Highland Creek Biosolids Environmental Assessment
Comments and City Responses from PIC #1
Posted Dec 2014
The first Public Information Centre was held on June 16th at the Legion Hall on Lawson Road. Those in attendance were invited to submit written questions and comments to the City. The City has recently tabled two documents outlining its responses (shown below in italics). The first document, issued by the Project Consultant CIMA, deals with the questions raised by the community attendees (16 pages), and the second, from the City Project Manager, deals specifically with the comments submitted by The Toronto Environmental Alliance (11 pages).
A summary of these documents is presented below.
Community Comments and Questions
Seventy attendees signed in, and thirty written comment sheets were submitted. The responses were prepared by the Project Team, and were grouped into ten topic headings:
1. PIC format and Contents
· There was some support for a town hall type meeting rather than the poster session used for PIC #1 – City will consider alternate formats for PIC #2 and PIC #3 to optimize the opportunities for group discussion.
· Most attendees felt the information was well presented, and there was support for the inclusion of health aspects in the new EA.
2. Rationale for Class EA Study
· Many attendees were upset that the recommendation of the original EA was not implemented by City Council, and were concerned about the extra cost of the new study – staff indicated that, because of City Council’s rejection of the Highland Creek recommendation, a new EA for Highland Creek was required, so that the remaining parts of the Biosolids Master Plan for the other City sewage plants could be implemented.
3. Study Approach
· Concerns were expressed that the City would choose a lower upfront-cost solution that may not be the best in the long term; a few attendees were concerned that Social impacts were being given priority over Health impacts – all feasible options will be considered based on a combination of health, environmental, social (community) and economic evaluation criteria; the Class EA will consider Cumulative Air Emissions, Human Health Risks and Health Impacts in the evaluation process.
· Will the City use the latest models to evaluate pollution emissions – the City will use the Biosolids Evaluation Assessment Model (BEAM) for calculating greenhouse gas emissions, and the CALPUFF model for cumulative air emissions assessment.
4. Public Consultation
· Concerns were expressed the process will be hijacked by special interest groups from outside the study area, and by politicians driven solely by ideology and political opportunity
- the City indicated that the consultation process is transparent and all comments received, and the responses, will be made public.
5. Health Impact Assessment (HIA) Stakeholders Group
· Who will be members of the HIA Stakeholder’s group and when will they meet – the first HIA Stakeholder’s meeting was held on November 12th and was attended by representatives from the NLC, the Centennial CRA, the Coronation CA, the Highland Creek CA, the West Rouge CA, Toronto Public Health, TDSB, TCDSB, the East Scarborough Boys and Girls Club, Local Immigration Partnership, Toronto Region Conservation Authority, TEA, and Open Policy Ontario and Metcalf Fellowship.
6. Timing for Implementation of Selected Biosolids Management Solution
· Concerns were expressed that the proposed new facilities would be delayed by modifications currently being made at the plant, and that the solution would be dated before it is built – the timing of the implementation of the recommended solution will be determined as part of the Class EA, and the recommended replacement of the existing incineration equipment will be undertaken in a timely manner, once the EA is completed; the existing incinerators are tested and monitored regularly, and meet all regulatory requirements.
7. Biosolids Generation and Management Alternatives
· There was strong support for the thermal destruction option with best available technology and resource recovery, as it appears to have the best health, environmental and financial outcomes – City will evaluate fluid bed incineration, pyrolysis, gasification and other emerging thermal destruction technologies;
· Concerns were expressed about the long term sustainability of the demand for processed biosolids as fertilizer, which could then result in the biosolids ending up in landfills – City acknowledges that there are a number of factors affecting long–term reliability; a contingency plan will be developed for all the alternatives.
· There were some questions about the reduction in the frequency of off-site trucking, if an on-site biosolids processing plant is recommended – City will consider the following on-site processes; drying (pelletizer), alkaline stabilization, thermal hydrolysis, Lystek process, and composting, and the related trucking requirements.
· The City needs to consider energy recovery options, such as co-generation – any processes that have potential for energy recovery, through biogas or heat generation, will be considered, along with ash recycling.
· City should partner with private industry to increase efficiencies – the City indicated a willingness to partner with private industries for the off-site hauling and processing of biosolids; in this case the ultimate end destination would not be selected by the City.
8. Biosolids Transport Off-Site
· There was much opposition to trucking biosolids through the local communities, for safety, as well as health and property value considerations, and airborne contaminants from the trucks – if truck haulage is selected, the City will specify measures to minimize noise, odours, traffic, and safety related impacts; the operation of vehicles transporting biosolids is regulated by Federal and Provincial legislation and City bylaws.
· There were requests to investigate other off-site transportation methods such as rail cars, lake barges or pipelines – the EA will evaluate all modes of transportation, and results will be presented in PIC #2
9. Land Application of Biosolids or Processed Biosolids Products
· Many concerns were expressed about the Health Impacts due to the contamination of food, soil and groundwater by spreading biosolids on farmland – City indicated that the assessment of health risks would be limited to residents of Wards 43 and 44 only.
· Many were concerned about the long term impacts on human health by the spreading of biosolids that contain complex chemicals that are not regulated in sludge, and heavy metals on farm lands; biosolids should not be used as fertilizer on Ontario croplands and beyond – the Province regulates the use of biosolids as a fertilizer on land, through the Ministry of Environment and Climate Change (MOECC) and the Ontario Ministry of Food and Rural Affairs (OMAFRA); these agencies, along with other Canadian and US government and academic institutions, have concluded that when practiced reasonably, and in accordance with guidelines and regulations, agricultural land application is beneficial, and poses minimal health or environmental risk; evaluating the regulations governing the application of biosolids to agricultural land is beyond the scope of the EA process.
10. Air Emission Impacts
· The City needs to consider the greenhouse gas emissions for the complete trucking operations, not just to the 401, but to the final disposal destination – the truck haulage greenhouse gas emissions will consider both the minimum and maximum haul distances, but the health impacts outside the community will not be considered.
· Many were concerned about the emissions from the existing incinerators – the emissions from the existing incinerator will be modeled, along with the emissions from all the feasible biosolids management options.
Toronto Environmental Alliance Comments and Questions
The TEA comments were predominantly focused on demonstrating that the PC #1 Poster Board presentation was biased in favour of the incinerator upgrade that was selected as the preferred option in the previous Biosolids Master Plan. The City did not accept this position.
1. Meeting Notice for PIC #1 and Technical Memoranda.
· Inadequate notice of PIC #1 was provided – City said that Notice of the Meeting was issued on June 5, 2014 and was publicized in two editions of the Scarborough Mirror; notices were also published on the Project website.
· Requested that the Technical Memoranda be posted on the website – City indicated that Technical Memoranda will not be published on the website, however some Technical Updates will be published on the website.
2. Format of Meeting
· Requested that the ‘read and roam’ poster board format be changed for PIC #2 and PIC #3 to include ‘question and answer’ sessions; this would allow more community dialogue, and would ensure accountability and lack of bias from the consultants – PIC #1 was only to provide information on the purpose of the Class EA, and the approach and schedule; other formats will be considered for PIC #2 and PIC #3, to ensure unbiased presentation of information and receipt of feedback.
3./10./11. Poster Boards were Biased
· Information on some of the Poster Boards was confusing and biased – the information in PIC #1 was intended as background for those less familiar with the wastewater treatment process; technical information will be provided at later stages in the process, as the options are developed
4. The EA Study Process
· When will the City Councillors and the Mayor vote on the final decision; does the current Public Consultation process eliminate the need for a 30-day Review; questioned the role of the Ministry of the Environment – once the Class EA Study is completed, it will be presented for approval to the Public Works and Infrastructure Committee, and then to City Council; the construction of any recommendations resulting from the study will require a modification to the MOE Environmental Compliance Approval (ECA); the ECA also covers monitoring and compliance requirements; the Public Consultation Process does not reduce or eliminate the 30-day mandatory review period, or the submission of the final report for review by the Minister of the Environment.
5. Long List of Options
· It is indicated that TM-2 will indicate the long list of options; how will the options be selected and will the public have a chance to comment on the list – information on the long list will be included in Newsletter #2, which is scheduled for release in November; the short list will be presented in one of the first Technical Updates.
6. Bias against Trucking
· It was suggested that some of the descriptions such as ‘risk of spills’ was biased against trucking – the intent of the posters was to provide general information on the project; a full list of impacts will be evaluated as part of the Class EA process, and will be presented at future PICs.
7./8./9./15. Development of Short List
· How will the four decision-making categories (health, social (community), environment and economic) be assessed in developing the short list; will both positive and negative impacts be assessed; how will the scoring system work – the short list of management options will be those determined to be feasible for the Highland Creek Treatment Plant; the screening process will be presented in a Technical Memorandum and at PIC #2; the evaluation criteria are currently being developed.
12. Approach 1 (On-site Thermal Treatment of Biosolids)
· The thermal treatment title is misleading, as the poster does not include all types of thermal processes; no mention of ash disposal – the Approach 1 category will cover all potential thermal destruction processes; ash disposal, which in 2013 involved 64 truck loads, will be considered in the evaluation.
13./19. Approach 3 (On-site Processing and Off-site Transporting of Biosolids)
· The on-site processing poster does not cover some of the advantages of this option, including the reduced number of trucks – note that some on-site processing options would increase the number of trucks compared to Approach 2 (Off-site Transportation of Biosolids), because of the need to import materials that could increase the volume of biosolids; other options, such as on-site pelletization, could reduce the number of trucks.
· A number of questions were asked about the transportation study – the evaluation of preferred routes and modes will become part of all options that involve the off-site transport of biosolids.
16. Health Impact Assessment
· Who will be included in the HIA Stakeholders group – a broad range of organizations will be asked to participate; one member from TEA will be invited.
17. Cumulative Air Impact Assessment
· Questions about the methodology for the CAIA – a range of scenarios, considering wind patterns, will be modeled to evaluate impacts.
18. Human Health Risk Assessment
· Questions about the HHIA, and who can attend the PICs – the HHRA is a quantitative assessment of health impacts in the study area, and will feed into the HIA; the PICs are open to anyone who would like to attend.
20. Further Opportunities
· A number of opportunities offered by the Approach 2 (Off-site Transportation of Biosolids) option were mentioned – the City appreciated the identification of these issues, and indicated that by utilizing the broad expertise of the project team, and through public and stakeholder consultation, all opportunities related to all the biosolids management options will be evaluated.
The above summary is not intended to cover the questions, comments and responses in complete detail. Interested readers should apply by email to Josie Franch, the Project Public Consultation Coordinator, for the compete reports (email@example.com).
The next PIC #2 meeting is scheduled for March 2015. It is critical that we get a strong attendance by local residents, including the submission of written comments, to ensure that the Community’s views are made known to the Project Team.
Notes prepared by Frank Moir,
Co-Chair Highland Creek Treatment Plant Neighbourhood Liaison Committee.