The following comments were…

The following comments were originally written by another Napanee resident who has given permission fir them to be shared. I have added further comments . As a resident of the Town of Greater Napanee, I have opposed the original amendment application by seeking rezoning approval to permit a permanent asphalt plant on the proposed property. My opposition is based upon the lack of consideration for the wishes of the clear majority of the residents of this and the unanimous decision of the Council to deny the application and to go further indicating by unanimous council motion stating that the Town of Greater Napanee is an "unwilling host" for this asphalt plant in the specific location applied for.

Since this represents the wishes and best interests of the population by a majority (99%), this needs to be respected by the R.W. Tomlinson Company, the Ontario Land Tribunal and by the Ministry of Environment. The wishes of the population override the wishes of any company, and include the regulating government bodies. Just because it is legal, doesn't make it right.

We are exposed to many odours, noxious, smelly, even unnoticeable - so very many of these chemicals, dust and particles are dangerous to health, breathing and are known to cause serious illnesses including cancer among others.

1. It is very important to note and remember, the objection is to the location and not the company or the actual plant itself - It is the location that is completely inappropriate and unacceptable.

2. Inadequate assessment and study has been devoted to identifying the impact on the residences located immediately below the subject property, Inadequate consideration has been given to the surface water flows that can occur with rain storms that will wash any surface dust and air borne materials downhill from the higher elevation property. This dust and air borne material will filter through the fractured limestone potentially contaminating the ground water. Simply viewing the slope of the hillside will evidence that runoff will flow through the residential properties.

3. The ground water that will result from such storms will flow downhill through the yards of the residences, part the Napanee River Watershed, and ultimately arrive in the Napanee River, a protected drinking water source for the Town of Greater Napanee. Inadequate assessment has been presented for this very serious concern.

4. Inadequate assurance can be made or implied by implementing emission controls mechanisms, even very strict methods will fail when operated by human beings. Once dust, particles, chemicals are released into the air, there is NO control of where they go, what impact will be realized and long term outcomes are impossible to assess.

Here I include an extract from the proposal:

{{This proposal is for an Environmental Compliance Approval with Limited Operational Flexibility (air & noise), which replaces all the current Environmental Compliance Approvals for air at this facility, and includes the addition of new, or historically unapproved, sources for all emissions from R. W. Tomlinson Limited, a hot mix asphalt plant, located in the Town of Greater Napanee, Ontario.

The proposal includes all sources at the facility that exhaust to the atmosphere, including:

a dust silo
hot oil heater
baghouse
crushing plant generator
fugitive emissions from the storage and transfer of materials associated with hot mix asphalt operations

Emissions to the air from this facility include:

benzene
benzo(a)pyrene
carbon monoxide
crystalline silica
naphthalene
nickel
sulphur dioxide
suspended particulate matter
products of combustion such as nitrogen oxides

The Environmental Compliance Approval with Limited Operational Flexibility (air), when issued, permits modifications to the facility subject to limits on operational flexibility that include a production limit for the facility to be specified on the Environmental Compliance Approval with Limited Operational Flexibility (air).

The limited operational flexibility conditions have an expiry date. The company will be required to make an application for amendment at that time to renew these conditions.}}

I ask these questions:

1. Would you want to live near to these kinds of emissions into the air around where you live, where your children play, walk to friends or wait for a school bus, suit out and enjoy a backyard BBQ?

2. Would you choose to live near such a facility recognizing the potential for significant exposure to odours, dust and air-borne chemicals from such an asphalt plant?

It is unthinkable to overrule the unified and unanimous choice of the Council representing the community of the Town of Greater Napanee in favour of the corporate wishes of R.W. Tomlinson who base their operations in Ottawa.

It bears repeating - just because it is legal, doesn't mean it is right or good or should be approved.
In closiing, I request that this proposal for this Environmental Compliance Approval be clearly denied! Added to Public Comments against Tomlinson Asphalt Plant at

One further note I add:
From the public virtual meeting last October 14, 2021, the numbers from a traffic study of the area stated there would be on a "typical average day" approximately 25 tri-axle trucks of asphalt, and approximately 25-60 triaxle trucks of import materials for the plant. This is in no way "insignificant", especially to those who live on Hwy 2 or Palace Road.
The emissions from all these trucks add to those enumerated above.

I respectfully request the proposal be rejected by our Environment Ministry.