The Honourable Glen R. Murray
Minister of the Environment and Climate Change
11th Floor, Ferguson Block
77 Wellesley Street West
Toronto, Ontario M7A 2T5
May 31, 2016
Dear Honourable Minister Murray:
I’m deeply concerned about the risks associated with the proposed Taggart-Miller dump in east Ottawa.
After meeting with members of the Capital Region Citizens Coalition for the Protection of the Environment and reading their public comment submission on the Ministry Review of EA File 10261, I believe there are too many unanswered questions and conflicting expert reports to let the dump proceed at this time.
I strongly encourage you to reject the Taggart-Miller landfill project or to send it in its entirety to the Environmental Review Tribunal.
There are a number of compelling reasons to reject the proposed Taggart-Miller dump. I would like to highlight four of them.
1. Surface and Groundwater Contamination: Most residents and farms in the area rely on their surface wells for clean water. Hydrogeologist, Dr. Ken Howard, concludes that the level of geological investigation is still insufficient for the size of the site and the potential environmental damage that may be caused during operation of the facility. He has little confidence that the site can be operated in the safe manner predicted.
2. Leachate Management Plan: The leachate management raises serious questions and concerns. Taggart-Miller’s only approach is on-site pre-treatment coupled with trucking of the treated leachate to the City of Ottawa ROPEC wastewater treatment facility. The proponent is aware that ROPEC will not be able to handle the volume of leachate trucks expected and that an alternate disposal method will be required within 6-7 years of commencing operations. Since the leachate management plan is not adequate, alternative leachate management plans must be identified and the impacts thoroughly described and modelled before the dump proceeds.
3. Leda Clay: The Leda clay at the site is a weak, 100 ft deep, unstable clay. It is not suitable as a pollution-proof liner. This is especially disturbing since the proponent is not planning to line the bottom of the landfill. The clay is prone to liquefaction if placed under load (during construction, or during the phased loading of the landfill), and especially vulnerable to seismic shaking. Dr. Ken Torrance has raised concerns that the Environmental Assessment minimizes the major constraints posed by the soil conditions and supports experimental design concepts as workarounds for significant geotechnical issues.
4. Air Quality and Human Health Impact Assessment: The air quality assessment does not include all potential sources of pollutants and is inadequate for an EA level assessment according to Arcadis/Senes. The proponent’s assertion, without further studies, that air quality beyond the site perimeter will not be compromised is not a reasonable response to the concerns raised. They also note that the proponent should undertake a Human Health Risk Assessment particularly considering the massive scale, longevity, and concentrated contaminants associated with this project. By not undertaking a human health risk assessment, the proponent has not shown that their EA assessment is protective of human health.
As you can see, Minister Murray, there are serious unanswered questions about the proposed Taggart-Miller dump.
One of government’s primary responsibilities is to protect citizens from health, safety and environmental risks. There are clearly too many unanswered questions for the Taggart-Miller dump to proceed at this time.
I am calling on you to reject the Taggart-Miller landfill project. Or, at the very least, send it in its entirety to the Environmental Review Tribunal.
Leader, Green Party of Ontario