*Please note that there is…

*Please note that there is nothing in this submission that prevents MECP from publishing this comment to the ERO.

Dear Madam/Sir

Please accept this submission as Environment Hamilton's formal comments on this ERO registry posting for an ECA - Waste for CCPS Land Development Ltd - for their 389 Kenora Avenue facility in Hamilton.

We have two main concerns about this application. First, on reviewing the supporting documents for this application. we could not find any information about odour control measures beyond the proponent's assertion that the activities take place indoors. We are concerned that this may not be enough to control potential odours generated by the proposed activities for this location. We would like to see assurances added to the ECA for this facility regarding odour impacts that the proponent will properly manage odour impacts at the site. We note that, while this facility is surrounded by other industrial activities, it is within 282 meters of a grocery store (Lococo's at the corner of Kenora & Barton Streets) and within 415 meters of a townhouse complex located on the south side of Barton Street. Assurances need to be provided to the public that there will not be odour impacts from this operation.

Related to this concern, we also note that the existing ECA NUMBER 7722-8CBM5S includes a condition that requires the proponent to transfer dewatered solids from the site at least once every 30 days. This requirement seems to be heavily emphasized in the ECA. We would like assurances that a similar requirement will be imposed in this new ECA regarding dewatered solids and frequency of transfer from the site. We are assuming that this requirement was put in place to minimize the potential for odour impacts.

Finally, it is our understanding that the City of Hamilton was asked for comment on this proposal. We have not had the opportunity to see city comments, if any were in fact submitted. But we hope that, should the city raise any concerns that we have not addressed in our submission, that these will be appropriately addressed in the final permit for this operation.

Thank you for the opportunity to comment on this proposal.

Lynda Lukasik, PhD
Executive Director
Environment Hamilton
llukasik@environmenthamilton.org
TEL: (905) 549-0900