1) The proposed facility is…

1) The proposed facility is an open building that will not contain any odours from neither unloading (feeding) of the biosolids nor the processing of the biosolids in the reactor. This will lead to frequent ammonia releases (as the proponent describes in ECA 6303-4Q9J8G Amendment Requests, page 10) that are more than a nuisance for the immediate neighbourhood. The closes residence is just 20m away from the facility. I propose that the building has to be of a closed nature with negative pressure to prevent any odours from escaping. Filtering equipment will have to be installed that filters the air leaving the building ensuring it is odour free. 2) Page 10 of "ECA 6303-4Q9J8G Amendment Requests" talks about a 100m distance from a residence. But the closest residence to Brant St. is only 20m! This overlooked fact poses a potential noise emission risk for the residences nearest the operation. 3) The chemical process in the reactor creates ammonia and uses chemicals to start the reaction. This can pose a risk of this process going "out of control" leading to unwanted creation of ammonia gas. This can pose a health risk and reduced enjoyment of the outdoor space in the immediate and larger neighbourhood. 4) The application posting on the Environmental Registry does not mention a time limit to this application. The proponent mentioned a one year time limit to this proposal. I want to ensure that this amendment is for one year only and only for up to 70 tons of biosolid processing per day. After this permit expires all granted permits should be set back to the current level. 5) The proponent should be forced to have a dedicated 24/7 phone number to report any odour issues from the community that are outside normal operating hours at this facility. Furthermore the proponent should demonstrate a setup to be able to react to odour complaints outside operating hours. 6) The proponent should be required to setup continuous ammonia monitoring along the fence line to pro-actively be aware of emitted ammonia levels. It would be wrong to rely only on the neighbouring community to report unpleasant odours back to the company. These odours need to be prevented in the first place and at all times. To ensure this a continuous ammonia monitoring strategy should be presented to the Ministry for approval and implementation. 7) The proponent should NOT be allowed to stage arriving loaded  trucks or park loaded trucks of any kind outside the building to reduce any odour emissions into the surrounding areas. Furthermore no more than one “delivery” truck with biosolids at a time shall be granted to be on-site of this facility to reduce the risk of odour impacts for the residents. No more than one “pickup” truck with the finished fertilizer product shall be on-site at any given time. 8) The operation hours for this permit should be restricted to weekdays from 7am to 7pm only to minimize the risk of impacting residents' enjoyment of the outdoors (backyards) during weekend hours. 9) The proponent’s application form states under the section Consultation the following: Community consultations deemed not necessary due to environmental insignificance of pilot project application. I challenge this assessment as arbitrary and not fact based. The proponent mentions on Page 10 of "ECA 6303-4Q9J8G Amendment Requests' that the operation is expected to potentially release mild ammonia odours in a best case scenario. Since the building is not enclosed the proponent has no means of controlling these odours once released to the air. The proponent furthermore is not proposing any air monitoring devices or strategies other than relying on the community to call in concerns. All of the above as a total warrants proper community consultations, since the proponent solely relies on the community to call in air odour concerns. Another concern is the fact that the proponent will be using sulphamic acid and quicklime on-site. When added to the biosolids both will lead to exothermic reactions, that in an event of operational problems could lead to a process going “out of control” in terms of excessive heat. Ammonia is also created during the process as well and it is an irritant. The fact that these substances are used on-site warrants a community consultation to educate the community better about this proposal and potential risks. 10) During the voluntary community Open house the proponent handed out pamphlets which describe the process. Nowhere is it mentioned that the process will produce 12 litres / minute of waste water from the scrubber unit. This waste water has to be trucked off-site for treatment or disposal. I do not see any specific mention in the application how exactly this waste water will be handled, i..e spill prevention, preventing it from ending up in the sewers, storage site on-site, quantities stored on-site, etc. I request that this application be sent back to the proponent to further provide details in this area of concern. 11) Extension of the consultation period: I hereby request an extension of this consultation period based on two facts. The first one as described above under section 9) the proponent mentioned during the open house on October 16, 2018 that there will be no air or odour monitoring systems used but asked the community to call in any concerns. This involvement of the community warrants an extension of the comment period, since the proponent just disclosed this information about 10 days prior to the comment period expiring. Secondly I have found it initially very difficult to view the application documents at the Hamilton District Office. I have called the posted number and have been transferred to an officer that could not find this application even after I shared the EBR Registry #, The Ministry Ref. Number, the proponent name and the site address. Neither resulted in locating any application documents. Then I have been passed on to another officer that was not in on that day and I could not reach her the following day. It was not until I have reached out to an individual I know at the District Office that he personally invited me to come to the office to provide all documents. I think the above shows a general unpreparedness of the MECP to provide application documents. It took me one week from initial contact with the MECP to then finally view them. If it was not for this individual's help I might have not been able to see them on time at all. I have tried to reach the Toronto office of the MECP over the last 2 days and left a message for a return call but not received one. By doing so I was hoping of making this extension request before the expiry of the comment period.