Due to the fact that he City…

Due to the fact that he City of London recently declared a climate emergency, the provincial application should be considered in this light, with a much more stringent review of energy and waste guidelines.

Timing of the application: we understand the new processes have been in place for a year or more – the timing of this application is cynical in that these processes were designed and implemented long ago. Denying the public a right to comment until well after changes are in place are a cynical abuse of process. Operation of the new processes should be suspended until the application, instrument decision and any potential appeals) are considered.

Use of energy: The combined maximum fuel input rate of the natural gas equipment units is over 28 million btu/hour, a phenomenal amount of energy for a completely ridiculous product – McNuggets. Greta Thunberg argues that our house is on fire – approving such rampant energy use (& waste) without significant public consultation is completely unacceptable.

Emissions levels: CO2 and NO2 at 89% and 86% of allowable maximums respectively, and suspended particulate at 61%. The Ministry may say these are in allowable limits but there’s no detail given – for example, WHO guidelines for certain thoracic particles (TP) suspended particulate matter are 70ug/m3 and this plant averages 73.3. More detail and study required!

Animal testing – the Safety Data Sheets show the use of products tested on rabbits, guinea pigs, fish, shrimp and other species. Cargill’s complicity in both polluting the planet with these chemicals and torturing killing other species (in addition to the 30 million + chickens) is frankly shameful.

More farms: Increased capacity and required additional farms with their impact on the environment. What increase in production from approval of these new methods? How many more farms and birds and trucks on the roads? What of the environmental impact of those?

Water & sewage levels & quality: Insufficient information is provided on the discharge of water (volumes and state of pollution) into the municipal sewer system. How can an environmental application be approved without any indication of how much fresh water is used in the operation, and consequently how much sewage is generated?

Understated volumes? Volumes appear to be grossly understated. The production target is believed anecdotally to be 120,000 birds per day, which equates to over 200,000kg of birds per day, however the application refers to 10,000kg of finished ‘product’ maximum daily. Is this an error or a deliberate misstatement? At the very least the application should be resubmitted with a new comments period.

Truck runoff impact: No information is provided on emissions generated by the transport of birds – feces and urine are regularly seen spilling from trucks on streets surrounding the plant.

Gas storage: CO2 and other gas storage – not information is provided on the capacity of (unvented?!) gas chambers CO2, backup generator systems, safety measures. Are they safe?

Odour patterns: Significant odours do come from the plant – an odour dispersion study map should be provided despite the lack of residences within 500 metres. Thousands of workers are within this range for long hours – the onus should be on Cargill to capture their odours and study their dispersion.

Stunning and cleaning: Insufficient information is provided on the success rate of stunning, unloading process of birds, loading or cleaning of trucks and cages. How can the Ministry and the public be assured that these are best practices (not for the birds, humans or the planet) and not environmentally harmful?

Blood and Viscera: In the 21st century, describing blood and viscera as being ‘removed by a rendering company’ is insufficient for an environmental application. Cargill should report on the ultimate uses and destination of the blood and ensure responsibility for the transportation and disposal.

Biogas recapture vs CO2, NO2 etc. venting: Modern facilities should be and increasingly are recapturing biogas and emissions – Cargill can vent those within City limits? Ridiculous.