Application Assessment…

Application Assessment Officer MECP , Dear Sir/Madam: RE: Application for Site Plan Approval (D07-12-18-0141) and Zoning By-law Amendment (D02-02-18-0088) 2596 Carp Road, City of Ottawa Ministry Reference Number: 8439-B4WKG4 I live in this area and it will directly impact my and my family's quality of life. I invite you out to the proposed site to see if you think you want to live beside where the concrete batch plant could be built. The Ministry of the Environment, Conservation and Parks (MECP) is currently reviewing the environmental impact of Cavanagh Development’s Application to build a heavy industrial concrete batching plant at 2596 Carp Road. The city of Ottawa has recently approved the re-zoning of this site, contingent upon MECP review. There are many reasons why we, the residents of Carp, are concerned with the environmental impact of this decision. According to the Carp Road Corridor Community Design Plan, which is referenced by the Ottawa Official Plan as providing “direction to the Zoning By-law for future land uses,” this site is intended to be for light industrial use. It was never intended for heavy industry. That is why a residential neighborhood was placed immediately adjacent to this parcel of land. The applicant has maintained that this facility qualifies as a Class II facility according to Ministry guidelines. This essentially equates to a medium industrial category, even though the applicant is proposing to produce 2000 cubic meters of concrete daily! It is clear that the applicant’s intention is to operate a heavy industrial facility. We estimate that this amount of concrete production will necessitate roughly 900 trucks daily in and out of the site. We maintain that it is in fact a class III (heavy) facility, and as such the site plan submitted fails to meet the Ministry of Environment, Conservation and Parks standards outlining setback requirements from existing sensitive land uses such as residences and workplaces. Residents are particularly concerned with water contamination and air quality issues. Concrete production involves significant amounts of Portland Cement, limestone gravel and sand. Emissions from concrete plants, such as heavy metals and crystalline silica, are known to be toxic. This plant will be no different. On a cumulative basis, the inevitable contamination of our air and water from this concrete facility will cause significant health issues. Children, the elderly and those with preexisting respiratory, liver or autoimmune conditions will be the most vulnerable. Because residential properties are immediately adjacent to the location, we believe that the health risks to the community pose a dangerous threat. All of the homes in the Carp area rely on well water. Our water is replenished by rain and snowfall from this area. It is noteworthy that this site is designated as a “high recharge” area for groundwater. Moreover, the site of the proposed plant has Huntley Creek running through it. In addition to being a pristine natural environment in its own right, it is the Carp River’s largest tributary which is in turn a tributary to the Ottawa River. As concrete plants generate copious amounts of toxic dust, it will not be possible to contain all of it from seeping into the creek. Runoff from the plant will also most certainly make its way into the groundwater. It seems unduly hazardous to place a large concrete batching plant this close to a sensitive creek and a “high recharge” area. Furthermore, you should be aware that this area has a very high water table and as a result flooding occurs frequently. Adequate stormwater management is therefore a much greater challenge, particularly since the stormwater on this site will include washout water from the fleet of aggregate, sand, cement and concrete trucks that will continuously roll in and out of the site. Resulting water contamination, both into the aquifer and into the creek, is a very real concern. In our view, it is quite simply irresponsible to place a heavy polluting concrete plant in this location. It is imperative for the health of this community’s well water, that any development of this site recognize the sensitive nature of this area. With respect to the noise from the facility, the applicant seems to have under-represented the number of trucks needed to move the required materials to produce 2000 cubic meters daily. Additionally, the applicant failed to include estimates on noise generated by some of the equipment to be employed at this facility. Submitted noise estimates should therefore be viewed with some skepticism. Beyond the impact that this plant will have to residents of the surrounding area, all other living creatures will also be negatively affected. Fish, frogs, salamanders, birds, mammals and insects such as pollinators will all experience life-threatening consequences. We have identified the following At Risk Species that have been observed at this site: Least bittern (threatened); Barn swallow (threatened); Bobolink (threatened); Barn owl (endangered); Blanding’s turtle (threatened); Snapping Turtle (Special concern and worth noting that Huntley Creek is their local nesting ground); West Virginia White (special concern); River Redhorse (special concern and Huntley Creek is the spawning site for the Ottawa River population); and Monarch Butterfly (special concern). We also know that naturally occurring Butternut trees (endangered) and American Ginseng (endangered) are found on adjacent properties but we have not been able to search this site specifically for their presence. Furthermore, we have a large population of salamanders in this area, but we have not had the opportunity to study them to determine if the Jefferson (endangered) lives among them. And finally, we would also ask that you carefully review the prosecution record of the Applicant and related companies. Multiple convictions of an environmental nature indicate a lax approach to environmental stewardship. Coupled with the sensitivity of the proposed site, this less-than-stellar record should be grounds for any impartial review to conclude that the application should be rejected. Sincerely, Concerned Resident of Carp