I have reviewed the…

I have reviewed the engineering report from Josselyn Engineering that makes up the bulk of this ECA application and I respectfully recommend that the ECA be denied for the following reasons: 1) Picton Terminals is of the opinion they can operate the port as « legal, non-conforming » and this zoning designation is being challenged in court in early 2018. No decision should be rendered by MOECC with regard to an ECA until such time as Ontario Supreme Court has ruled that the port is operation within the legal zoning bylaws of the county. 2) The ECA as presented fails to address the critical requirement of « quality «  of the effluent that will eventually be allowed to discharge into Lake Ontario. In particular, the engineering report specifies that the report does not address the quality issue of « chlorine and other hazardous materials «  in the effluent but rather addresses the suspended solids in the effluent (see page 5 of the report). While the report refers to a « technical memo » by XG consulting as having dealt with quality elements of the effluent, the aforementioned technical memo provides no technical information whatsoever that could be used to determine what would be monitored, when sampling would take place, what analytical equipment and standards would be used etc etc. In fact the technical memo is nothing more that a solicitation for funding (monthly fees) by a consulting company. Even if one were to accept this memo as a demonstration the the chlorine and other hazardous materials would be assessed, to suggest that this could all be done through one or two visits a mont at a cost of only$750 borders on the rediculous. 3) The ECA is totally built upon and depends upon the future construction of structures that would hold and cover the salt. It is assumed that there would be no objections, concerns or legalities involved to literally blast out an area the size of 2 football fields (>3 ha) immediately adjacent and bordering on the shores of Lake Ontario. Such a project alone will and should require a full environmental assessment before any work can proceed. One can not fathom the likes of blasting out a limestone cliff escarpment to create a storage area for holding thousands of tons of road salt within feet of the lake shore of Lake Ontario. Picton Terminals is wanting only to reduce their costs of loading and unloading the salt by moving the storage to an elevation (lowering the storage area to lake level)...this proposed project has nothing to do with storm water management interests. 4) Picton Terminals has clearly demonstrated that it is unable to manage the receipt, storage and maintenance of road salt. This has been documented through MOECC Provincial Officer’s Reports (see latest report of November 21, 2017). Picton Terminals has been referred to the MOECC compliance and enforcement dept due to lack of compliance in previous provincial orders (order issued in Nov 2016). There is documented evidence of salt and salt contaminants (cyanide) polluting neighbouring land, groundwater and flowing into Lake Ontario as a result of Picton Terminal’s activities. 5) Picton Terminals has recently (Nov. 16th) informed the public through press releases (the Wellington Times newspaper) that it is now operating as a quarry and not a port, despite that fact that they have no provincial permits to operate as a quarry and in fact are operating a quarry on land that is zoned agricultural (again, no proper zoning permit). Any one of these significant points should be cause for alarm and reason to deny the ECA as presented. Taken together they should be overwhelmingly sufficient to reflect this application. Thank you Gary Whitfield Ph.D (Retired...former Federal lead on the Great Lakes Action Plan and COA 1994-2000)