Submit Comments to the Ministry of the Environment by Friday April 2, 2010

Friday April 2, 2010 is the deadline for the public to comment on the Environmental Assessment for the Durham Region incinerator proposal - officially called the "Durham-York Residual Waste Study".

The Ontario Ministry of the Environment has reviewed the reports that were submitted by the project team (staff and consultants) in July, the amendments submitted in November, and the additional sections and memos submitted in December and issued their "Ministry Review", an interim ministry staff opinion.

The five-week public comment period that ends Friday April 2, 2010 is the final opportunity for the public to provide comments on the entire environmental assessment study before the Ontario Minister of the Environment makes his decision to approve the EA (with or without extra conditions), reject it, refer all or part of it to the Environmental Review Tribunal.

The letter below is based on the pre-formatted letters available on the Don't Get Burned site. Those letters are provided as links that automatically open your mail program and pre-fill the email with the text. We invite you to add your own comments, your name and full return address, then send. One thing every Durham Region resident of can do is comment on the consultation done throughout the environmental assessment study.

We would like to hear more about your experience with the consultation around the incinerator project. Please complete this short anonymous online survey (SurveyMonkey is a site that provides free or low-cost support for surveys and polls). The survey may also jog your memory about the consultation process: public meetings, surveys, ads, displays, correspondence or literature.

To: Agatha Garcia-Wright
Director, Environmental Assessment Approvals Branch
Ontario Ministry of the Environment
c/o Gavin Battarino, Project Officer <>

Copy to:
Hon. John Gerretsen, Minister of the Environment <>
Hon. Dalton McGuinty, Premier of Ontario <>
All members of Regional Council (via Clerks) <>
John O'Toole, MPP Durham <>
Toby Barrett, PC environment critic <>
Peter Tabuns, NDP environment critic <>
Mike Schreiner, Leader, Green Party of Ontario <>

(Please forward a copy of what you send to <>)

Subject: Durham-York Residual Waste (Incinerator) Study

Dear Ms. Garcia-Wright,

I am a resident of Durham Region and I urge the minister to reject the EA on the proposed incinerator in Clarington.

In the absence of outright rejection, I support citizen requests for a referral to an Environmental Review Tribunal because of the following issues and concerns that were not appropriately addressed.

Inadequate consultation

A properly conducted EA is supposed to inform the community the community about the potential impacts of the project. However, many Durham residents appear to not fully understand what the Region is considering, i.e. burning garbage, nor what the range of impacts around burning garbage entails.

The so-called consultation conducted by the project team was about appearances rather than engaging in meaningful dialogue. True consultation is about informing, listening and addressing concerns.

Air quality and its impact on human health

The EA study data shows that the Courtice airshed is already overburdened. Air quality issues and their impact on human health have not been adequately addressed in this EA.

* Nitrogen dioxide (NO2) levels measured at the site are the highest of southern Ontario urban centres;

* Fine particulate matter (PM2.5) levels are very close to exceeding the Canada Wide Standard;

* Ozone (O3) is already in excedance of air quality criteria.

These pollutants are associated with serious health effects and the incinerator would add to the airshed significant quantities of these, other respiratory irritants, and other toxic and/or carcinogenic emissions.

Risk was assessed and characterized in the EA for these key pollutants by comparing estimated exposures against less stringent air standards instead of up-to-date Toxicity Reference Values (TRVs). It is documented in the EA that, had more stringent TRVs been used, potential risk to human health would have been identified.

Risk assessment is not sufficient to study risks and concerns

The EA relies on the inexact process of risk assessment which cannot adequately assess, or assess at all, some of the major concerns and risks of incineration.

Risk assessment does not:

1. adequately or accurately determine the risk associated with toxic ultrafine particulates (nanoparticles). Studies show links between particulate exposure and adverse health outcomes. Ultrafine particulates, however, are not regulated and risk assessment cannot accurately evaluate their risk. Furthermore, incinerators emit significant quantities of heavy metals and other toxins which can adsorb onto (cling to the surface of) particulates, further increasing toxicity.

2. adequately assess for chemical mixtures such as the additive effects of all the respiratory irritants emitted together by incinerators. The EA study itself states that "This is a considerable source of uncertainty in any risk assessment in Ontario".

3. assess many of the hundreds of pollutants emitted by incinerators which, due to their unknown emission factors and toxicity, cannot be assessed.

4. adequately assess for synergistic effects - i.e. how the many pollutants emitted could react with each other and how those reactions could create other chemicals with potentially more toxic effects.

Inadequate monitoring

The facility will be subject to inadequate monitoring:

* only a handful of the hundreds of pollutants emitted will be monitored continuously even though the technology to monitor many more exists;

* many of the most toxic known pollutants will only be monitored one day a year through a pre-arranged stack test (Table 4-1, HHERA, Dec. 10, 2009);

* no pre-sorting of waste is planned - emissions can vary as the waste composition changes;

* the Host Community Agreement (HCA) proposes only ambient air monitoring and for only 3 years of the facility's 30 year life. Further, there is no commitment as to what specific pollutants would be monitored;

* the HCA states that the operator (Covanta) would do the monitoring, which is inappropriate and a clear conflict of interest;

* the HCA appears to be inconsistent with the EA commitments. (Section 3.3, Host Community Agreement).

Effects on Lake Ontario

The effects of building an incinerator on the shores of Lake Ontario were not fully considered in the EA. This affects not only our local region, but over million on either side of the Canada-US border who rely on Lake Ontario for their drinking water and recreational uses.

To protect the lake and its users, a Federal EA should be triggered.

Monitoring is necessary to protect the quality of Lake Ontario for current and future generations.

Impact on Tourism

The incinerator stack will be visible from 5 kilometres away. For visitors to Darlington Provincial Park, the view of an 86.7 meter incinerator stack as they come off the 401 will be truly uninviting.

Agriculture is the single largest industry in Clarington. Our community relies heavily on agri-tourism and the sale of locally grown products. The stack will serve as a reminder of the pollution that will be spread to ai, land and water across the municipality, and beyond.

Furthermore, visual and health concerns would increase with a possible future 400,000 metric tonne per year incinerator that would require 'approximately 14 new structures plus 1 more stack' (pg. 11-104, EA Study, November 27, 2009).

There is no mitigation possible for lost tourism and potential loss of business to our farming community.


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