial development in any event associated with Aerotropolis. Other area would be the considerable land area outside the City of Hamilton, which was left out of the Greenbelt.


• The success of a landfill siting process looking at industrially-zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities. Landfilling on designated industrial/employment lands would be inconsistent with applicable Provincial policy and land use planning principles intended for the prevention of urban sprawl. Notwithstanding, the availability of vacant industrial lands in Niagara and Hamilton has been reviewed and is discussed in Section 4 of the Addendum to Evaluation of “Alternatives to” and Selection of a Preferred Disposal System..


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • From a discussion I had with a member of the

Task Force it appears that much of the desire for Option 2b is simply ease of location. I was actually told by a member of the Task Force that the reason this is happening is because in Hamilton-Niagara there are not a lot of people who support Zero Waste as a concept just to stop incineration.

• Each system was evaluated using methodology and evaluation criteria presented in the EA Study Terms of Reference which has been approved by Regional Niagara Council, City of Hamilton Council and the Ministry of the Environment (MOE). The selection of the preferred system was based on a review of all of the advantages and disadvantages for each system.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • There will be a strong NIMBY opposition to an

incinerator once a site is proposed. This can be guaranteed from PALS own experience in the opposition to the failed toxic waste incinerator in Niagara. It should be pointed out that the flaw that killed this incinerator i.e. possible leaching into ground water of the landfilled incinerator ash – would apply equally to this facility. Was found that the only way to prevent leaching from toxic ash was to contain the ash and char in ceramic containers.

• The Niagara-Hamilton WastePlan study team recognize that any of the alternatives physical, biological, thermal or landfill will all likely have some form of local opposition. This opposition will be managed as part of the siting process through an extensive consultation process.

• In Ontario, bottom ash regularly tests below hazardous waste limits for all parameters using the methodology set out in ON Reg. 347, and thus us classified as a municipal solid waste and can be disposed in a conventional landfill site.

• The fly ash captured in the air pollution control system must be managed appropriately either by disposing of it in a secure landfill or by chemically treating it in a manner to render it safe for disposal in a conventional landfill. It can be argued that by concentrating the contaminants in the air pollution control residue and managing this material in a secure landfill, a higher degree of environmental protection is provided – compared to the conventional landfilling of the waste containing all the heavy metal contaminants.



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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Another rationale for Option 2b over 1 is water

pollution. The greater the air pollution caused by Option 2b over 1, will in itself be a major source of water pollution through contamination be precipitation.


• Water pollution from a stabilized landfill can be further reduced through a combination of good design and the use of constructed wetlands. Using constructed wetlands will enhance the value of the site for wildlife habitat. PALS has not see any results that indicate this cannot be achieved from the consultant’s report.

• Acknowledged. Such design features would be contemplated at the design phase for any landfill forming a component of the long-term disposal system.


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • There is no indication in the report of the

groundwater contamination that will come from the leaching of landfilled ash.




• The stack ash, and even the bottom ash from municipal incinerators is more toxic after incineration at high temperatures and care will have to be taken to make it secure. This factor is not highlighted in the consultant’s report.

• Please see response provided in Section 3.4 of Substantive Issues Discussion Paper (March 9, 2006) under Thermal processes produce ash which is contaminated and which much be managed appropriately (pg 11).


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Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • PALS is strongly opposed to the use of energy

generation as a criteria in ranking various waste disposal systems. We are opposed to this because by the time the facility is actually operating, technology changes regarding the reduced cost of renewable technologies…would make such considerations obsolete. Most of the cost benefit, (another lowly ranked option by the public), also comes from the electrical generating aspect of electricity from incineration.

• Please see response provided in Section 3.2 of Substantive Issues Discussion Paper (March 9, 2006) under Energy recovery should not be included in the natural environmental category (pg 7).

• The Province of Ontario has a goal to phase out all electrical generation from coal because of concerns for air pollution. It appears absurd, while pursuing this goal, to have new incinerators to generate electricity by burning garbage.

• Comment noted.

• Should be stressed that the level of emissions identified for incineration is based on the assumption of the efficient operation of the facility, which may be disrupted, giving this option far less reliability than a stabilized landfill.

• An RFP process will be used to select a vendor of the preferred technology following the selection of a preferred Niagara-Hamilton site. The preferred vendor would have to prove the reliability of their technology in their RFP submission.

• Pollution from an incinerator has been on some occasions trivialized by comparison to trucks. Such comparisons are not warranted when it is considered that the additional air pollution caused by an incinerator, can be prudently avoided by the use of Option 1.

• Comparisons were only provided to put the air emission into context.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Incineration has a basic need for an assured

supply of waste. If this waste does not come from within Niagara, it will have to be imported from elsewhere to ensure high efficiency burns.


• Over the course of the study, it may be apparent that opportunities exist to provide excess capacity in the early stages of the planning period to neighbouring municipalities provided it would benefit the proponents and the broader environment. Municipal solid waste originating from outside the study area, particularly from smaller neighbouring communities, would offer a potential waste stream that could be managed by surplus capacity incorporated into the undertaking, should this be determined to be beneficial.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Building an incinerator conflicts with branding

Niagara as a tourist area, and consumer to each our fruit, and hinder the market of our grapes and tender fruit to processors e.g. Cadbury Schwepps threatened to halt purchases of grapes from lands that perceived could be affected from fallout from the incinerator.

• In 1999, the Ministry of the Environment (MOE) released a study assessing the risks associated with incineration to human and ecological health. In this study, the MOE concluded that no significant health effects are likely in a typical suburban community located near an incinerator. They also predicted that water and sediment quality near an incinerator would meet ministry guidelines for protection of aquatic life. Since the release of this document, even more stringent air emission regulations have been released and enforced by the Province, further reducing the potential impacts related to the types of facilities studied in 1999.





-DRAFT-


Stakeholder/Agency

Comment Received

Response

Dr. John Bacher

(PALS)…cont’d • Background papers about the economic strategy

(e.g. Anne D-4) of the City of Hamilton suggest that the incineration option is being proposed to build an economic strategy based on making incineration an economic specialization for our community in the Great Lakes basin.

• Annex D-4 provides an overview of the current economy in Niagara and Hamilton, and provides information on the potential costs and affordability of the waste disposal systems that are being evaluated at this stage in the EA process, based on the results of detailed cost estimates that have been developed to support the evaluation of “Alternatives to”.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

David Griffith

(Lake Gibson Park Lte) • Concerned that atmosphere of Southern Ontario

is already overloaded with pollution. Concerned about the health of children. Are our children the canaries in the coal mines?



• Following the approval of Thermal Treatment as the preferred “Alternative To” by Council, a comprehensive review of the potential human and ecological impacts of Thermal Treatment, specific to the Hamilton/Niagara Study Area would be undertaken as part of the siting process. Input received from the analysis of the potential for human and ecological health impacts will represent an important component of the siting of a long-term waste processing facility.

• Concerned about methane from open pit composting and sewage lagoons, green house gas recovery and elimination of offensive odours.

• Comment noted.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

David Griffith

(Lake Gibson Park Lte)…cont’d

• Concerned about NIMBY effect on real estate values and political problems.

• Comment noted.

• Encourages the exchange of building materials through drop-off/pick-up programs.

• Various strategies will be considered by both communities as they pursue their goal of 65% diversion.

• Encourages re-use of lumber (as is or chips) and plaster (gypsum) and separating treated wood as hazardous.


• Suggests the recovery of combustibles deprives the incinerator of fuel. That the need for supplementary fuel is a disincentive to recycle.



• Criticizes apartments, builders, commercial and industrial operations that still use unsorted dumpsters for landfill.

• Comment noted.

• Encourages “return for deposit” programs, and all coloured glass returned to vendors.


• More analysis needed on exhaust gas (composition, treatment, monitoring, etc). Ontario minimum standard is outdated.

• Comments will be considered over the course of the EA.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

John Jackson

(Citizens’ Network on Waste Management)

• Inadequate supporting documentation to help understand consultant’s recommendation of Option 2B. Only provide two annexes – Annex E-4 and E-5. Information in them is meager. Ex: Anne E-4 is only 26 pages long and is made up primarily of tables without providing the sources of the numbers. This failure to provide sources is consistent throughout the entire alternatives analysis. Makes it impossible for a reviewer to assess the adequacy of the supporting information.

• Annex E should be reviewed to reference and understand the evaluation outputs and the inputs to the various models and or spreadsheets applied.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

John Jackson


…cont’d

• Comparison of alternatives in the document not rigorous. Is very qualitative, using a “yes-no” method without a weighting of the relative differences among the “yes-no’s” when the criteria are added up.

• Section 8.1 of the report on “Alternatives to” provides our rationale and a detailed reasoning for use of a qualitative versus quantitative comparative evaluation process.

• We are unable to identify such a reference in the draft report or any previous documentation and are of the opinion that such a reference serves to over simplify the approach applied. Rather the concerns with the qualitative approach appear to be founded on the use of “professional judgement” and a perceived lack of detail in the documentation supporting the various decisions. We have noted where concern exists with the supporting background documentation and these issues will be specifically addressed during finalization of the draft report and the preferred long-term disposal system.

• With regard to the use of “professional judgement” a more accurate reference to the technique would be “professional experience” or “experienced judgement”. The key aspect of this technique is that of ‘experience’ and the experience of the consultant / staff team with past relevant professional consulting, planning, and/or engineering services. In moving forward and reviewing and responding to specific comments on the draft report an effort will be made to expand on descriptions of sources and experiences when experienced judgement is being applied.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

John Jackson


…cont’d

• From environmental burden consideration, stabilized landfill (System 1) is preferred over incineration (System 2B). This is concluded from the following comments:

• Conclusion that incineration is the best option for impact to land resources is incorrect. Inappropriate assumption that landfill would be sited on agricultural land and the incinerator on industrial land. Landfill could be placed on industrially-designated land. Therefore, criterion number 4 for “Environmental burden at a global or macro environmental scale” should have been neutral.



• The success of a landfill siting process looking at industrially-zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities. Landfilling on designated industrial/employment lands would be inconsistent with applicable Provincial policy and land use planning principles intended for the prevention of urban sprawl. Notwithstanding, the availability of vacant industrial lands in Niagara and Hamilton has been reviewed and is discussed in Section 4 of the Addendum to Evaluation of “Alternatives to” and Selection of a Preferred Disposal System.

• See Section 3.2 of Draft Consideration of Substantive Issues Discussion Paper (March 9, 2006) related to aggregate air and water emissions.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

John Jackson

(Citizens’ Network on Waste Management) …cont’d

• Emissions of contaminants to water are overstated for a stabilized landfill. Consultants assumed water contamination from a stabilized landfill would be the same as from a regular landfill. Major reason for stabilizing wastes before putting them into landfill is to reduce water contamination potential.

• Inappropriate to give equal weighting to the differences in water and air emissions when they come to a conclusion on overall environmental burden. The differences in the emissions to air are dramatically higher than the differences to emissions to water. These differences should be taken into account when coming to a final decision on which system is preferred. To arrive at a proper comparison it would be appropriate to combine air and water releases for the substances. Results are provided if such an analysis was run and conclude that stabilized landfill is the preferred system.



• The success of a landfill siting process looking at industrially-zoned lands only would be challenged by the availability of suitably sized parcels of land and more significantly by the land acquisition costs and displacement of valued employment lands designated by both municipalities. Landfilling on designated industrial/employment lands would be inconsistent with applicable Provincial policy and land use planning principles intended for the prevention of urban sprawl. Notwithstanding, the availability of vacant industrial lands in Niagara and Hamilton has been reviewed and is discussed in Section 4 of the Addendum to Evaluation of “Alternatives to” and Selection of a Preferred Disposal System.

• See Section 3.2 of Draft Consideration of Substantive Issues Discussion Paper (March 9, 2006) related to aggregate air and water emissions.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

John Jackson


• From the conservation/preservation of non-renewable environmental resources, stabilized landfill and incinerator are possibly equal but more likely in favour of landfill because of the potential to increase recycling. This is concluded from the following comments:

• Consultants conclude that incineration is preferred because of the energy the incinerator generates. Conclusion is flawed because: o Experience shows projections for energy

generates and sold from garbage incinerators are usually inflated.

o More energy is saved by making new products out of recycled materials instead of raw materials than is generated by a garbage incinerator (Source provided).

o Fails to take into account that expanding waste reduction and recycling works counter to energy generation from the incinerator. (Source provided).

• Current experience with modern EFW facilities is reflected in the evaluation process. Referenced facilities include those in Canada, the U.S.A and Europe. In the original evaluation, only the generation of electricity was factored which is a conservative assumption.

• See Section 3.2 of Draft Consideration of Substantive Issues Discussion Paper (March 9, 2006) for additional detail regarding other points on energy recovery.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• For the potential for disruption of sensitive habitats, the comparison of stabilized landfill and incineration should arrive at a neutral conclusion. This is concluded from the following comment:

• Consultants conclude incineration is preferred regarding potential for disruption of sensitive habitats. Assumes that a landfill would be located adjacent to sensitive areas. The standing criteria for landfills always include avoidance of sensitive terrestrial and aquatic habitats as a critical factor.

• This criterion considered the potential disruption which is considered greater for landfill given its location and area.

• Agree with the consultants that stabilized landfill is preferred from the potential to increase disposal diversion rate and/or make best use of residual waste materials.

• Comment noted.

John Jackson


• Summarize that their analysis shows that from the perspective of overall impact on the natural environment, the stabilized landfill is the preferred system.

• Comment noted.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• Criticize Annex E-4 for having insufficient detail to be able to conduct an appropriate critique of the analysis. Specifically identify two areas of concern: o Positive ranking for incineration option

relies primarily on revenue from the sale of energy from the plant. Sources are not provided to justify the sale numbers provided. And as highlighted before experience shows that energy generation numbers are not reliable, especially if waste diversion increases.

o Under the stabilized landfill option revenue is shown from the sales of recyclables captured. There is no revenue line, however, for revenue derived from industry contributions to municipal loses on their diversion activities, which is provided through WDO. With the incineration option, the municipality is stuck with all the costs. With the mechanical treatment facility attached to the stabilized landfill, industry will have to pay part of the municipal costs.

• Current experience with modern EFW facilities is reflected in the evaluation process. Referenced facilities include those in Canada, the U.S.A and Europe. In the original evaluation, only the generation of electricity was factored which is a conservative assumption.

• See Section 3.2 of Draft Consideration of Substantive Issues Discussion Paper (March 9, 2006) for additional detail regarding other points on energy recovery.

• There is no precedence to establish that WDO would fund an MBT plant. If this opportunity were available, given the small quantities of recyclables assumed to remain for capture by a plant, the amount of funding would be very limited. The exclusion of this consideration is considered a conservative assumption similar to the assumed standard rate and sale of electricity only from EFW.

John Jackson


• Urge Niagara and Hamilton not to accept the financial conclusions until much more detail is provided on the bases for the numbers used and another opportunity is provided for the public to assess the new information.

• Comment noted.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• By choosing incineration, door will be closed on going beyond 65% diversion over the next twenty years because materials will have to be burnt to feed the incinerator.

• The draft report on Additional At Source Diversion identified examples of some of the best performing at-source diversion programs worldwide. There is a variation of opinion and information available on the performance of waste management systems, that is evident when examining the issues of potential conflicts between source separated diversion programs and the issue of thermal treatment. In the study of the jurisdictions used to develop the draft report, it was found that many of the European jurisdictions that are achieving the highest at-source diversion rates, also recover energy from their post diversion residual waste stream, thus minimizing their landfill requirements.

• Section 5.2.2 of the Addendum Report describes how as part of the sensitivity analysis the assumptions of overall at-source diversion over the 25 year planning period from 2013 onwards, have been adjusted to allow for a small incremental increase in at-source diversion over the 25-year period of time from 2013 to 2037 from 65% to 70% diversion.

• By choosing incineration, industry will be let off the hook in terms of assuming their financial responsibilities.

• Comment noted.

John Jackson


• Recommend choosing to go beyond 65% diversion and choosing a stabilized landfill with pretreatment (system 1).

• Comment noted.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Susan Corcoran

(Council of Canadians – Niagara Chapter)

• Capital costs to build incinerator will lock the region into an expensive, dead-end option. Expenditure would deny flexibility to explore or adopt other technical options as they become available. Yet, region will still require a landfill for the highly toxic/hazardous ash residues.

• The financial implications of Thermal Treatment have been assessed as part of the evaluation of “Alternatives to”. It was found that Thermal Treatment, although currently more expensive than conventions landfill, is comparable in expense when compared to other forms of waste disposal and some forms of waste diversion.


• The flexibility of the systems was considered in the evaluation of “Alternatives to” including their ability to manage variable waste streams, seasonal variations in waste, and incorporation of new technologies that become available.



• Please see response provided in Section 3.4 of Substantive Issues Discussion Paper (March 9, 2006) under Thermal processes produce ash which is contaminated and which much be managed appropriately (pg 11).


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Susan Corcoran


…cont’d

• Niagara already endures horrendous air quality. Incinerator will add additional pollutants. Effects of each additional contributor of air pollution is not in isolation but rather cumulative. Must consider combined effects of this project with other local development plans that will impact air quality – such as widening Hwy 406 and QEW. May seem acceptable when considered individually but should be judged as a whole.

• Detailed studies related to human and environmental health are more appropriately dealt with as part of the evaluation of “Alternative Methods” (i.e. facility siting).

• As part of the siting process, cumulative effects will be study and taken into consideration.

• Concerned about the release of heavy metals such as mercury from the incinerator. Recognizes that technology can stop release of 90% of the mercury, but worried about remaining 10%. Stressed that many heavy metals and chemicals, which would be released, are known carcinogens, and cause various health problems. Provided sources of information on release of dioxins and furans from incinerators. Highlighted that children are more susceptible to the ill effects of pollutants.

• Following the selection of a preferred technology and site, a Human Health Risk Assessment, using established methodologies, will be undertaken.

• Pollutants emitted by incineration, as particulate matter, are persistent and implicated in effects on vegetation, ecosystem, humans, light, weather and climate.

• Following the selection of a preferred technology and site, a Human Health Risk Assessment, using established methodologies, will be undertaken.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• Incinerators act as a disincentive to maximize diversion. Priority should be on increasing recovery from the waste stream. Future advances will make 100% diversion/Zero waste more realistic. It is important not to be locked into a technology that precludes acting on these advances.



Susan Corcoran


…cont’d

• Consultants assume the incinerator will operate at maximum capacity. Peak performance is an unrealistic expectation as complex technologies rarely operate at maximum efficiency all of the time.

• Thermal facilities operate most viably at maximum capacity. They do not however have to operate at capacity. It is an economic decision on behalf of the owner of the facility as to how they will manage this.

• Mention of Europe as a ‘positive (?)’ example of the safe use of incineration ignores that Europe did not choose incineration because it was the best choice but because it was the only one available to them, along with exporting their trash and dumping abroad, due to an insufficient landbase. Second, in an effort to reduce risks, Europeans have incorporated several additional strategies to deal with waste. Incineration is just one component of the package (e.g. manufactures’ product ‘buy back’ schemes, reducing packaging requirements, etc.)


• Section 5.2.2 of the Addendum Report describes how as part of the sensitivity analysis the assumptions of overall at-source diversion over the 25 year planning period from 2013 onwards, have been adjusted to allow for a small incremental increase in at-source diversion over the 25-year period of time from 2013 to 2037 from 65% to 70% diversion.

• Both Niagara and Hamilton intend to continue to participate in initiatives to lobby provincial and federal levels of jurisdiction on initiatives such as industry stewardship.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Susan Corcoran


…cont’d

• The amount of energy that could be generated by an incinerator does not justify the huge capital outlay necessary for this project or the threat of harm to health and the environment.






-DRAFT-


Stakeholder/Agency

Comment Received

Response

Susan Corcoran


…cont’d

• We oppose incineration as the best option for management of Niagara’s waste. Instead we support System 1A, stabilized landfill located on industrially zoned property accompanied by continued exploration of ways to reduce the waste stream as the best available option.

• Comment noted.

Gord Perks

(Toronto Environmental Alliance)

• By treating all air emissions as one category, incineration’s impacts are understated. A better approach would have been to look at impacts, or pollutants rather than media. This is known as an ecosystem approach and acknowledges that pollutants move between media.

• Figure 7-1 of the Draft Report on the Evaluation of "Alternatives To" and Selection of a Preferred Disposal System shows the net lifecycle emissions to air which includes greenhouse gases, acid gases, smog precursors, heavy metals and organics emitted from all facilities and offsets (credits) achieved by generating energy and recycling of materials.

• Consultant’s report provides no consideration of the phenomenon of fallout of toxins to air and water. While the consultant claims this amount is negligible, the evidence suggests instead that potential problem is severe. (Sources and statistics are provided.)




-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks

(Toronto Environmental Alliance)…cont’d

• The consultants didn’t include a variety (they are listed in the comments) of known or suspected persistent bioaccumulative toxic organic chemical, toxic heavy metals, acid gas emissions, smog precursors, and greenhouse gases in their air emissions analysis. By missing so many substances and grouping all air emissions into a single comparative category the consultants have dramatically understated the environmental impacts of incinerators.

• Figure 7-1 of the Draft Report on the Evaluation of "Alternatives To" and Selection of a Preferred Disposal System shows the net lifecycle emissions to air which includes greenhouse gases, acid gases, smog precursors, heavy metals and organics emitted from all facilities and offsets (credits) achieved by generating energy and recycling of materials.

• The life cycle assessment tool is biased. The tool is developed by lobby groups representing industries that make products that wind up in our waste stream. They have a huge economic interest in how governments manage wastes. And they both have repeatedly advocated in favour of incineration of wastes (Sources are provided). Further the LCA tool is open to value judgments and importation of bias (a detailed explanation is given).

• The model used to estimate the life cycle implications, was the Integrated Waste Management (IWM) model, developed by the University of Waterloo and commissioned by Corporations Supporting Recycling (CSR) and the Environment and Plastics Industry Council (EPIC) and subsequently Environment Canada.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks


• WastePlan pamphlet on air emission from Thermal Waste Treatment Plants displayed a strong bias.

• The pamphlet attempts to downplay the emissions from incinerators.

• Interestingly, no similar pamphlet attempting to downplay the impacts of landfills was produced.

• None of the claims contained in the pamphlet are referenced.

• The subject pamphlet represents a summary of a broader emissions study which was commissioned by a number of Ontario municipalities including Niagara, Hamilton, Durham and York. That study provides the detail supporting the information presented in the pamphlet. The study was completed to balance the availability of current performance data for modern thermal facilities which was found to be more readily available for landfill – the primary method of disposal in Ontario since the inception of modern landfill technologies. Of more relevance though, is that the study was prepared separate from the EA and accordingly, was not included as part of the subject Draft EA documentation. That study continues to be updated based on the release of more current emissions data from operating facilities.

• Relevant to the EA study, the consultant team is confident that the potential impacts associated with both landfill and thermal treatment processes have been reasonably stated in the comparative process of alternative disposal systems.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks


• Many claims in the pamphlet are false or misleading. For example: the pamphlet claims that recent research has shown these compounds [dioxins]: i) may not be created in synthetic gas production process; ii) get destroyed in a well controlled high temperature process; and iii) are created in trace amounts through chemical reactions that occur in post-combustion exhaust gases following direct combustion of waste, waste-derived fuels, syngas produced from waste, or other hydrocarbons such as diesel fuel.

• In response to these claims: o There is no research that shows that a

gasification process (which includes the production of syngas) does not create dioxins.

o Dioxins are created in high temperature combustion processes.

o Some dioxins are destroyed (pamphlet uses ‘destroyed’ as an absolute statement)

o Use of the word trace to describe the amount of emissions suggests the emissions as trivial or insignificant. This is misleading because dioxins cause harm at small amounts of exposures.

• The subject pamphlet represents a summary of a broader emissions study which was commissioned by a number of Ontario municipalities including Niagara, Hamilton, Durham and York. That study provides the detail supporting the information presented in the pamphlet. The study was completed to balance the availability of current performance data for modern thermal facilities which was found to be more readily available for landfill – the primary method of disposal in Ontario since the inception of modern landfill technologies. Of more relevance though, is that the study was prepared separate from the EA and accordingly, was not included as part of the subject Draft EA documentation. That study continues to be updated based on the release of more current emissions data from operating facilities.

• Relevant to the EA study, the consultant team is confident that the potential impacts associated with both landfill and thermal treatment processes have been reasonably stated in the comparative process of alternative disposal systems.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• An undocumented comparison between truck emissions of dioxin and incinerator emission is made. Only recent comparison of Canadian emissions conducted in 1995 found that garbage incinerators were responsible for 1,110 grams of dioxin emissions annually while all diesel transport emitted 33.5 grams. (Source provided). Even if the comparison were accurate (which it is not) a more honest restating of the claim would be: a new incinerator would be like parking additional 1,700 tractor trailers in your neighborhood and running them every day.

• Comments will be considered over the course of the EA. Gord Perks


• Misleading statements are also found throughout the alternatives document as well. Ex: “hydrocarbons in the waste stream are converted [in incinerators] to thermal energy, carbon dioxide, and water” this is patently false. The hydrocarbons are released in many forms including smog precursors, and as constituents of toxic organic chemicals.

• The reference to this statement in the text is in the context of energy recovery. We understand that hydrocarbons are converted to other things besides thermal energy, carbon dioxide and water. Refer to the rest of the draft report on ‘Alternatives to’ for information on air emissions from thermal treatment facilities.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• Critical to review of the different alternatives is the assumed reduction in energy related emissions attributed to incineration. Here the consultants assume that province will replace existing coal plant 100% with natural gas. No proposal from the Ontario government has ever recommended 100% substitution. Proposals have included using nuclear, increased hydro, wind, other green power, conservation and efficiency to varying degrees. Every one of these has vastly lower air emissions than natural gas. As a result the study overstates the air quality benefits of energy production from incineration.

• It is understood that the selection of energy grid has significant impacts on the output of the life cycle analysis.

• Using the current Ontario grid would overstate the potential benefits of the systems that generate electricity and recover recyclable materials. Therefore, a custom grid was developed and used, reflecting the assumed eventual replacement of coal-fired power plants with natural gas-fired plants in Ontario.

• Section 5.2 of the Addendum Report describes how the original assumption was improved and applied for the sensitivity analysis. The revised assumption uses a 2015 projected Ontario grid (which assumes increased renewables and replacement of coal with natural gas).

• Also, worth noting, is the lack of specific operating data from incinerators to justify the amount of energy production assumed.

• Current experience with modern EFW facilities is reflected in the evaluation process. Referred facilities include those in Canada, the U.S.A. and Europe.

Gord Perks


• Study makes no reference to fallout of hazardous emissions from incinerators to the land. By treating the use of land for facility construction as the only significant impact on land the consultant deeply misrepresent the actual case. A better assessment would have recognized that incineration impacted a much larger land area than landfill. Because of this Option 2B should be listed as the worst of the principle alternatives in terms of land impact – not the best, as the consultants have done.




-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks


• Consultants overlook the impact of fallout on water. A better approach would have been to model fallout from incinerators, and compare it to landfill leachate impacts. This would best be done on a pollutant-by-pollutant basis.




-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks


• Given that the Niagara region is primarily agricultural there are huge potential economic risks associated with the fallout of toxic accumulative substances from incineration (Source and statistic provided). These are not taken into account anywhere in the study.






-DRAFT-


Stakeholder/Agency

Comment Received

Response

• There is no supporting information on the capital and operating costs of the incineration model. This is especially important as incineration construction costs have been soaring worldwide as attempts to reduce emissions become more and more expensive. Without that information the accuracy of the consultant’s costs for incineration cannot be used in decision-making.

• Annex E-4 provides detailed information on the financial analysis and costs of the ‘Alternatives to’.

Gord Perks


• The blithe and unsupported assertion that incineration is easier to site because it involves fewer land use conflicts ignores that it has been harder to site incinerators in Ontario than it has been to site landfills.

• Disagree with the statement that incinerators have been harder to site in Ontario than landfills. The lack of new incinerators in Ontario is more a function of the regulatory environment than as a result of difficulty with siting.

• Thermal facilities are industrial operations which are appropriately located on industrial lands. Siting a thermal facility on an existing, designated, industrial property will involve fewer land use conflicts than if it were located in an agricultural area.



-DRAFT-


Stakeholder/Agency

Comment Received

Response

• Reasoning about reduced land use conflicts given to support the argument that incinerators have lower social/cultural impacts, and would be easier to site, is used to support the claim that there would be fewer legal problems associated with an incinerator. There is not reason to accept this assertion.

• Disagree with the statement that incinerators have been harder to site in Ontario than landfills. The lack of new incinerators in Ontario is more a function of the regulatory environment than as a result of difficulty with siting.

• Thermal facilities are industrial operations which are appropriately located on industrial lands. Siting a thermal facility on an existing, designated, industrial property will involve fewer land use conflicts than if it were located in an agricultural area.


Gord Perks


• Concerned about economic impacts to the urban area surrounding the site of an incinerator.

• Following the approval of Thermal Treatment as the preferred “Alternative To” by Council, a comprehensive review of the potential economic impacts of Thermal Treatment, specific to the Hamilton/Niagara Study Area would be undertaken as part of the siting process. Input received from the analysis of the potential for economic impacts will represent an important component of the siting of a long-term waste processing facility.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

• Comparison of alternatives in report states incineration option is preferred because it may avoid the need to site additional landfill. First, approx. 20% of the material that enters an incinerator must later be landfilled. Second, incinerators are very inflexible in terms of capacity. Guess too low and landfill will be needed. Too high and the incinerator becomes uneconomic and must be closed and a landfill is needed. Alternately waste must be imported from other jurisdictions. This is not adequately explained in the document.

• The amount of material requiring to be landfilled is unlikely to require the establishment of additional landfill capacity. Niagara and Hamilton may have enough capacity to manage the bottom ash within their municipal boundaries.

• The flexibility of the systems was considered in the evaluation of “Alternatives to” including their ability to manage variable waste streams, seasonal variations in waste, and incorporation of new technologies that become available.


• Over the course of the study, it may be apparent that opportunities exist to provide excess capacity in the early stages of the planning period to neighbouring municipalities provided it would benefit the proponents and the broader environment. Municipal solid waste originating from outside the study area, particularly from smaller neighbouring communities, would offer a potential waste stream that could be managed by surplus capacity incorporated into the undertaking, should this be determined to be beneficial.

Gord Perks


• Believe criterion for “need to site additional approved landfill capacity” should not have been included. It is nothing more than an inbuilt bias in favour of incineration.

• The amount of material requiring to be landfilled is unlikely to require the establishment of additional landfill capacity. Niagara and Hamilton may have enough capacity to manage the bottom ash within their municipal boundaries.


-DRAFT-


Stakeholder/Agency

Comment Received

Response

Gord Perks


• In their mass balance calculations the consultants insert a line between quantity of residual and quantity landfilled called moisture and mass loss. The first law of thermodynamics states that matter is neither created nor destroyed. It isn’t lost either. In the case of incineration it is disposed of into the air. Dilution is not the solution to pollution. By claiming that the mass of materials emitted by an incinerator and dispersed into the air, the consultants violate this tenant.




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