August 18, 2022 Email to:…

August 18, 2022
Email to: enviropermissions@ontario.ca
Client Services and Permissions Branch
Ministry of the Environment, Conservation and Parks
135 St Clair Ave West, 1st Floor Toronto, ON M4V 1P5
Dear Sir/Madam:
RE: ECA Application – Tomlinson’s Proposed Asphalt Plant (Napanee Quarry)
ERO No. 019-5565

I am writing to express my strong opposition to the hot mix asphalt plant that R.W. Tomlinson Ltd. proposes to build and operate at 8205 County Road 2 in the Town of Greater Napanee. I am concerned about the toxic chemicals that will be emitted during production and transportation of hot asphalt being produced at this location. My husband and I purchased a condominium unit in Napanee under construction within the area of influence approximately 2 km. from the quarry site. I suffer from asthma, heart disease and limited lung function. We chose to relocate to Napanee because of its healthy, safe environment. A hot mix asphalt plant in close proximity will certainly change that. The proposed asphalt plant is located too close to residential houses, rural farms, downtown Napanee and my future condominium. I am worried about the effect, that the proposed discharge of potentially harmful chemicals listed in the instrument, will have on human health and the fragile ecosystem that exists along the Napanee River.
I am especially concerned that:
· The existing aggregate-related activities at the Napanee Quarry already discharge dust, noise, and other substances into the local air, and it is unacceptable to compound or aggravate these problems by approving a new permanent asphalt plant that will discharge even more contaminants into the air.
· Tomlinson does not currently have rezoning approval for the proposed asphalt plant, which was unanimously rejected by the Napanee council for sound environmental reasons under the Planning Act.
· If approved, the proposed asphalt plant will discharge a number of different noxious chemicals into the air that may cause serious odour and air quality impacts if not fully abated or mitigated.
· Tomlinson’s own reports confirm that air pollutants, such as volatile organic compounds, metals, hydrocarbons, particulate matter, products of combustion, and other substances, will be emitted into the air from the asphalt plant.
· There is considerable uncertainty arising from Tomlinson’s air studies (i.e., use of non-local meteorological data in the computer modelling), which I believe raises serious doubt about the accuracy of the predicted air quality and odour impacts and undermines the credibility of Tomlinson’s claim that there will be compliance with applicable air pollution standards.
· The proposed asphalt plant is inappropriately located just east of downtown Napanee and in relatively close proximity to environmentally sensitive natural features, agricultural operations, and numerous people who live, work or travel through the area.
· While Tomlinson’s air studies focus on the asphalt plant and its emissions, these studies have not fully identified, modelled, or assessed the emissions from the concrete batching plant that Tomlinson also wants to construct at the site.
In light of these and other unresolved concerns, I therefore request that the Ministry refuse to grant an air and noise Environmental Compliance Approval (ECA) to Tomlinson under the Environmental Protection Act in relation to the asphalt plant, the concrete batching plant, and any other new or historically unapproved emissions from the site. In my view, issuing an ECA for these proposed sources of air contaminants is unreasonable and could potentially result in significant environmental harm.