1384341 Ontario Ltd. operating as Cavanagh Developments - Environmental Compliance Approval (sewage)

Comments were received and reviewed, and, where appropriate, were considered in the design of sewage works by the consultant and in the ministry’s decision whether or not to proceed with the proposal.

Summary of the comments and the ministry's responses are below:

1. The rezoning of the site to be light industrial is a concern.
    

   Ministry’s response: The local municipality is in charge of rezoning and the ministry will not comment on this issue.

2. The development will significantly impact the nearby village’s water table and communal wells.
    

   Ministry’s response: The consultant assessed the impact of development to groundwater and the ministry’s groundwater specialist reviewed the assessment. It was found that limited hydraulic connection is expected between the shallow overburden aquifer and the deep bedrock aquifer. The water supply wells in the area (including the site) are deep and completed in the bedrock, hence, it is not expected impacts from activities and/or historical shallow contamination at the site. To reassure the public with a precautionary approach, pre-construction baseline groundwater monitoring and post-construction groundwater monitoring at three monitoring wells are imposed in the sewage approval to monitor water quality and water levels before and after the operation of the proposed plant. The results will be summitted to the ministry in annual report and available for the public.

3. The operation will contaminate the Huntley Creek and washout water from the fleet of aggregate, sand, cement and concrete trucks will cause water contamination.
    

   Ministry’s response: All process operation will be in the enclosed plant and no outdoor operation and material storage is allowed. Washout water will be treated in covered tanks in a closed-loop and water is returned to the plant for reuse and sediment will be disposed off-site. This approval only permits the construction of stormwater management works for the collection and treatment of non-contact stormwater runoff. Contingency plan is in place for spills from the trucks. In addition, water quality monitoring in the Huntley Creek is proposed. Pre-construction baseline surface water monitoring and post-construction surface water monitoring at upstream and downstream of Huntley Creek are required in the Approval. The results will be submitted to the Ministry in an annual report and available for the public.

4. Species at risk exist in the area.
    

   Ministry’s response: Biologist from the ministry has reviewed the mentioned species and the area. It is important to note that the existence of these species is not confirmed. Comments and recommendations were provided to the consultant and there is no further concern on the impact of development to the mentioned species.

5. There is groundwater seep/springs on the property.
    

   Ministry’s response: Groundwater seep/springs on the property as noted within the EBR comments was not identified at the site by qualified personnel, and the 2018 Environmental Impact Statement prepared by Muncaster Environmental Planning Inc. states that no seeps or springs were observed during their field surveys according to Golder. The pond previously identified at the northeast of the existing building, located outside of the development area cross-gradient from the stormwater system at the site, is not considered a natural hydrogeological feature.

6. The idea that 2 bioretention facilities will capture, filter and remove all dissolved toxins is ludicrous. According to the Environmental Impact Statement, the bioretention facilities are only designed to “capture runoff from the concrete site plant for precipitation events (rain or snow) under 27 mm or the first 27 mm of higher intensity precipitation events.” This area has had several precipitation events greater than 27 mm during the Spring of 2019 alone. Ottawa has had record flooding both in 2017 and 2019, so it is reasonable to assume that with the effects of climate change, this area will continue to experience regular mass flooding.
    

   Ministry’s response: The ministry agrees that stormwater management with two bioretention facilities is not adequate and capture runoff for precipitation events under 27 mm is not acceptable. The consultant was requested to revise their design. After several revision, the stormwater management design is completely different now: StormSack insert filters installed on all catchbasins to remove total suspended solids, oil and grit separator to provide further treatment and remove any oil, dry pond to provide further treatment and handle storm events up to 100-year storm events, and bioretention trench to provide polish treatment. Truck wash water will be treated in a closed-loop covered tanks and reused in the plant with no discharge to the environment.

7. Considering that concrete, cement aggregate and sand trucks will all be subject to unintended wash-off during rain events, and that the washout ponds are in the open, provisions for stormwater management appear inadequate to protect Huntley Creek and the groundwater that the surrounding community relies on.
    

   Ministry’s response: The consultant was requested to revise their design. After several revision, all material will be stored indoor and truck wash water will be treated in a closed-loop covered tanks and reused in the plant with no discharge to the environment. There will be no unintended wash-off during rain events and no open washout ponds.