Red Eagle Trailer Park Inc. - Environmental Compliance Approval (sewage)

Comment #1

It is not clear whether this is for a new septic system to replace existing (inadequate) systems of sewage management or if it is for an additional system. Is it their intention to increase the number of trailer sites or to upgrade the sewage treatment of the existing sites? What is the basis for the proposed volume? Not enough information is presented here to validate the requested treatment system.

Are there sufficient measures being taken to protect the new system from high water levels, current and future?

With an old trailer park located lakeside on intermittently flooded sandy soil, will there be adequate phosphorus adsorption capacity to ensure that the lake is not impacted for several decades? Aquatic macrophytes are an increasing threat to residents' enjoyment of the lake, and all possible measures should be taken to limit pollution from human waste.

Ministry response

The centralized sewage works is proposed to augment the existing sewage works and does not propose an increase to the number of trailer sites at the site.

Comment #2

I am making this post to raise concerns with the process regarding ERO 019-1230 that is intended to ensure public participation in the consultation process as required by the Ontario Environmental Bill of Rights. My family and I are long time lakefront property owners on Wollaston lake, a cold deep Lake Trout lake deemed “at capacity” by the Ministry of the Environment.

The problem is that people are unable to access documentation and other information within deadlines – or at all – that would allow them to be informed. Following the application posting on the environmental registry of Ontario on January 31, 2020, there was a delay of approximately three weeks before documents were available for viewing, and then, only in the Belleville office. Further, despite a request to the proponents and an FOI request to the MECP, I am currently unable to access the documentation supporting the application. I am also therefore unable to provide the requested information to a third-party professional engineer for review.

I am particularly concerned in this case based on the proponent’s previous non-compliance to the planning process: The Red Eagle campground has increased the number of sites on the shores of Wollaston Lake without the necessary environmental assessments having been completed. Therefore, it is essential that before this ECA review process proceeds, stakeholders of Wollaston Lake are assured that the property in question is capable of supporting the 226 trailers identified in the application to prevent this site from unduly contributing to the further eutrophication of Wollaston Lake.

These concerns are further amplified by the acknowledgement during the LPAT hearing for a second trailer park, Bear ridge of non-compliance to planning process by the owners’ legal counsel and the Township of Wollaston’s legal counsel.

Please consider this posting as a formal request to review the breakdown in due process that is preventing adequate public participation in the consultation process as required by the Ontario Environmental Bill of Rights. I request that an extension be granted until such time as the FOI request is processed and the 3rd party engineer is able to complete their review.

Ministry response

Ministry review and approve the design of sewage works to ensure that the environment is protected, while the municipality review and approve site plan approval.

Comment #3

As a neighbour of the Red Eagle Campground for many years, I am writing with concern about the sewage system of the trailer park. Since the 1970's, the Red Eagle has undergone extensive growth. It is essential for the health of Wollaston Lake, the surrounding environment, and our local economy that their sewage system is done right. The same applies to all lakefront property owners, naturally, but since the trailer park's sewage system needs to support 226 families this represents the largest stakes of any system on the lake. Of particular concern is that their property, like the properties of many others of us on the lake, is on a floodplain/close to the water table.

We need to ensure the growth of invasive species such as Eurasian milfoil is not being aided by phosphorus from inadequate sewage systems. When going up the Deer River, one can now see the many trailer sites that are right on the river, and changes made to the shoreline due to moorings or docks for boats. There is a large and growing infestation of Eurasian milfoil along and at the mouth of the Deer River, where it enters Wollaston Lake.

We need to be better informed before a decision is made regarding the Red Eagle's ECA. I am requesting the MECP make all supporting documentation available for this purpose. Thank you for your consideration.

Ministry response

Ministry review and approve the design of sewage works to ensure that the environment is protected, while the municipality review and approve site plan approval.

Comment #4

The proposed sewage works are on a property that abuts Wollaston Lake and the Deer River. The proposed sewage works are within the floodplain of the adjacent Wollaston Lake and Deer River. There is no storm water drainage study or analysis presented, as it would relate to these proposed sewage works.

The property is within an area of Site Plan Control, per the by-laws of Wollaston Township. An extensive development such as this sewage system on a property designated as being under Site Plan Control mandates that the Ministry of Environment is party to a Site Plan Control Agreement. There is not known to be any proposed Site Plan Control Agreement.

Wollaston Lake is designated as an "At Capacity Lake" under the Official Plan of the County of Hastings. As such, any nearby development requires a Lake Impact Study and Environmental Impact Study prior to proceeding. There are not known to such studies.

Further to this, between trailer parks and waterfront residential properties, there are approximately 600 households oriented to Wollaston Lake. A Lake Impact Study is necessary.

The documents related to this application are not available online, and have become entirely unavailable due to the recent COVID-19 crisis. It is very strongly suggested that the application be deferred until all relevant documents are available online, and the public therefore has a reasonable period of time to provide more informed comment about this proposed development. Documents located 100 kilometres away do not constitute reasonable public access in this online world.

Ministry response

Ministry review and approve the design of sewage works to ensure that the environment is protected, while the municipality review and approve site plan approval.

Comment #5

As a lakefront property owner on Wollaston Lake, in Coe Hill Ontario, I have concerns with the Environmental Compliance Approval (ECA) application itself and also with the manner in which this process is being conducted.

The application for this ECA is for a trailer park which is located on the shore of Wollaston Lake as well as the bank of the Deer River. Although this establishment has been operating at this location for over 40 years this ECA will be the first one granted for this property. Wollaston Lake is classified as an “At Capacity”, “Lake Trout Lake”, and since the proposed sewage works will be developed on the active flood plain of the Deer River, a river that flows directly into Wollaston Lake, I believe that an Environmental Impact Assessment should be obtained as a minimal prerequisite before any approval of the ECA is granted.

Wollaston Township’s lack of enforcement of non-compliance issues regarding infractions of its Comprehensive Zoning By-law, including some matters that involve this property, should also be closely examined, and taken into consideration, prior to the approval of this ECA application. Further to this, I believe consideration should be made for the requirement of a Site Plan Control Agreement, entered into by both the owners of the property and Wollaston Township, in order to ensure that the works are constructed and operated in such a way that ensures the environment is safeguarded, now and in the future.

With respect to the ECA itself, the public has not had a reasonable opportunity to examine or obtain the documentation associated with the application. Despite a Freedom of Information request being made to the MECP, and a separate private request being made to the applicants of the ECA, no materials have been available to the public other than for ‘viewing only purposes’ at the MECP office in Belleville or Toronto. Since these documents were not readily available to the public for a considerable after the original posting, consideration should be given for this lack of reasonable access to the materials, which in turn, made it impossible to arrange for an independent 3rd party review of the application to be completed within the allotted time.

Since the purpose of this is exercise, as set out in the Environmental Bill of Rights, is to ensure that there is an opportunity for public participation in the process, I am requesting that the deadline for submitting comments on this issue be extended primarily to ensure that there is sufficient time allowed for the completion of a professional engineering review of the submitted documentation.

Ministry response

Ministry review and approve the design of sewage works to ensure that the environment is protected, while the municipality review and approve site plan approval.