HomeMy WebLinkAboutPSD-141-07
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REPORT
PLANNING SERVICES
Meeting:
GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
Date:
Monday, December 3, 2007
Report #:
PSD-141-07
File #: PLN 33.3.10
By-law #:
Subject:
DURHAMNORK RESIDUAL WASTE ENVIRONMENTAL ASSESSMENT STUDY -
SITE SELECTION PROCESS
MUNICIPAL COMMENTS ON STEP 7 - EVALUATION OF SHORT-LIST OF SITES
AND IDENTIFICATION OF PREFERRED SITE
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee recommend to
Council the following:
1. THAT Report PSD-141-07 be received;
2. THAT this Report and Attachments 5, 6, 7, 8 and 9 be adopted as the Municipality of
Clarington's comments on Step 7 - DurhamlYork Residual Waste Environmental
Assessment Study - Site Selection Process;
3. THAT the Regions of Durham and York be requested to respond to and address, early
in 2008, the issues identified by the peer review consultants that are necessary for the
submission of the EA documentation to the Ministry of the Environment;
4. THAT the Regions of Durham and York commit to including in the Request for
Proposals and Certificate of Approval, Maximum Achievable Control Technology
(MACT) for the emission standards and monitoring that the EFW facility will meet;
5. THAT the Regions of Durham and York be requested to delay the final selection of a
preferred site for the Energy from Waste facility until such time as the submissions in
response to the Request for Proposals have been reviewed, a preferred technology and
vendor has been selected, and the sensitivity analysis in relationship to the site
selection and the specific Human Health and Ecological Risk Assessment has been
carried out;
6. AND FURTHER THAT the final site selection be delayed until the business case for the
Energy from Waste facility clearly indicating the cost to the taxpayers of the Regions of
Durham and York has been adopted by the Regional Councils;
REPORT NO.: PSD-141-07
PAGE 2
7. THAT a copy of Report PSD-141-07 and Council's decision be forwarded to the
Durham-York Joint Waste Management Group, the Region of York, the Region of
Durham, the Ministry of Environment, and the other area municipalities in Durham
Region; and
8. THAT all delegations and interested parties be notified of Council's decision.
Submitted by:
Da (j J rome, .C.I.P, R.P,P.
Director of Planning Services
Reviewed bY~ ~
Franklin Wu,
Chief Administrative Officer
JAS/FUDJC/sn
27 November 2007
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T (905)623-3379 F (905)623-0830
REPORT NO.: PSD-141-07
PAGE 3
1.0 PURPOSE OF REPORT
1.1 On September 21, 2007, the Regions of Durham and York issued the reports
prepared by their Consultants related to Step 7 of the facility siting process for the
DurhamlYork Residual Waste Environmental Assessment (EA). Step 7 involves the
evaluation of the Short-List of sites and the identification of a preferred site for the
DurhamlYork energy-from-waste (EFW) facility.
1.2 As a result of their evaluation of the Short-Listed sites, the Regions' Project Team
Consultants have identified Clarington Site 01 as the Recommended Preferred Site
for the EFW facility. The reports relating to the Step 7 evaluation have been issued
for public and agency comments, with December 10, 2007 being the deadline for
submitting comments on Step 7 of the site selection process.
1.3. The purpose of this report is to provide the Municipality of Clarington's comments
on Step 7 of the facility siting selection process. This report incorporates comments
prepared by both staff and the Municipality's peer review consultants. The report
discusses and focuses on the over-arching issues related to the EA process, the
evaluation of the Short List of Sites and the selection of a Recommended Preferred
Site. More detailed comments regarding these and other issues are provided in the
reports prepared by the Municipality's peer review consultants, attached to this
report as Attachments 5 through 9.
1.4. Clarington's Peer Review Team and Staff met with the Regions' Project Team on
October 10, 2007 to review questions and seek clarification on items; the responses
provided by the Regions' Project Team Consultants are indicated in Attachment 10.
However, for 62 of the 127 issues raised by Clarington, the Regions' Project Team
Consultants responded that the issue would be addressed at a later date and/or
prior to the submission of the EA documentation in late 2008.
2.0 OVERVIEW OF STEP 7 (SITE EVALUATION PROCESS)
2.1 Steps 1 through 5 of the site selection process resulted in the identification of the
following four Short-Listed sites (see Attachment 2), which were then evaluated in
Step 7:
Clarington 01 A 12.4 ha parcel owned by the Region of Durham located
on the west side of Osbourne Road immediately north of the
CN rail line in the Clarington Energy Business Park
Clarington 04 A 14.8 ha privately owned parcel located immediately south
of Highway 401 east of the South Service Road
Clarington 05 A 27.2 ha privately owned parcel located immediately south-
east of the Highway 401/Courtice Road interchange
East Gwillimbury 01 An 11.5 ha site owned by York Region in the Town of East
Gwillimbury, immediately adjacent to York Region's Waste
Management Centre.
REPORT NO.: PSD-141-07
PAGE 4
2.2 The Short-Listed sites were evaluated by the Regions' Project Team Consultants on
the basis of criteria grouped into five categories - Public Health & Safety and
Natural Environment, Social and Cultural, Economic/Financial, Technical Suitability,
and Legal. Each category was assigned a priority on the basis of public consultation
undertaken in Step 1 of the facility siting process. The first and last categories were
assigned high and low priorities respectively, while the other three were assigned a
medium priority. Attachment 3 provides more detail on the evaluation criteria.
2.3 Using these criteria, the Regions' Project Team Consultants undertook a
comparative evaluation of the four Short-Listed sites. Potential effects to the
environment and reasonable measures to mitigate these effects were identified,
resulting in the identification of the net effects for each of the sites. Under each
criterion, the net effects for each site were compared and ranked as follows: Major
Advantage, Advantage, Neutral, Disadvantage, and Major Disadvantage. The
Regions' Project Team Consultants evaluation was primarily qualitative, relying on
their professional judgement and using previously established community priorities
as noted in 2.2 above. How the evaluation was carried out and the professional
judgment applied is not clear.
2.4 The following table summarizes the evaluation of the Short-Listed sites undertaken
by the Regions' Project Team Consultants. According to this evaluation, Clarington
Site 01 was the only site that was ranked as having an advantage in all high and
medium priority categories, and the only site ranked as having an overall
advantage. No site was ranked as having a major advantage in any category.
Environmental Clarington 01 Clarington 04 Clarington 05 E. Gwillimbury 01
Cateaorv
PRIORITY: HIGH
Public Health & Major
Safety & Natural Advantage Neutral Disadvantage Disadvantage
Environment
PRIORITY: MEDIUM
Social & Cultural Advantage Disadvantage Disadvantage Neutral
Economic/Financial Advantage Disadvantage Neutral Neutral
Technical Advantage Neutral Advantage Advantage
PRIORITY: LOW
Leaal Neutral Disadvantage Disadvantage Neutral
OVERALL ADVANTAGE DISADV ANT AGE DISADV ANT AGE NEUTRAL
Attachment 4 provides a more detailed breakdown of the evaluation undertaken by the
Regions' Project Team Consultants.
2.5 The Regions' Project Team Consultants have a number of separate reports
attached as Annexes to the main report of the site selection process. These reports,
as noted below, provide the detailed information and rationale of how the evaluation
criteria were applied and how the indicators were used in the evaluation process:
REPORT NO.: PSD-141-07
PAGE 5
Annex A
Annex B
Annex C
Annex D
Annex E
Annex F
Annex G
Annex H
Annex I
Potential Air Quality Impacts
Potential Water Quality Impacts (Surface Water and Groundwater)
Potential Environmentally Sensitive Areas and Species Impacts and
Aquatic and Terrestrial Ecology Impacts
Compatibility with Existing and Proposed Land Uses
Report on Archaeological and Cultural Resources
Potential Traffic Impacts
Capital Costs and Operation and Maintenance Costs
Compatibility with Existing Infrastructure and Design/Operational
Flexibility
Complexity of Required Approvals and Agreements
3.0 CLARINGTON'S PEER REVIEW OF STEP 7 DOCUMENTS
3.1 Clarington's Peer Review Consultants and Staff have prepared brief reports
highlighting the substantive issues that have not been adequately addressed to date
(Attachments 5 through 9). The focus of this staff report will be the over-arching
issues related to the site selection process and those that have previously been
identified by Clarington Council through its endorsement of the recommendations
contained in PSD-070-07 (Attachment 11) and PSD-097 -07 (Attachment 12) as
items critical to any decision to be a host community to the EFW facility.
3.2 General Concerns in Site Evaluation Process
3.2.1 A review of the evaluation process used to identify the recommended site has
identified a number of deficiencies with the evaluation process. In particular, the
evaluation process is not clearly described, and parts of the process do not appear
to be consistent with either the Environmental Assessment Act or the approved EA
Terms of Reference. It is the opinion of Staff and the peer review consultants that
the site evaluation process has been inconsistent, as discussed below.
Determination of Advantages and Disadvantages
3.2.2 The Environmenta/ Assessment Act requires an EA to describe the advantages and
disadvantages to the environment associated with each alternative method (i.e.
site). However, the EA study determined the advantages and disadvantages of
each site in comparison to the other sites. For example, under some criteria a
negative impact on the environment is seen as an "advantage" because the impact
is not considered to be as great as for the other sites. This approach creates
difficulties in undertaking a consistent comparison and assumes that all of the
REPORT NO.: PSD-141-07
PAGE 6
Short-Listed sites are suitable for the EFW facility. The peer review consultants note
that this assumption has not been justified by the EA study work done to date.
3.2.3 The definitions used for the terms "advantage", "disadvantage", and "neutral" in the
main study report are not the same as those used in the technical background
documents. For example, the main study report uses the following definition of
Major Advantage: "Development of the site would have minimal impact based on
the criteria/indicator being applied and in most cases a net benefit would result from
facility development." However, in the Annexes (supporting technical documents), a
major advantage was identified for any site "with the significant ability to meet the
evaluation criteria when compared with the other sites." This lack of consistency in
the definitions of the indicators used to evaluate and rank the Short-List of sites
remain a concern.
Assessment of Net Effects
3.2.4 The EA Terms of Reference states that each potential effect will be considered with
respect to the availability of measures to mitigate a negative effect or to enhance a
positive effect, resulting in a "net effect". It is these net effects that are to be
considered when evaluating and ranking the sites on the short list. However, it
would appear that the Regions' Project Team Consultants ranked an alternative that
does not require mitigation as being preferable to an alternative that does require
some mitigation, even though the net effects would be the same. This is illustrated
by the following example given in the main study report to describe a Major
Advantage - "A site that would not require the development of additional
infrastructure would be considered a major advantage when compared to a site that
does require additional infrastructure development." A proper analysis would
consider alternatives that have the same net effect as being equal. Any effect would
be more appropriately considered in the relevant criteria group - for example, the
costs associated with the various mitigative measures should be considered under
the Economic/Financial criteria.
3.2.5 In addition, the Regions' Project Team Consultants did not adequately consider the
application of mitigative measures when determining the net effect of an alternative.
For example, in the assessment of impacts to surface water quality, Clarington Site
01 was considered to have an advantage over the other Short-List Sites because it
is located 600 m from the receiving water course, while Clarington Site 05 was rated
as neutral because it is located 250 m from the watercourse. In fact, the net effect
for both sites should have been rated the same since surface water runoff from both
sites would be collected in a stormwater pond prior to being discharged to the
stream.
Transparency and Traceability of the Evaluation Process
3.2.6 The evaluation process undertaken as part of EA process must be transparent and
traceable, and readily replicated by others reviewing the EA document. A number of
both quantitative and qualitative approaches can be used to ensure that these
REPORT NO.: PSD-141-07
PAGE 7
objectives are achieved. Quantitative approaches such as the arithmetic method
seek to quantify the evaluation by assigning numerical values to the effects
associated with an alternative, and thus are generally traceable and replicable.
Qualitative approaches, on the other hand, rely on the professional judgment of the
reviewers and, by their very nature, are more subjective and less easily traced and
replicated or sensitivity assessed. Some EA studies use both approaches, not only
to improve the understanding of the evaluation process, but also to confirm the
validity of the results (sensitivity testing).
3.2.7 The Municipality's peer review consultants do not necessarily disagree with the use
of a qualitative-only approach to the site evaluation. However, in such cases, the
rationale used in the evaluation must be clear and sufficiently detailed to enable
readers to clearly trace and replicate the process. This information has not been
provided in the EA study documents. The Regions' Project Team Consultants have
indicated that additional information will be provided before the EA documents are
submitted to the Ministry. However, given the deficiencies in the evaluation process
discussed above and in Attachments 5 through 9, both Staff and the Municipality's
peer review consultants remain concerned that there are flaws in the evaluation
process used to identify a preferred site. It is unlikely that they can be addressed
by providing more information.
3.2.8 The Regions' Project Team Consultants used a qualitative approach to consider
and compare site advantages and disadvantages, identify trade-offs, and select
preferences. A quantitative approach was not used to validate the results of their
evaluation process. For these and other reasons discussed below, both staff and
the Municipality's peer review consultants have not found the evaluation process
used in the EA study to be traceable, transparent and replicable.
3.2.9 A deficiency in the evaluation process was the absence of a mechanism to weight
the importance of the various criteria. The Regions' Project Team Consultants
indicated that, as a result of public consultation early in the EA process, a high
priority was assigned to the Public Health & Safety and Natural Environment criteria
group, a medium priority was assigned to the Social and Cultural, Economic!
Financial, and Technical Suitability criteria groups, and a low priority was assigned
to the Legal criteria group. However, it is not readily apparent how these relative
priorities were incorporated into the evaluation process, other than through the
professional judgement of the Regions' Project Team Consultants. An appropriate
mechanism to accomplish this could have been to assign a relative weight to each
criteria group that reflected the priority given to it by the public.
3.2.10 Another deficiency in the site evaluation process results from the combining of
diverse criteria into one criteria group. This is most significant in relation to "Public
Health and Safety" and "Natural Environment". These criteria were assigned a high
priority by the public and each is worthy of its own criteria group. However, the
Project Team Consultants combined both into one criteria group entitled "Public
Health and Safety and Natural Environment". Given that there are only a total of five
criteria groups, this results in the devaluing of public health and safety and natural
REPORT NO.: PSD-141-07
PAGE 8
environment considerations in the overall evaluation. This effect is further
compounded by the absence of a mechanism to assign relative priorities (ie. weight)
to the different category groups as discussed above. It is unclear whether the
public, when they were asked the questions about weighting of the criteria in March
and June of 2005, had a clear understanding of how they would be employed and
there has been no mechanism for confirming with the public that they concur with
how the evaluation criteria has been applied.
3.3 Separation of Site Selection from Technology Selection
3.3.1 Clarington's peer review consultants have questioned the rationale for separating
the site selection process from the competitive vendor selection process. Clarington
Staff appreciate that the Request for Proposals (RFP) is being carried out in a
confidential and objective manner. However, it would not be compromised by
including two (2) geographically separated sites as suggested in PSD-097-07.
Carrying two sites forward would allow for a better evaluation of the sites once the
specific thermal treatment is selected since there are differences in the background
environmental data and emissions control technologies.
3.3.2 This issue was addressed in Section 7.4 of PSD-097-07, as noted below:
"The Region has committed to revisit the short list site evaluation
after a vendor technology has been selected to determine if the site
comparison remains valid and if a change in the preferred site is
warranted. The Region should consider whether the anticipated
cost saving of determining a preferred site prior to knowing the
specific thermal technology is adequate justification given the
potential costs to revisit the short list site evaluation and the
problems that changing the preferred site could involve. The
Region should consider whether carrying forward at least two
geographically separate sites through the RFP to provide for the
option on siting in relation to the specific technology and the
specific HHERA may be beneficial."
3.3.3 The comment that the Region should carry at least two geographically distinct sites
through the RFP process remains valid, especially given the deficiencies and lack of
clarity in the site selection process identified by Staff and the peer review
consultants. As such, the benefit of retaining more that one site in the process
would allow a detailed rather than a generic evaluation of the sites to be
undertaken. In particular, this would allow for the Public Health & Safety concerns
discussed below to be addressed when a specific thermal technology is selected.
3.3.4 In the site evaluation process, the indicator "Air Quality Impacts", which is included
in the Public Health and Safety and Natural Environment criteria group, has been
used as a surrogate for human health and safety. The Municipality's peer review
consultants have indicated that there is insufficient information currently available
REPORT NO.: PSD-141-07
PAGE 9
on both background air quality and the emission controls at the EFW facility to
provide for air quality impacts to be adequately addressed at this time (see
Attachment 6). Rather, it is only when the background air quality monitoring has
been completed and the specific thermal treatment technology has been selected
that the issues concerning air quality can be addressed with any degree of certainty.
3.3.5 The underlying assumption used by the Regions' Project Team Consultants
throughout the EA study and the site selection process is that any of the thermal
treatment technologies being considered will meet MOE's A7 Guidelines, and thus
will not adversely affect human health or the natural environment. However, staff
note that some areas of potential risk have been identified by the Generic Human
Health and Ecological Risk Assessment and will need to be addressed through the
evaluation of emissions technology.
4.0 UPDATE ON RFQlRFP PROCESS
4.1 The Region issued a Request of Qualification (RFQ) to Design, Build and Operate
an Energy from Waste Facility on July 12, 2007 with a closing date for submissions
of October 11, 2007. The Region received 11 submissions from 9 different bidders
being:
1. City of Amsterdam Entity of Afval Energie Bedrijf (Waste and Energy
Company AEB)
2. Dongara Pellet Plant LP and Algonquin Power Income Fund
3. Veolia Environmental Services Waste to Energy Inc.
4. Greey CTS Inc.
5. Covanta Energy Corporation
6. WRSI/DESC Joint Venture and the Project Team Members
7. ATCO Power Canada Ltd., Thermoselect
8. Wheelabrator Technologies Inc. (A Waste Management Company)
9. Urbaser SA (Note: 3 submissions were made).
4.2 The Regions RFQ Evaluation Team will be providing a Report to Regional Council
in January 2008 indicating which of the bidders have met the 60% threshold and are
qualified to proceed to the Request of Proposal (RFP) stage. It is conceivable that
all the bidders could qualify. The RFP is to be issued in April 2008 with selection in
late-2008. The successful proposal/proponent at the end of the process will
determine both the vendor and the specific thermal treatment technology. The
Regions' Project Team Consultants will then be able to finalize the EA
documentation for submission to the Ministry of Environment by the end of 2008
based on the specific thermal treatment technology.
REPORT NO.: PSD-141-07
PAGE 10
4.3 The RFP will be formulated by the Regions' Project Team and their consultants. To
maintain the confidentiality of the process, Clarington staff are not involved in the
review process and do not wish to be. Rather Clarington can recommend certain
criteria be included in the RFP which is being drafted at this time.
Council through Resolution # Resolution GPA 632-07 and C-592-07 (Attachment
13) has requested the Region to:
"Agree to protect the health and safety of the residents of Clarington
and Durham by incorporating into the design and installation of the
EFW facility the most modern and state of the art emission control
technologies that meet or exceed the European Union (EU) monitoring
and measurement standards".
At this time Clarington Staff cannot confirm for Council that the Region is committed
to including this level of emissions control technology in the RFP; however, there
are ongoing discussions in this regard. Clarington's peer review consultants have
provided a Maximum Achievable Control Technology (MACT) outline (Attachment
14). MACT is technology-based standards based on the best-performing similar
facilities in operation and state of the art monitoring.
4.4 For the EFW facility appearance and site development, regardless of the site
selected Clarington staff have recommended that an adequate cost allowance for
the architectural finishes and site development be included in the RFP. The
qualifications of the architectural design team should be submitted as part of the
requirements; however, the evaluation of the bids should not include the "look" of
the facility. The RFP evaluation should concentrate on the interior design and
function of the facility and its emission controls and ongoing operational
improvement. A process for determining the exterior finishes and site development
can be part of the Site Plan Requirements and could be carried out in consultation
with the host community staff. Since the Region is committed to providing an
aesthetically pleasing facility and the architecture is essentially a shell around the
mechanical and emission control systems, a process for exterior and site
development design can be determined after the vendor and thermal technology are
selected. This also maintains the integrity and confidentiality of the evaluation
process.
5.0 Conclusions
5.1 The Regions' Project Team Consultants will have the opportunity to address the
deficiencies in the site selection process that have been identified by Staff and
Clarington's peer review consultants prior to the submission of the EA Study to the
Ministry of Environment. Staff and the peer review consultants will continue to work
with the Region and assist with the review of the EA documentation prior to its
submission to MOE to address the deficiencies.
REPORT NO.: PSD-141-07
PAGE 11
5.2 Clarington Council has already passed Resolutions GPA 632-07 and C-592-
07(Attachment 13) which requests the Region to protect the health and safety of the
residents of Clarington and Durham by incorporating the most modern and state of
the art emission control technologies and monitoring systems. Clarington's peer
review consultants have been working on a Maximum Achievable Control
Technology (MACT) outline (Attachment 14) which is a technology-based standard
based on the best-performing similar facilities. The MACT and continuous
monitoring for key parameters should be included in a Host Community Agreement
and the Certificate of Approval from the Ministry of the Environment. In addition, it
will be necessary to demonstrate that the actual levels of emissions are acceptable
and low risk.
5.3 In Report PSD-097-07, Staff and Clarington's peer review consultants suggested
that two geographically separated sites should be carried forward to the Request for
Proposals. This is especially important given the anomalies identified in how the
site evaluation has been carried out and the significant differences between the
sites depending on which specific thermal treatment technology is selected. It is
therefore again recommended that two geographically separate sites be carried
forward to the Request for Proposals stage. The site specific Human Health and
Ecological Risk Assessment can then be used to determine which site is more
suitable with respect to public health and safety.
5.4 An area of concern, not just to Clarington but to all residents of Durham and York, is
the business case for the EFW. There are significant assumptions, outstanding cost
implications and anticipated off-setting revenues that have been used to reach the
conclusion that the Clarington 01 site is preferred. However, given that there are
concerns regarding the financial analysis, as demonstrated in Attachments 8 and 9
and that the infrastructure cost savings could be off-set by the costs of the
emissions control technology required, there does not appear to be a clear
advantage for any of the four Short-Listed sites from an economic perspective. A
formal business case will have to be approved by Regional Council, including the
costs of a Host Community Agreement before the impact on the Regional taxpayers
can be estimated.
Attachments:
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5
Attachment 6
Attachment 7
Glossary of Terms
Map - Short List of Alternative Sites
Table 3.1 Comparative Evaluation Criteria for the Evaluation of Short-
Listed Sites
Table 4.6 Summary of Short-Listed Sites Advantages and
Disadvantages
Review of the Step 7 Draft Report: DurhamNork Residual Waste
Study, Evaluation of Short-List of Sties and Identification of
Consultants Recommended Preferred Site, Steven Rowe
AMEC Peer Review - Preferred Site Selection Process - Conclusion
SENES Consultants Limited, Memorandum, Review of Site Selection
Study Documents - Main Report! Annex Band C
REPORT NO.: PSD-141-07
Attachment 8
PAGE 12
Attachment 9
Attachment 10
Attachment 11
Attachment 12
Attachment 13
Attachment 14
TSH Memorandum, DurhamNork Residual Waste Study, Peer
Review Comments
Finance Department Memo
Jacques Whitford/Genivar response chart
Resolution for PSD-070-07
Resolution for PSD-097-07
Resolution GPA 632-07 and C-592-07
Maximum Achievable Control Technology (MACT) outline
Interested Parties.
Joachim Baur
Alexandra Bennett
Barry Bracken
Kathi Bracken
Wendy Bracken
Karen Buck
Terry Caswell
Katie Clark
Shirley & Keith Crago
Kevin Diamond
Wayne Ellis
Linda Gasser
James Gibson
Glenda Gies
Tenzin Gyaltsan
Ron Hosein
Dr. Debra Jefferson
Laurie Lafrance
Lee McCue
Warren McCarthy
Cathrine McKeever
Kerry Meydam
John Mutton
Karen Nichol
Dave Renaud
Jim Richards
Andrew Robson
Yvonne Spencer
Nicole Young
Lucy Wunderlich
Bill Collie
Anthony Topley
Katherine Miles
Paul Andre Larose
Don Wilkinson
Noah Hannah
Katherine Miles
Donna Mcaleer-Smith
Kristin Robinson
Steve Tharme
David Climenhage
Steve Conway
Chester Miles
Bernadine Power
Hilary Balmer
Willis & Marilyn Barrabal
Stewart and July Dayes
Maureen Dingman
Carl Zmozynski
Gaston Morin
Ann and Mike Buckley
Fraser and Cathy Grant
Jean and Wallace McKnight
Stephanie Adams
Julie Allen-Freeman
John & Dale Cerniuk
Garland & Anne Foote
Sylvain Gagnon
Melissa Girard
Beth Hewis
Manuel Jimenez
Debbie Kuehn
John MacDonald
Ralph Machon
Mary Anne & Gerry Martin
Kristin D. McKinnon-
Rutherford
Lorna McSwan
Brent Mersey
Donna Packman
Devon Richard
Brian & Sharon Thompson
Bill & Lorna Turner
Doug Woods
Don Wright
Benjamin Fuller
Chief & Medical Director
Lorraine Huinink, MCIP,
RPP
John Oates
Rev. Christopher Greaves
Lesiie Heinrichs
Diana Kanarellis
Elaine & Vincent Ho
Ron Campbell
Stephanie Adams
Betty Robinson
Nicola Keeme
Mable M. Low
Jacqueline Muccio
Chariie and Irene Briden
Nadia McLean-Gagnon
Mrs. Dorothy Barnet
Marc Tepfenhart
EA
EFW
HHERA
MOE
MACT
RFP
RFQ
Attachment 1
To Report PSD-141-07
GLOSSARY OF TERMS
Environmental Assessment
Energy From Waste
Human Health and Ecological Risk Assessment
Ontario Ministry of the Environment
Maximum Achievable Control Technology
Request for Proposals
Request for Qualifications
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Attachment 3
To Report PSD-141-07
T bl 3 1 C
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Criteria Indicator
Public Health & Safety and Natural Environment
Air Quality Impacts Local meteorological conditions
Note: The preferred technology must al
least meet al/ applicable air
quality regulations.
Distance travelled from main source(s) of waste generation to the
site.
Water Quality Impacts (Surface Relative distance to and type of watercourses (aquatic habitat)
Water and Groundwater) present within close proximity of site for wastewater
or surface water discharge from facility (if applicable).
Receiving body for wastewater discharge from
the facility (if applicable)
Quality of water in the receiving body based on
size and flow of watercourses.
Environmentally Sensitive Areas and Species of special concern, threatened and/or endangered species
Species Impacts identified by Ministry of Natural Resources (MNR) in the area
potentially impacted by the site or haul route.
Distance from site or haul route to areas that are designated
Natural Heritage Features and Areas including: Significant
Wildlife and Fish Habitat; Significant Areas of Natural and Scientific
Interest; Significant Wetlands, Woodlands, etc.;
Designated Hazard Lands; and, Conservation Areas
Aquatic and Terrestrial Ecology Amount of woodlands, hedgerows, etc., affected or removed at
Impacts the site and the degree of impact on the edge of a
woodloVhedgerow.
f
E
f
C "t
f th E
f
fSh rt L" tS"t
Social and Cultural Environment
Criteria Indicator
Compatibility with Existing and/or
Proposed Land Uses
Consistency with current land use, approved development plans,
and proposed land use changes.
Compatibility with existing land use designations.
Residential Areas
Size of buffer zone available on the site.
Opportunity for brownfield development.
Distance from site to designated residential areas within an
appropriate separation distance of the site and within an
appropriate separation distance of the haul route(s).
Number and distribution of residences within an appropriate
separation distance of the site and within an appropriate
separation distance of the haul route(s).
Social and Cultural Environment
Criteria Indicator
Parks and Recreational Areas
Number and type of recreational areas (i.e., parkland) within an
appropriate separation distance of the site and within an
appropriate separation distance of the haul route(s).
Institutional Facilities or Areas
Number and type of institutions within an appropriate separation
distance of the site or area and within an appropriate separation
distance of the haul route(s).
Archaeological and Cultural Resources
Number and significance of known archaeological and cultural
areas at the site based on review of documented sites and the
potential for uncovered resources to be located at the site.
Traffic Impacts
Type of roadway (i.e., paved, gravel) and access to businesses
and/or subdivisions & proximity of site to major arterial roads or
highways.
Existing and projected volume oftraffic along haul route (i.e., high,
moderate or low).
Conformity with Durham's Goods Movement Network
Economic/Financial
Criteria Indicator
Capital Costs
Site development costs, including: infrastructure required,
upgrades to existing infrastructure (roads, sewers, etc.), property
acquisition and possible site remediation.
Operation and Maintenance Costs
Distance from waste generation points, transfer stations (e.g.,
length of haul route), annual operating costs and maintenance
costs.
Mitigation requirements
Monitoring requirements
Distance from potential markets for sale of marketable materials
(i.e. heat, electricity, recovered metals, etc.).
Technical Considerations
Criteria Indicator
Compatibility with Existing Infrastructure
Design/Operational Flexibility Provided
by Site
Distance from required infrastructure (i.e., sewers, hydro, road
access, water).
Area surplus to minimum requirement provided by site.
Legal Considerations
Criteria Indicator
Complexity of Required Approvals
Nature of approvals required.
Nature of property acquisition (related to the need for expropriation,
Region owned or willing seller site).
Complexity of Required Agreements
Revised Attachment 4
To Report PSD-141-07
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OVERAll: ADVANTAGE NEUTRAl ADVANTAGE ADVANTAGE
Compl"""y of R8<lUIt'ed DISADV ANT AGE DISADVANTAGE DISADVANTAGE DISADVANTAGE
Approval.
Complexity of Required ADVANTAGE DISADVANTAGE DISADVANTAGE ADVANTAGE
Agr.ements
OVERAll: NEUTRAL DISADVANTAGE DISADVANTAGE NEUTRAL
Attachment 5
To Report PSD-141-07
REVIEW OF THE STEP 7 DRAFT REPORT: DURHAMIYORK
RESIDUAL WASTE STUDY
EVALUATION OF SHORT-LIST OF SITES AND IDENTIFICATION OF
CONSULTANTS RECOMMENDED PREFERRED SITE
Prepared for
The Municipality of Clarington
By:
Steven Rowe Environmental Planner
November 2007
TABLE OF CONTENTS
1. Introduction ........................ ..... ...... ....... ..... .................................................... 3
1.1 Background ........... ...... .... ......... ... ..... .................................................... 3
1.2 Adoption of a Preferred Alternative to the Undertaking ........................3
1.3 Short List Report .................................................................................. 3
2. Identification of a Preferred Site ....................................................................6
2.1 The Preferred Site Report.................................................................... 6
2.2 Approach to the Review....................................................................... 7
2.3 Commentary on the Preferred Site Report........................................... 7
2.3.1 Report Introduction ....................................................................7
2.3.2 The Evaluation Criteria .............................................................. 8
2.3.3 Description and Approach to the Preferred Site Identification... 9
2.3.4 Review Against the Evaluation Criteria.................................... 10
3.0 Conclusion............................................................................................... 14
1. Introduction
1.1 Background
Steven Rowe Environmental Planner was retained by the Municipality of
Clarington in May 2007 to review a process being conducted by the Regions of
Durham and York to identify a site and vendor/technology for a thermal treatment
or energy-from-waste facility. The process forms part of a study being conducted
under the Ontario Environmental Assessment (EA) Act to identify an undertaking
"to process... .the waste that remains after the application of both Regions' at -
source waste diversion programmes in order to recover resources - both
material and energy - and to minimize the amount of material requiring landfill
disposal."
The EA must be conducted in accordance with Terms of Reference (TOR)
approved by the Minister of the Environment on March 31,2006. The TOR
outlines a screening and comparative evaluation process for "alternative methods
of implementing the undertaking" (i.e. siting alternatives). Preliminary screening
and evaluation criteria for alternative methods are provided in Appendix F to the
TOR. The TOR and subsequent documentation - including the documents under
review here - relating to this process may be found on the project website at
http://www.durhamvorkwaste.cal.
1.2 Adoption of a Preferred Alternative to the Undertaking
In May 2006 the DurhamlYork Joint Waste Management Group (JWMG)
established to oversee the EA process recommended that their respective
Regional Councils approve their consultants' recommendations regarding a
preferred "alternative to" the undertaking or waste management technology
system. The preferred alternative encompassed two generic types of system,
both involving heat treatment of waste and production of energy. The exact
thermal technology will not be known until Durham and York Regions have
identified a preferred vendor through an ongoing Request for Qualifications and
Request for Proposals process.
1.3 Short List Report
In March, 2007 the consultants for Durham and York Regions produced a "Draft
Report, Thermal Facility Site Selection Process, Results of Steps 1-5,
Identification of the "Short-List" of Alternative Sites" (the "Short List Report"). The
report describes a process of "screening" lands (i.e. removing from further
consideration based on exclusionary criteria) across the two Regions, identifying
a "long list" of sites within the unconstrained areas, and evaluating these to
identify a "short list" of sites.
The short list comprised Clarington Sites 01 and 05, which are located in the
Clarington Energy Business Park south of Courtice, Clarington Site 02 located
south of the Energy Park, Clarington Sites 03 and 04 located on industrial land
west of Bennett Road and south of Highway 401, and East Gwillimbury Site 01
located north of Davis Drive and east of Woodbine Avenue. Clarington Site 02
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Steven Rowe Environmental Planner November 2007
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was later removed from the list when its "Greenway" land use designation -
which was an exclusionary criterion - was confirmed. Clarington Site 03 was
removed when its owner withdrew it from consideration. The short listed
Clarington sites are shown on Map 1 attached to this report.
In July and August 2007 Steven Rowe Environmental Planner reviewed the Short
List Report and produced an "Interim Report: Gap Analysis of the EA Process
and Review of the Site Selection Process" that was presented at Clarington's
General Purpose and Administration Committee on September 4, 2007 as
Attachment 6 to Report PSD 097 07. The Interim Report identified a number of
concerns with the Short List Report and found that it did not provide enough
information to support the conclusions reached. The following is a list of the
issues identified in the conclusions of the Interim Report, with insertions in italics
where findings need to be qualified based on present day circumstances.
"Issues in relation to the site selection process conducted to date are:
. The Site Selection Short List Draft Report does not provide screening maps to
show which parts of the study area were excluded under each of the criteria,
and it does not provide sufficient explanation of how each of the criteria were
applied. The process is not traceable as described. The Regions' consultants
subsequently provided C/arington with a set of screening maps, but they have
not been provided to the public or other stakeholders.
. Despite the lack of screening information it is apparent, for example, that not
all federally regulated airports were considered in the screening, and it is not
clear whether or how federal requirements were applied in relation to organic
waste as an attractor for birds, or stack height as an obstruction to aircraft, or
both. If all regulated airports are considered under a consistent approach this
may result in the exclusion of additional lands from the study area. The
Oshawa Airport was added to the airport constraint mapping, but the
remaining concerns are not addressed. Around the proposed Pickering
Airport land is shown as constrained when permitted heights of structures
based on federal airport zoning are well in excess of the assumed stack
height for the facility.
. The information presented in the Site Selection Short List Draft Report does
not describe a comprehensive approach to the identification of public lands.
There may be public lands in the study area owned by agencies that were not
directly approached as part of the process.
. There is uncertainty regarding the size of the facility being sought by the
proponent team and the size of site required to accommodate it. The process
as presently structured would give preference (other things being equal) to a
large site such as the 27.4 hectare Clarington Site 5, when the site size being
sought is around 10-12 ha. There is also ambiguity over the scale of facility
that would be required, with a proposal by York Region to scale back its
involvement, and by Durham Region to seek expanded capacity. On a large
site there may be no physical limitation on the ultimate scale of a thermal
treatment facility. It is now proposed that the facility be constructed with a
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Steven Rowe Environmental Planner November 2007
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capacity of 150,000 to 250,000 tonnes per year, depending on the outcome of
altemative a"angements made for a portion of York Region's waste. The
ultimate proposed capacity is 400,000 tonnes per year, which may include
waste from other non-GTA municipalities, and industrial, commercial and
institutional waste. Site size issues are dealt with further in the Preferred Site
Report.
o The sites in the Clarington Energy Business Park are being analyzed as part
of a different economic study and could have either a positive or negative
affect; the effects are potentially different depending on which site is selected.
o The Report indicates that a change in direction was undertaken to bring lands
in the Greenbelt into the site selection process, but it does not describe
whether or how lands in the Greenbelt were examined to identify potential
public and willing seller sites other than the East Gwillimbury Site 1. There
may be other potential sites in the Greenbelt that have not been identified.
o The Site Selection Short List Draft Report does not provide a full description
of how consultation on the proposed methodology and criteria affected the
approach now being undertaken. The Regions' consultants subsequently
posted a copy of a missing consultation document on the project website.
In relation to the site evaluation and comparison currently under way (at that
time - i.e. the preferred site comparison now completed in draft form):
o The proponent team now proposes to identify a recommended preferred site
and to submit an interim environmental assessment planning document to
the Ministry of the Environment in the fall of 2007, before a preferred vendor
and the exact thermal technology has been identified. This would mean that
a site would be selected without knowledge of the facility that would be sited
on it or its specific environmental effects. Therefore the assumptions being
made by the consulting team must be reviewed in light of information on the
specific selected technology and its environmental effects.
o It would be greatly preferred if information on the vendor/technologies and
their environmental effects was available for the site comparison. The final EA
submission will have to include the vendor and specific technology to meet
the EA terms of reference and EA Act.
o There is also concern that the process of selecting a preferred vendorl
technology through the ongoing Request for Qualifications and future
Request for Proposals may not meet EA Act requirements.
In relation to the short-listed sites identified in Clarington:
o There are existing and proposed residential uses in close proximity to Sites 3
and 4, which are in the Bowmanville Urban Area. (Site 3 was subsequently
withdrawn)
o The Durham Region Official Plan and the Clarington Official Plan identify a
proposed interchange between Lambs Road and Highway 401 that would
likely be displaced by a thermal treatment facility on Site 4.
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. A proposed industrial service road passes through both Sites 3 and 4.
A thermal treatment facility Occupying the whole of Site 5 would displace the
primary entrance to the Clarington Energy Business Park from the Courtice
Interchange, and the western part of the 'spine' route through the Park. The
Energy Business Park was initiated, planned and approved in partnership
with Durham Region, and there is potential for an EFW facility to compromise
the vision and planned function of the Park. The proponents are examining
alternative siting concepts for each site and not all of each site will necessarily
be required."
Other than the instances noted above, the proponents have not provided
information to resolve the identified issues and have not committed to resolve
them in an interim environmental assessment planning document that the
Regions propose to provide to the Ministry of the Environment at some later date.
2. Identification of a Preferred Site
2.1 The Preferred Site Report
On September 21, 2007 the Regions' consultants produced a "Draft Report,
Thermal Treatment Facility Site Selection Process, Results of Step 7: Evaluation
of Short-List of Sites and Identification of Consultants Recommended Preferred
Site" ("Preferred Site Report"). The report describes the application of criteria
derived from those provided in the TOR, priorities identified through consultation
and the team's professional judgement in evaluating and comparing the four
remaining short-listed sites to identify a preferred site. The preferred site as
recommended by the Regions' consultants is Clarington Site 01, located in the
Clarington Energy Business Park.
There are a number of technical "Annexes" to the report that describe the
evaluations conducted under individual disciplines, as follows:
Annex A: Report on Potential Air Quality Impacts
Annex B: Report on Potential Water Quality Impacts (Surface Water and
Groundwater)
Report on Potential Environmentally Sensitive Areas and Species
Impacts and Aquatic and Terrestrial Ecology Impacts
Report on Compatibility with Existing and/or Proposed Land Uses
Report on Archaeological and Cultural Resources
Report on Potential Traffic Impacts
Report on Capital Costs and Operation and Maintenance Costs
Report on Compatibility with Existing Infrastructure and
Design/Operational Flexibility Provided by Site
Report on Complexity of Required Approvals and Complexity of
Required Agreements
Annex C:
Annex D:
Annex E:
Annex F:
Annex G:
Annex H:
Annex I:
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2.2 Approach to the Review
This document review relates to the broad consistency, transparency and
traceability of the EA process and includes the Preferred Site Report and
selected parts of the Annexes that relate to the assumptions, information and
methodology used in the site comparison.
As part of an ongoing effort to resolve issues to the extent possible, the
Municipality of Clarington peer review consultants undertook a preliminary review
of the report and the appendices/annexes relevant to their disciplines, and
Clarington staff provided their consultants' initial concerns and questions to the
Regions and their consultants. A meeting was held (October 10th) between
Clarington's and the Regions' staff and consultants, and written responses were
provided to Clarington for the majority of the issues by October 26, with further
clarification being received by November yth.. These responses are reflected in
the review that follows.
Clarington's peer review consultants met on November 16th to jointly review the
Regions' responses and methodology employed in the evaluation of the sites.
2.3 Commentary on the Preferred Site Report
2.3.1 Report Introduction
This review follows the sequence of material in the Preferred Site Report, with
references to the technical annexes where appropriate.
Section 1, Introduction, provides an overview of the study and a summary of
the Terms of Reference and the process conducted to date. This includes a
description of the site selection process up until Step 5, for which comments are
provided above and, in more detail, in our earlier report.
Under "Shared Opportunities" Section 1.1, states:
"Facing common waste disposal issues, the Regions are acting to
implement, as quickly as possible, a DurhamlYork based solution that: is
socially and politically acceptable to both communities; maximizes
environmental protection; and, fosters the wise management of resources
that are currently lost by way of landfill in Michigan."
The reference to "as quickly as possible" relates to the 2010 deadline after
which Durham and York will no longer have the option of waste disposal at
landfill sites in Michigan. The need for an accelerated process to accommodate
this deadline has reduced the amount of information available to support
decisions at each step of the process, and the ability to respond to issues raised
as the process proceeds. As indicated in our earlier review of the Short List
Report, details on the specific technology to be used and its environmental
effects are not available as the preferred site is being selected. The proponents
have made a commitment that when the preferred vendor has been selected a
sensitivity analysis would be undertaken to confirm that the process leading to
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Steven Rowe Environmental Planner November 2007
Pg. 7
the selection of the preferred site remains valid. Clarington's Peer Review Team
believe it would be prudent to carry more than one site in the Request for
Proposals to allow for the sensitivity analysis to have more validity.
The reference to "maximizing environmental protection" raises an issue identified
by the Municipality's technical peer review consultants, that the Regions'
commitment to environmental protection, the actual level of protection and the
means of implementing and monitoring this is very unclear at the present time.
Section 1.2.2 describes the evaluation of "alternatives to" (Le. technologies). The
descriptions of the two selected systems, Systems 2(a) and 2(b) include
gasification of mixed waste or solid recovered fuel, respectively, whereas the
following description identifies gasification as a "new technology" in relation to
System 2(b) only. The proponents have confirmed that both systems could
include gasification, however this description could have been written more
clearly (Le. is gasification a new technology when applied to both mixed waste
and solid recovered fuel, or to solid recovered fuel only?).
Section 1.3.2 includes a description of facility/site size requirements, and
identifies a need for 13.7 ha site with a 100m buffer and 7.3 ha without a buffer, if
all required facilities are included within the site. In Appendix E to Annex H
("Technical Memorandum on Facility Site Size") it is assumed that an additional 1
ha would be required for a stormwater pond, however Clarington staff have
indicated that shared, off-site stormwater facilities would be required in the
Clarington Energy Business Park, and therefore for the preferred Clarington Site
01 and Clarington Site 05. At 12.4 ha, Clarington Site 01 is smaller than the 13.7
ha requirement if a 100m buffer is to be included. The Technical Memorandum
includes "Usable Site Area" plans of all the short-listed sites showing how a
facility could be configured within each site - Figure 2, the plan for the preferred
Clarington Site 01 and Clarington Site 05, is attached as Map 2.
The Technical Memorandum also states that land on Clarington Site 05 south of
a watercourse is "unusable", and this is reflected in the above "Usable Site Area"
plan. There appears to be an opportunity to sever and dispose of this additional
land, and yet the cost of the full area of the site is assumed for the purpose of the
cost comparison. When this comment was provided to the proponents'
consultants they responded by conducting a cost sensitivity analysis that
excludes an estimate of the value of the area south of the watercourse. This is
further discussed below.
2.3.2 The Evaluation Criteria
Section 3 of the Preferred Site Report describes the evaluation of the short-listed
sites. Table 3.1 provides the criteria used for the evaluation, with corresponding
"indicators" and "rationale". The following comments are provided on the contents
of this table:
. The "rationale" under "Compatibility with Existing and/or Proposed Land
Uses" mentions a need for rezoning when the evaluations under this criterion
state that public uses are generally permitted in all zones in Durham Region.
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Steven Rowe Environmental Planner November 2007
Pg. 8
However, Clarington staff will have to consider whether a rezoning would be
required for the proposed facility on lands within the Energy Park.
. There is potential for double- counting between the "Compatibility" and
"Residential Areas" criteria. The Regions' consultants response to this
concern is that "As the evaluation approach was qualitative in nature the risk
of double counting generally does not apply. A qualitative process allows for
the evaluation to account for, discount and therefore avoid double-counting.
Where necessary, this consideration can be documented and explained in the
evaluation text" In practice, the Preferred Site Report limits the use of the
"Compatibility" criterion to permitted land uses and future land use changes
rather than actual land uses on the ground.
. In our initial comments to the Regions' consultants we noted that there seems
to be an inherent conflict in the "Institutional Facilities or Areas" criterion.
While the indicator is "number and type of institutions within an appropriate
separation distance", the rationale notes that there are some institutional
facilities that can benefit from close proximity to the facility. The consultants'
response is that there would not be a conflict, but this appears not to be an
issue in the actual site comparison.
2.3.3 Description and Approach to the Preferred Site Identification
The description and application of the "advantages and disadvantages"
evaluation and the application of mitigation measures in the report generated a
number of comments and questions for the Regions' consultants. Overall, it was
considered by Clarington's consultants that the description of the evaluation
approach in the Preferred Site Report is unclear. For example:
. The description of the net effects analysis on page 3-6 of the Preferred Site
Report states that the net effects analysis was done based only on available
data, and yet it is clear from the annex documents that the work included field
work in a number of instances. In the consultants' initial responses it was
suggested that a more accurate description be provided. The Regions'
consultants responded that there was only limited field reconnaissance and
the field studies were not considered to be sophisticated. They should still
have been included in the description, however.
. The description of the process on page 3-6 describes the application of
mitigation measures to determine net effects, however Table 4.1 suggests
that no site specific mitigation was considered.
. "Advantages and disadvantages" are defined differently in the main report
versus the annex documents, suggesting that the technical consultants had a
different understanding of this term than those who prepared the main report.
The explanations are also unclear. The Regions' consultants reply that "the
intent of a relative site comparison is achieved by both".
. The descriptions of advantages and disadvantages appear to be at variance
with the meaning of these terms in the EA Act. For example, the definitions in
Table 3.2 state that alternatives with a "major advantage" or an "advantage"
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Steven Rowe Environmental Planner November 2007
Pg. 9
under a criterion can have "minimal" or "manageable" effects, respectively.
Also, under the "Potential Air Quality Impacts" criterion the effect on air quality
based on distance of collection and transfer vehicles travelled to Clarington
Site 01 is considered an "advantage". Under the EA Act, however, the
proponent is to consider advantages or disadvantages to the environment. An
advantage cannot be a negative effect or simply an advantage for one
alternative over another.
. The description of the "advantage" ranking in Table 3-1 suggests that if an
alternative does not require mitigation, it is preferable to one that does (i.e.
where an impact is "manageable"), even though the net effect is the same. In
fact alternatives with the same net effect should be assessed equally - if the
mitigation itself has an environmental effect (including cost) this can be taken
into consideration in the comparison under the appropriate criteria.
. The description of the process does not make a clear distinction between
environmental effects and advantages and disadvantages, whereas these are
two different concepts in the EA Act. The Regions' consultants have
responded that their approach did involve identifying and rating environmental
effects first, followed by application of tradeoffs and interpretation of effects in
terms of advantages/disadvantages. This is not clear from the report,
however.
. There is no demonstration that the "advantages" and "disadvantages"
identified represent equivalent or comparable increments or magnitudes of
effect. As indicated above, in this process an "advantage" is not necessarily a
positive effect but can represent a lower level in a range of negative
environmental effects. In the actual evaluation results are traded off against
each other as if they are positive and negative effects, which they are not. In
some instances a "neutral" and an "advantage" are combined to result in an
"advantage", which further distorts the comparison.
. In addition, the evaluation uses a prioritization of criteria categories derived
from public consultation as well as "professional judgement" in comparing the
siting alternatives, however the application of these priorities is not explained.
The Regional consultants' response to these concerns is to state that a more
comprehensive description of the process will be provided in a draft EA
document to be submitted to the Ministry of the Environment. It is unclear
whether this more comprehensive description will reflect the concerns identified
in relation to Steps 1-5 as well as Step 7 of the site selection process.
2.3.4 Review Aaainst the Evaluation Criteria
Public Health and Safety and the Natural Environment
Air quality impacts are dealt with by Clarington's air quality consultant (AMEC).
Water quality impacts: Our initial response to the Regions' consultants
asked why there would be different environmental effects resulting from a facility
location 800m versus 15m from a watercourse. In response to this concern the
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Steven Rowe Environmental Planner November 2007
Pg. 10
Regions' consultants explained that a lengthy outlet channel that is "shady" is
more beneficial than a shorter outlet channel because it can mitigate water
temperature effects. We defer to Clarington's technical consultants in verifying
this.
Environmentally Sensitive Areas and Species Impacts: In our initial response we
asked why species of conservation concern that (p.3-10) that are highly unlikely
to occur on the site - Bushy Cinquefoil (occurs on lake beaches) and Red-tailed
Hawk (dense deciduous forest) contribute to the identification of environmental
impact. The response was that "There is evidence to suggest that these species
are known to exist in the areas and therefore, may be potentially impacted by this
development..... in a relative comparison of sites, a site without this potential is
advantaged over another with no potential impact"
For the Bushy Cinquefoil, the consultants' Annex C states (p. 3-1): "Bushy
Cinquefoil is a lakeshore species preferring beach and wet prairie habitats. This
type of habitat is not found on the site (Clarington 01), thus it is unlikely this
species would occur on site. The NHIC record of this species in the general area
is likely a record from the nearby Lake Ontario shoreline." Also, "the Red-
shouldered Hawk is a woodland nester that occurs throughout southern Ontario.
Given the absence of woodland habitat on the East Gwillimbury 01 site, it is
extremely unlikely that this species breeds on or immediately adjacent to the site.
There are existing woodlots east and north of the site that may provide suitable
habitat for this species. This species was not observed on-site during the site
visit." In neither case - and particularly in the case of Clarington Site 01 - does
the evaluation establish a potential environmental effect with any degree of
certainty.
We also questioned the disadvantages posed by hazard lands if the facility can
be accommodated on the rest of the site. The Regions' consultants responded
that the presence of hazard land presents a relative disadvantage, and
consideration includes the potential need for monitoring of impact to the area
during construction and operation. It is still unclear, however, what the potential
environmental effects would be, other than those already addressed by other
criteria (e.g. water quality impacts, aquatic and terrestrial ecology).
There is a lack of explicit consideration of mitigation, or measures that would
reduce potential environmental impact, thereby reducing the net environmental
effect. This is illustrated by the "Major Disadvantage" rating given to Clarington
site 05 under the "Aquatic and Terrestrial Impacts" criterion. This is based on the
presence of woodland and hedgerows, and potential aquatic habitat on site. The
woodland and watercourse identified in Annex C, Public Health and Natural
Environmental Considerations is 100 metres or more distant from the "site
infrastructure" and "site layout" templates shown in Annex H, Infrastructure and
Site Size (Appendix 2 to this report). The conceptual facility location also appears
to avoid most if not all of the hedgerow. There appears to be an opportunity to
mitigate the impact through placement of the facility at a distance from these
features, but this was not taken into consideration in the comparison. This places
Review of the Step 7 Draft Report: DurhamIYork Residual Waste Study
Steven Rowe Environmental Planner November 2007
Pg.11
the site at an unnecessary disadvantage when it is compared with other sites,
and similar concerns arise (for different sites) for a number of the other criteria.
The "Public Health and Safety and Natural Environmental Considerations"
category has the highest rating in the evaluation. Because of the methodology
adopted by the proponent, however, public health and safety and natural heritage
"advantages and disadvantages" are traded off against each other in arriving at
an overall rating under this category for each site. Clarington Site 1, for example,
was assigned a "disadvantage" under "local meteorological conditions". This
rating, however, was discounted against an "advantage" assigned in relation to
emissions from haul traffic, resulting in a "neutral" level for "Potential Air Quality
Impacts", This, when traded off against natural heritage ratings, resulted in an
"advantage" overall for Clarington Site 1. Even if the Clarington Peer Review
Team's other concerns with the evaluations carried out under the criteria in this
category were discounted, the public may not have intended the potential air
quality effects of the facility and the haulage effects on air quality to be
discounted against each other and for air quality effects overall to be discounted
by natural environment considerations when it assigned a high priority to this
category as a whole.
Social and Cultura/ Considerations
Compatibility with Existing and/or Proposed and uses: Table 4.2 states that a
Regional Plan Amendment "may" be required to permit a facility at East
Gwillimbury Site 01 - the consultants indicated in response to our comment that
York Region was not willing to comment or provide clarification as to whether a
ROPA would be required.
The land use profile of the East Gwillimbury site in Annex D: Report on
Compatibility with Existing and/or Proposed Land Uses does not discuss the
Greenbelt Plan, although the Plan is identified in the evaluation tables. The
proponents' consultants have indicated that this matter will be addressed in the
EA documentation to be submitted to the Minister.
We noted in our initial comments that the 1 km distance for land use compatibility
is calculated from the centre of the site and not the edge or a conceptual location
as shown in the "Usable Site Area" plans. The Regions' consultants responded
that the 1 km radius was applied consistently, and that the potential configuration
of the facility on the site has little impact on the application of this criterion. At the
same time, it is preferable to use a more detailed level of information when this is
available.
In relation to the "Archaeological and Cultural Resources" criterion we requested
a clearer description of the advantages and disadvantages of the sites with
mitigation, and the Regions' consultants committed to review and enhance the
material where necessary.
Review of the Step 7 Draft Report: DurhamIYork Residual Waste Study
Steven Rowe Environmental Planner November 2007
Pg. 12
Economic/Financial Considerations
We noted in our initial review that the haul cost analysis is based on savings from
existing rather than actual costs, and that this would comprise a saving from
costs of haulage to Michigan, which would no longer be available. The
consultants responded that a remote Ontario landfill was assumed for the
purpose of calculating haul cost savings. Section 3.2.2 of Annex G, Costs, states
that "Operating costs are presently incurred to haul residual waste from existing
transfer stations and collection areas to remote landfill sites such as Green
Lane." We still consider that a comparison of actual costs would have been more
appropriate than savings over long distance haulage, which is not an alternative
considered in this EA, would not represent the true cost of the alternatives, and
would tend to reduce the relative magnitude of difference between the short
listed sites.
We also noted that acquisition costs for Clarington Site 01 and East Gwillimbury
Site 01 are rated at zero because they are owned by Durham and York Regions,
respectively. This is inappropriate because there would be an opportunity cost to
the public purse of "losing" either of these sites - they still have value that should
be reflected in the site comparison. The Regions' consultants responded to this
concern and the concern about including the "unusable" portion of Clarington Site
05 in the cost comparison by undertaking a sensitivity analysis that considers the
opportunity costs of using the two publicly owned sites and discounts the
"unusable" Clarington Site 05 land. They found that this analysis showed that
with these factors considered the overall conclusions do not change.
The findings from the capital cost analysis in the Preferred Site Report and in the
sensitivity analysis are compared in the following table:
Clarington 01 Clarington 04 Clarington 05 E Gwillimbury 01
Capital Costs: Site specific Site specific Site specific Site specific
Preferred Site capital costs capital costs capital costs capital costs
Report range from $7.6 range from $8.9 range from $10.6 range from $3.8
to$11.3million to $16.7million to $15.5 million to $11.4 million
Overall rating, Neutral Disadvantage Disadvantage Advantage
Preferred Site
Report:
Capital Costs: Site specific Site specific Site specific Site specific
Sensitivity capital costs capital costs capital costs capital costs
Analysis range from $7.6 range from $8.9 range from $8.9 range from $3.8
to $13.1 million to $16.7million to $15.5 million to$13.1 million
Overall rating, Neutral Disadvantage Disadvantage Advantage
Sensitivity
Analvsis
Comment Lower end of No change Lower end of Lower end of
range would be (privately owned) range is reduced range would be
$9.4m (second ("unusable" land $5.5m if land
highest) if land discounted) but cost added
cost added not the higher
range (would be
$138m)
Review of the Step 7 Draft Report: Durham/York Residual Waste Study
Steven Rowe Environmental Planner November 2007
Pg. 13
It is not clear why the sensitivity analysis applied changes at only one end of
each of the cost ranges affected. If the changes were applied to costs at both
ends of each range Clarington Site 01 would be seen as roughly equivalent to
Sites 04 and 05 from a capital cost perspective. This would, in turn, affect a
present value calculation of both capital and operating costs as discussed below.
We also commented to the Regions' consultants that the evaluation treated
operational cost and capital cost "advantages and "disadvantages" as equal
when there is no basis for comparing them. It was suggested that these costs be
"present valued" (i.e. converted to reflect total costs over the long term, rather
than capital costs versus annual costs). The Regions' consultants responded by
producing a present value calculation that they say shows Clarington Site 01 as
preferred under their "lower" and "higher" capital cost assumptions.
Lower Site
Specific Capital
Costs ($ X1000)
Savings +ve and
costs -ve)
Higher Site
Specific Capital
Costs
CL 01
$23,308
CL 04
$21,610
CL 05
$20,455
EG01
$22,750
$19,774
$14,163
$15,760
$15,471
This calculation appears to depend on the effects of savings in long term haulage
to a remote landfill site over a 20-year term, however. As noted above, actual
haul cost figures would have been a more appropriate measure to compare the
sites with each other, and may have resulted in a different outcome.
3. Conclusion
Overall, further information is required from the Regions' consultants to
demonstrate that their EA planning process is traceable, replicable, logical and
systematic, and that Clarington Site 01 is indeed the preferred site.
The most significant issues raised in this review comprise:
. Use of secondary information such as information on species at risk and
endangered species for the broader area, rather than site specific data that
would have provided more certainty as to actual effects for the purpose of the
comparison and would have been more appropriate in the final siting decision
for a major public utility use;
. Lack of identification and consideration of reasonable mitigation in identifying
rankings, resulting in unnecessary distortions in the site comparison;
. Concerns with the lack of consideration of the opportunity cost of publicly
owned sites in the site comparison, and with the consultants' approach in
attempting to resolve this in its sensitivity analysis.
Review of the Step 7 Draft Report Durham/York Residual Waste Study
Steven Rowe Environmental Planner November 2007
Pg. 14
. Concerns with trading off capital against operational costs and the use of
"savings" to calculate operational costs, and the consultants' approach in
attempting to resolve this in their sensitivity analysis;
. Flaws in the way "advantages and disadvantages" are identified, aggregated
and considered in the site comparison. Advantages and disadvantages do not
necessarily represent advantages and disadvantages to the environment, as
required by the EA Act, and this has the potential to affect the site
comparison.
. The effect of the selected evaluation methodology in reducing the relative
significance of the air quality and natural environment criteria rated highest by
the public through the consultation process, by trading these criteria off
against each other.
The Regions' consultants have committed to describe the evaluation
methodology in more detail in their interim environmental assessment document.
In their covering letter to their responses to our comments they state that "we
confirm that it is our position that the process we employed is sound and all of
the conclusions and findings are valid". They also appear to assume that the
finding regarding the preferred site will remain unchanged in the face of the
concerns raised earlier in relation to Steps 1-5.
The Regions' consultants have also committed to a sensitivity analysis of the site
comparison based on full consideration of the characteristics and environmental
effects of the selected technology once it is known. By this time, however, a high
degree of commitment will have been reached (for example, the preferred site
will be the basis for the Requests for Proposals) and a shift to a different site
would be costly and time consuming, especially considering the deadlines
imposed on this project. As noted above, the Clarington peer review team has
advised that it would be more prudent to proceed with more than one site.
The Regions' consultants responded to concerns expressed by SENES
Consultants in their peer review on behalf of Clarington, by saying that the
Ontario Ministry of the Environment recognized the potential environmental
effects of a thermal treatment as "minimal" when it established Regulation 101/71
and the associated Environmental Screening Process, "and therefore, such
facilities can be located on sites selected by proponents outside the historic EA
process". As described in our Interim Report, however, the proponents had an
opportunity to undertake their EA under the Environmental Screening Process
and elected to continue under the full requirements of the EA Act. They therefore
have an obligation to consider alternatives and environmental effects as required
by that legislation, rather than the Environmental Screening Process.
There are potential uncertainties regarding the process conducted to date,
including the potential for a consistent site selection process at an appropriate
level of detail to result in a different preferred site. It would be preferable to
resolve the outstanding issues now to the extent possible rather than to address
them later in the process.
Review of the Step 7 Draft Report: Durham/York Residual Waste Study
Steven Rowe Environmental Planner November 2007
Pg.15
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Review of the Step 7 Draft Report: DurhamIYork Residual Waste Study
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Attachment 6
To Report PSD-141-07
aineC!' ._m
November 20, 2007
Faye Langmaid
Manager of Special Projects
Municipality of Clarington
Dear Faye
Re: Peer Review - Preferred Site Selection Process - Conclusion
AMEC was retained by the Municipality of Clarington to undertake a peer review of the air
quality issues for specific aspects of the Environmental Assessment for the proposed thermal
treatment plant to be sited in either Durham Region or York Region.
We have reviewed the overall methodology and approach taken by the Region in reaching their
selection of the preferred site. There are some serious concerns related to overall process and
the current availability of key data and information necessary to make a final determination of
the preferred site.
The weighting or ranking of the sites is done on the basis of profeSSional judgment. Professional
judgment is used to compare the sites against each other, determining which site is preferred
over another site for each criterion and then again using professional judgment as the criterion
rankings are combined to give an overall ranking. Though this may be appropriate when all data
is available and studies completed, with incomplete data and studies still in progress, it is
possible that rankings could change for various criteria and final ranking of the sites may be
different. The "judgment" aspects of the system, do not allow for a re-assessment of rankings
based on different assumptions or different results of ongoing studies and efforts (e.g..
technology selection). As a result, the current preferred site may not stay preferred as more
data and information comes in. We would recommend carrying a second site through the
technology selection and the detailed site and background studies.
The Region is currently assuming that any technology and pollution control system can be
placed with equal impact on any of the sites. This basically assumes that the emissions from all
possible technologies and all potential facility sizes are either trivial or so insignificant that any
change to current or future air quality at these sites would be acceptable. This has not been
demonstrated. In fact, the HHRA performed for a "generic" site, indicated that a number of
parameters (e.g. dioxins and furans) were potentially at unacceptable levels at the generic site.
This lead to a statement in the "Generic Human Health and Ecological Risk Assessment" that if
the site specific risk assessment shows unacceptable risks that further emission reductions
("enhance the performance of the technology") could be undertaken to reduce the risk. This
suggests that different sites might require different air pollution control systems. The level of
control, and therefore the cost of the system, could therefore be very site specific. This cannot
AMEC Americas Limited
2020 Winston Park Drive
Oakville. ON, L6H 6X?
905-829-5400
www.amec.com
AMECPreferred Site Selection Process
final
Page 2
be assessed without further selection of a technology and control system, in conjunction with
appropriate background air quality' studies. As noted previously, the ranking system does not
allow for a determining if the ran kings of the sites would change based on whether or not
technology costs varied from site to site.
The current site selection process has considered background air quality based on existing
MOE monitors. The MOE monitors were located in Newmarket, Stouffville, Oshawa and
Mississauga. Though these are appropriate to provide a general regional background, these
monitors will not pick up specific nearby sources. As a result, the selection process does reflect
the regional background air quality, but it does not reflect any significant sources near the short
list sites. Key sources in the area that will impact the site specific local air quality in the
Clarington sites include St. Marys Cement (SMC), Oshawa urban area, General Motors and
major transportation corridors (e.g 401 and 35/115). These are existing sources that will impact
the sites and though these have been qualitatively assessed (i.e. the presence of these sources
reduces the desirability of the Clarington sites), it has not yet been determined if the absolute
level of impact at the sites are acceptable. As part of the air quality assessment and
subsequent risk assessment, it will also be necessary to determine a future baseline for these
sites. This would include modelling increased traffic and other development in the areas. Again,
as with existing air quality, the future air quality will be different at various sites. As noted
previously, the ranking system does not allow an assessment of changes in the rankings of the
sites based on either actual current background data or future predicted background data.
The MOE monitoring stations only consider a number of the key emissions (e.g. S02, Nox,
PM2.5). These stations do not monitor a number of the contaminants of concern related to
thermal waste treatment. These will include dioxins and furans and key heavy metals (e.g.
mercury). As noted previously, this background data is important in differentiating cumulative air
quality impacts (i.e. health risks) at each site. When combined with the previous discussion
above concerning technology options and control; it may be premature to choose a single
preferred site.
The Regions assessment recognizes that differences in local meteorology can influence
dispersion and as a result, the air quality at each site. The local meteorological conditions need
to be assessed with respect to specific impacts. Data is being collected for the sites. The
current challenge is that without the specific technology and control, without the site specific
background for all key contaminants and without the site specific meteorological data; it is not
possible to determine actual differences in air quality impacts at the various sites. As all of these
are still under consideration, it is not currently possible to properly assess the sites with respect
to air quality; a key component in the potential health impacts at the sites.
Further, one of the key criterion used by the Region is the air quality impacts related to traffic to
and from the site. The current assessment considers traffic for a 150,000 tpy facility and a
, It is important to note that my assessment is focused on emissions and air quality impacts. The
background assessment needed to complete an appropriate site-specific HHRA would require
background data for all media; including water and soil.
AMECPreferred Site Selection Process final
Page 3
250,000 tpy facility. As noted in the TSH review of the Region's traffic assessment report, a
proper assessment to adequately compare difference in haul distances and optimizing for road
links (e.g. the 407 has not been used in the traffic analysis) and transfer stations, indicate that
for the 250,000 tpy case, the ranking of the Clarington and Gwillimbury sites can change. The
Gwillimbury site could then go from a "disadvantage" to an "advantage". As discussed above,
since the ranking is done on professional judgment, it is not clear how this would translate into
final overall rankings. No analysis for truck traffic for the 400,000 tpy has been carried out.
In summary and conclusion, the current site selection process starts with an underlying
assumption that all of the potential technologies have air emissions at levels that can see any
technology placed on any site at the same costs and impacts. Even though the Regions own
consultants state that further control might be needed if site specific risks are present, this
potential technology change has not been considered in the site selection process. The
Region's consultants also assume that background data (current and future), site specific
meteorology and site specific key receptors are such at all sites, that the inclusion of a thermal
waste treatment facility is acceptable as a cumulative impact and that once these factors are all
taken into account the ranking of the sites will still follow the current ranking based on
professional judgment. This has not been conclusively demonstrated. We would strongly
recommend that a second site be carried forward into the detailed assessment and technology
selection process to allow for a quantitative comparison of the air quality (and human risk) and
thereby chose the appropriate preferred site.
Yours truly,
AMEC Americas Limited
~
.___._...c.....~ _
-----~
Tony van der Vooren Ph.D., P.Eng., QEP
Manager; Air Quality
Environmental Department
tony. vandervooren@amec.com
AMECPreferred Site Selection Process final
Attachment 7
To Report PSD-141-07
SENES Consultants Limited
MEMORANDUM
121 Granton Drive, Unit 12
Richmond Hill, Ontario
Canada L4B 3N4
Tel: (905) 764-9380
Fax: (905) 764-9386
E-mail: senes@senes.ca
Web Site: http://www.senes.ca
TO:
Faye Langmaidl Janice Szwarz, Municipality of CIa ring ton 34574
FROM:
M. Ganapathy I M. Monabbati I Y. Hamdyl B. Lebeau 21 November 2007
SUBJ:
Review of site selection study documents - Main Report I Annex B - Potential Water
Quality Impacts I Annex C -Terrestrial-Aquatic Biology
This is the second draft of the SENES's review of site selection study documents which was
prepared after receiving the consultant team response to the first draft of the SENES's review.
MAIN REPORT
Our review of the main thermal treatment facility site selection process indicated that there are gaps
and shortcomings in the selection process. The conclusion of the assessment that Clarington 0 I may
be a suitable site for the proposed project could have been arrived at by adopting a more transparent
and logical approach to the entire process using the existing information and assumptions. Some key
issues are as follows:
I The study claimed that the initial screening process ensured that unsuitable areas, such as
significant natural features, agricultural lands and existing residential areas would not be considered
further in the siting process. The main report indicates that some of the selected sites are in fact
located near Natural Heritage Features including: Areas of Natural and Scientific Interest (ANSI),
Environmentally Sensitive Areas (ESA), Wetlands, community parks and residential areas. This
undermines the effectiveness of the initial screening process in reviewing the other sensitive sites.
2. The main report indicates that the areas from the initial screening process consist of primarily
industrial and commercial land uses, located away from city centres and suburban communities.
However, SENES believes that this statement is not accurate as some of the short-listed sites could
be considered as close to suburban communities. The consultant team indicated subsequently that
they will "adopt the references description in future documentation to reflect the fact that some areas
may abut some sub-urban communities as set-backs were not applied to constraints at Step 2".
34574
21 November 2007
Memo to Municipality of Clarington (Continued)
Page 2
3. SENES questioned the validity of the rationale for separating the siting and the competitive
vendor selection processes. The report cites the "fairness of the selection process" as a reason to
separate the siting and vendor selection processes. It conveys an impression that all thermal
technologies are similar. This impression is evident from the Regions' consultant team response that
"modern EFW facilities are expected to have minimal environmental effects and, therefore, such
facilities can be safely located on sites selected by proponents outside of the historic EA process."
This is the stated justification for the separation of the siting and vendor selection processes. In our
opinion, the site-specific impacts of a selected technology need to be assessed prior to finalizing the
selection of the preferred sites. Given the level of uncertainty in the site selection process, in our
opinion the possibility of consideration of two sites for the tendering process should be considered.
4. SENES commented on the inappropriate use of the word "advantage" / "disadvantage"/
"neutral" etc. causing confusion in the comparative site selection study. The consultant team clarified
that the actual trade-offs were made during the evaluation process and these will be better
documented in the various discussions and tables in the future draft of the EA report and hopefully
clarify the usage of these words. However, there is a lack of traceability for the EA process at this
time.
5. The siting process uses a qualitative process to identify the preferred site for the project. The
consultant team indicated that during the preparation ofthe EA Terms of Reference, the public was
consulted and ultimately a qualitative methodology was specified. The record of public consultation
and approval of the selected qualitative methodology should be provided as an appendix to the main
report to provide evidence that the community/ stakeholders consented to a qualitative evaluation
process of the sites. In addition, weighting of the factors should be clearly identified.
6. The capital cost allocation for site infrastructure is relatively small compared with the capital
cost ofthe thermal treatment facility, and the facility cost is associated with a large uncertainty as it
is evident from the Low-Cost and High-Cost estimates in the costing report. The difference in capital
infrastructure cost estimates for various sites has no statistical significance with respect to overall
capital costs. In addition, some of utility costs may be offset by the capital cost of the project (e.g.
cost of waste water treatment and sewer connection against potentially more expensive dry scrubbing
process), thus making the utility costs even less important factor in the site selection process. In
34574
21 November 2007
Memo to Municipality of Cia ring ton (Continued)
Page 3
addition, special costs were compared to "distant landfill", which is not a comparative cost among
the alternatives. Distant landfill is not one of the alternatives being considered.
Therefore, in our opinion the capital cost of infrastructure has no significant input to the selection
process and this cost was not reviewed in detail by us. The consultant's justified inclusion of the
costs based on "Approved EA Terms of Reference"; however, our comment is concerned with the
fairness of the site selection process and documentation, irrespective of the EA Terms of Reference.
It will be desirable to include the record of public consultation and approval of the selected criteria in
the main report.
7. SENES had questioned the validity of the criteria considered for Evaluation of Short-Listed
Sites, particularly the last three criteria (page 10 of the draft site selection process report) which are
closely related to each other. Further, in our opinion, public health and safety and natural
environment are separate issues and should have been dealt with as separate criteria for impact and
fairness of assessment. In particular, the weight of air quality impact, which is the primary human
health concern, is subsumed under natural environment. Both the Clarington 01 and East
Gwillimbury 01 sites have been ranked "neutral" for air quality. However, Clarington 01 was ranked
"advantage" compared with the East Gwillimbury 01 site which was ranked "disadvantage" for
Public Health & Safety and Natural Environment Considerations.
It is also our opinion that utility costs and legal considerations have no role to play (relative to the
much larger total capital costs) in selecting a site because communities do not care whether "the legal
permitting issues are more or less" or "something costs more or less". SENES comments are
concerned with the soundness of the site selection process and selected criteria irrespective of the EA
Terms of Reference. The consultant team indicated that the criteria and indicators for these five
categories of criteria were all developed as part of the approved EA Terms of Reference. Again, it
will be desirable to include the record of public consultation and approval of the selected criteria and
EA Terms of Reference in the main report.
8. We disagree with the consultant team's assertion that the qualitative assessment avoids the
risk of double-counting. If this were the case, the proponent would not have needed to have multiple
criteria and the report could have been much shorter, with all three criteria lumped together as one
criterion.
34574
21 November 2007
Memo to Municipality of Cia ring ton (Continued)
Page 4
In summary, in our opinion, the site selection process and documentation do not convey the
impression that the process was fair and transparent.
ANNEX B - POTENTIAL WATER OUALITY IMPACTS (SURFACE WATER AND
GROUNDWATER)
The following peer review considered the responses received from the Region's consultants on the
questions previously raised by SENES regarding the report on potential water quality impacts. In
general, the responses to SENES' questions have clarified the report and provided explanations.
Some of our additional observations are as follows:
· The construction of the thermal treatment facility will result in an increase in paved areas,
parking lots, and landscaped areas which in turn will result in an increase in stormwater
flows. Stormwater Management facilities are required to detain the excess stormwater flows
and release flows which are equivalent to pre-development flows.
· The concern regarding the inclusion of the regional storm was addressed by stating that this
event will be added at the detailed design stage. We accept this response.
· The identification of the length of the modeled storm or the CN (a parameter related to the
permeability of the soil for penetration of precipitation) values for post development were
clarified by stating that the post-developed area was calculated based on an impervious site
area of 45% and the DESIGN ST ANDHYD (a hydrology computer model) was used for the
developed area. For the remaining undeveloped area, the post-development conditions are
still to be the same as the pre-development conditions and therefore, the CN value of74 stays
the same and the DESIGN STANDHYD.
· The response regarding the need to provide a description of topography and existing drainage
is not satisfactory. Although the response indicates that the topography and drainage pattern
are illustrated on the maps, a description should be added to the text.
· The response to the availability of I OO-yr and regional flood plain mapping under existing
and proposed conditions indicated that it will be investigated during the detailed design
stage. We concur with this response.
· The response to comment on the removal efficiency indicated that it will be up to the
Conservation Authority. However, as per the MOE guidelines, the requirement is 80%
removal of solids especially for sensitive streams and hopefully this will be investigated
during the detailed design stage.
34574
21 November 2007
Memo to Municipality of Clarington (Continued)
Page 5
· Section 3.3 of the report will be revised to include the requirement for Permit- To- Take-
Water (PTTW) application for the dewatering activities.
· In Table 4.1, the temperature of the receiving water (cold or warm) was used as one of the
criteria for ranking purposes. However, the Stormwater Management facility should provide
enhanced treatment, i.e. 80% removal of solids as outlined in the MOE Stormwater
Management Planning and Design Manual (2003) regardless of warm or cold fishery in the
receiving water. Therefore, the receiving water temperature should not be used as a factor in
ranking the sites.
ANNEX C ESA'S AND SPECIES IMPACTS, AND AOUATIC AND TERRESTRIAL
ECOLOGY IMPACTS
Key issues SENES had were primarily the lack of explanations or descriptions as to the methodology
and approach of this study, and the quality of technical writeup leading to low confidence in the
evaluations. These aspects were addressed specifically in the memo from the consultant team
entitled "Clarification Questions" and are not discussed in the present document. The consultant
team indicated that they will incorporate changes in the document to address these aspects. The
report, as its present condition, does not adequately support the conclusions. SENES expects that the
changes in the follow up version of the report would make the methodology acceptable.
I A key issue with respect to this report is that it was prepared without consultation with
(area/district) biologists and experts from government agencies. Only website databases
were consulted and these could be out dated. The Natural Heritage Information Centre
(NHIC) web site was last updated in 2005.
2 The report did not evaluate the plants that are locally and regionally rare and endangered.
These plants are as important as those listed by the Natural Heritage Information Centre
(NHIC) for the Province of Ontario. We raised this issue in the first version of this review.
The report's authors responded that they were not aware of any such list of rare plants listed
as locally or regionally significant. Here are the two main references (these plants are now
under the jurisdiction of Conservations Authorities):
a. J.L. Riley (with contributions from Bakowsky, W.D. and II other). 1989.
Distribution and Status of the Vascular Plants of Central Region. Ontario Ministry of
34574
21 November 2007
Memo to Municipality of Cia ring ton (Continued)
Page 6
Natural Resources, Parks and Recreational Areas Section, Central Region, Richmon
Hill. Report.
b. Varga, S. and 8 others. 1999. The Vascular Plant Flora of the Greater Toronto Area.
Ontario Ministry of Natural Resources, Aurora District. Report.
Attachment 8
To Report PSD-141-07
~~
architects
planners
5 J 3 Division Street
Cobourg, Ontario K9A 5G6
(905) 372-2121 Fax: (905) 372-3621
E-mail: cobourg@tsh.ca
MEMORANDUM
TO:
Ms. Faye Langmaid, FCSLA, MCIP
Municipality of Clarington
FROM:
Will McCrae, P. Eng.
TSH
DATE:
November 22, 2007
RE:
Durham/York Residual Waste Study
Peer Review Comments
Introduction:
As per the request of the Municipality of Clarington, we have undertaken a peer review of Annex 'F',
Annex 'G' and areas of Annex 'H' where it impacted on considerations in Annex 'F' and Annex 'G'.
Our report looks at the approach and economics assigned to the development of a Thermal Treatment
Facility (TTF) at each site and the conclusions reached with respect to the assessment of the short-list
sites.
Discussion:
ANNEX F- "REPORT ON POTENTIAL TRAFFIC IMPACTS"
The report provides a basic assessment offuture traffic operations at the intersections in close proximity to
each site for a 2016 horizon year. In summary, the facility would generate low peak hour and daily traffic
volumes, and as such would have minimal impacts on adjacent roads or intersections from a traffic volume
perspective.
In general, the three Clarington sites were found to be preferred over the East Gwillimbury site, and
specifically, the two elarington sites in proximity to the Highway 40l/Courtice Road interchange were
preferred to the Clarington site in proximity to the Highway 40 IIBennett Road interchange. The key factor
that gave the latter site a disadvantage was the uncertainty with respect to maintaining direct access to
Highway 40 I (via South Service Road) ifthe Bennett Road interchange were to be replaced in the future by
an interchange at Lamb's Road.
1. The lane configuration shown in Figure 3-5 for the Highway 40 I eastbound off ramp intersection
with Courtice Road shows two eastbound through lanes on the approach to Courtice Road, but it
appears that there is only one receiving lane as the South Service Road is shown on the same figure
Memorandum to: Ms. Faye Langmaid, FCSLA, MCIP
Date: November 22, 2007
2.
to be a basic two lane road. There are in fact two receiving lanes on the South Service Road, one of
which terminates a few hundred metres from the intersection.
2. Further to the previous point, there is an inconsistency in the related analysis of this intersection. For
the existing and future a.m. peak hour analysis, the eastbound approach is analyzed as one
left/through lane and one through/right lane, which corresponds to the lanes depicted in Figure 3-5.
For the existing and future p.m. peak hour analysis, the same approach is analyzed as one left turn
lane and one through/right lane. With the very heavy volume of eastbound left turns that occur
during the p.m. peak hour, it is understood that the through/left lane could function as a "de facto"
left turn lane and this appears to be what was intended in the analysis. Depending on the actual
number of receiving lanes on South Service Road opposite the ramp approach, consideration may be
given to dcsignating the eastbound approach lanes as left and through/right as used in the analysis.
In telms of the concl usions drawn from the analysis, this inconsistency can be considered
inconsequential.
3. The impact of the future Highway 407 extension appears to bc limited to detrimental effects to site
Clarington 05. At this location, major interchange works will result in property requirements
effectively reducing the available area of the Clarington 05 site. The report does not fully reflect the
impact of the future Highway 407 with respect to this site. It has not been considered as a possible
haul route either.
4. The use of the South Service Road and Osbourne Road as truck routes to service the TTF on
Clarington 01 site is not acceptable in terms ofthe road uses envisaged in the Secondary Plan for the
Clarington Energy Business Park.
A route following Courtice Road with a southerly east/west access road north ofthe CP Rail corridor
is the arrangement envisaged by the Municipality. Osboume Road, for example, is promoted within
the Park Plan as a local street built to an urban standard, complete with sidewalks, landscaped
borders and treed boulevards, a street standard hardly conducive to heavy truck traffic.
5. In Section 4.1 of the report, it is indicated that a full build out of the Energy Park will influence
traffic patterns and traffic composition. How can the traffic impact of the TTF located in this area,
social and otherwise be fully appreciated without some knowledgc of traffic trends from the Park
development?
At the time of the preparation of the report, no applications for site plan approvals for the Energy
Park had been made. Given this and with no knowledge on timing of the park build up, a traffic
impact study in support ofthc TTF, prepared to support a site plan application in the near future, will
have to make assumptions on future park traffic.
6. In Section 7 "Haul Distances", it is indicated that haul distances have not been applied to the report
as a factor in determining social and cultural impacts. A conclusion is reached, however, which
shows a reduction of 40% in vehicle kilomctres for the Clarington 01 and 05 sites under the 150,000
tpy scenario which we understand to only include 20,000 tpy of waste from York Region. This
VII
Memorandum to: Ms. Faye Langmaid, FCSLA, MCIP
Date: November 22, 2007
3.
skews the analysis in favour of the Clarington sites. The advantages of the Clarington sites as
compared to the East Gwillimbury site diminish under the 250,000 tpy scenario.
It could be concluded that the Clarington sites only have a social/cultural advantage under the
150,000 tpy scenario and that under the 250,000 tpy scenario, there is no real advantage between the
Clarington sites and East Gwillimbury and in fact, the East Gwillimbury site could be considered
more favourably because access roads are already exposed to truck traffic carrying municipal waste.
7. Section 8 "Maximum Scenario (400,000 tonnes per year)" - In order to properly assess impacts on
each site under the maximum scenario, a traffic impact study should be promoted for each site or are
we to assume that the two paragraph discussion on the East Gwillimbury 0 I under this section
constitutes a study for this site? The fact that further studies are required for the Clarington sites
would seem to preclude making a meaningful comparative evaluation of the Clarington 0 1,05 sites
and East Gwillimbury 0 I site from a traffic view point.
In addition, it should be noted that the EA planning process allows for the proposed thennal facility
to receive waste from other non-GT A municipalities such as Peterborough. With regard to the
400,000 tpy scenario, it is our understanding that no agreement has been reached with Kawartha
Lakes, Peterborough or Northumberland regarding disposal of waste at the York/Durham facility.
No assumptions can be made with respect to potential volumes from these sites or their applicability
as potential sources for disposal of ash.
It is indicated in the report that the origin of additional waste beyond the 250,000 tpy scenario is
unknown (Page 8.1). Thus it is difficult to determine the preferred site located under this scenario
using haul distance criteria as pointed out by the proponent.
8. The "Significant Findings from the Traffic Study" section should bc revised on Page 10-2, in that
mitigative measures for the East Gwillimbury site should bc addressed.
Section 12 "Identification of Preliminary Site Advantages/Disadvantages"
In Table 12.1, it is indicated that there are critical movements affecting waste truck travel associated
with the East Gwillimbury site. An assessment of this situation should be addressed in detail
including the potential introduction of signalization, which has been promoted at the Clarington 05
and 0 I sites. The present use of this site for resource receiving should be highlighted in terms of its
potential to handle increased truck volumes.
It is difficult to relate this "disadvantage" for the East Gwillimbury site to the assessment on Page
10.2, which indicates that no improvements to this site are required to accommodate future truck
traffic. This is again emphasized in Table 4.2 of Step 7 ~ "Evaluation of Short-List Site", which
gives a disadvantage rating to East Gwillimbury from a traffic perspective.
9. Haul distances used to assess air quality impacts are detailed in Table 7.2. The following concerns
are noted:
IIH
Memorandum to: Ms. Faye Langmaid, FCSLA, MClP
Date: November 22, 2007
4.
. Criteria should be established for different haulage approaches, i.e. trailer or packer tnIck and
utilized consistently in each scenario. In Clarington 01,04 and 05 scenarios, haul distances of
10 !an are used for trailers whereas in East Gwillimbury, haul distances are included up to 60
!an for packer truck use.
. In the East Gwillimbury scenario, packer trucks are used to haul waste for Brock and Uxbridge.
It is not clear in the Clarington scenarios how this waste is being hauled or if it has been
accounted for.
. Haulage distances under "Other Eastern Municipalities" should not be included for the reason
outlined in Item No.7 above.
. For the East Gwillimbury scenario, the haul distance for packer trucks used to haul waste from
Aurora, East Gwillimbury, King, Newmarket and Whitchurch-Stouffville are included even
though these haul distances are common to all scenarios. For the Clarington scenarios, waste
from these locations would be hauled to the East Gwillimbury TS which is adjacent to the
proposed location of the East Gwillimbury TTF and then to Clarington by means of transfer
trailers.
. The location of a sitc for disposal of residual materials from the TIF, i.e. ash, has not becn
decided. Haulage distances associatcd with this disposal should be reflected in the comparison
ofvehicle-kilomctre costs for the different sites.
. Under the Clarington scenarios, is it practical to continue to operate three transfer stations
within a20 kilometre radius of the TTF, while in East Gwillimbury packer trucks are operating
in haul distances from 20 ~ 60 km?
Haul costs calculations were well documented in Annex 'G' Appendix' A. Similar detail
should be provided for haul distances summarized in Table 7.2. A more detailed and
representative assessment mayor may not alter the conclusions, but will remove any concerns
regarding bias and misinterpretation.
ANNEX G - "REPORT ON CAPn AL COSTS, OPERA nON AND
MAINTENANCE COSTS"
Section 2: Methodology of Study
In the "Study Approach and Key Assumptions", capital costs for water supply, sanitary sewer connection,
natural gas and electrical grid connections have been estimated on the basis of 250,000 tonnes per year.
Given that these facilities may be supplied to the site by installation within reconstructed roads, it would
seem prudent to service the site initially for the final capacity requirements of 400,000 tonnes. This is what
is proposed for stormwater management facilities. The implications ofupgrading services at a later date for
VH
Memorandum to: Ms. Faye Langmaid, FCSLA, MCIP
Date: November 22, 2007
5.
the 400,000 tonne facility have not been assessed due to uncertainty with respect to infrastructure at the time
of expansion.
It is important to note that the choice of actual treatment technology has a serious bearing on certain aspects
ofinfrastructure. This is highlighted by the sanitary sewer costs for the East Gwillimbury site as outlined in
Item No. I ofthe discussion which follows.
There are a number of areas where infrastructure costs need to be revisited in order that a proper evaluation
be given to allow advantage/disadvantage assessment to be attached.
I. There are options with respect to the type ofTTF which will eventually be used. In one type, there is
no need for sanitary sewer facilities. For an option which requires sanitary sewer facilities, there is a
severe cost disadvantage indicated for the East Gwillimbury 01 site. Table 3.4, "Cost of Sewer
Connections" indicates a sewer cost for the East Gwillimbury site of approximately $7,500,000.00.
2. Within the Clarington Energy Park, road reconstruction is required to an urban standard. The cost
estimates for road works on Clarington 05 and 01 sites should be increased accordingly. The costs
are currently estimated for rural standard construction. Standards should conform to the Clarington
Energy Business Park Secondary Plan.
3. The analysis revealed that from the traffic operations stand point, the four sites can generally
accommodate the future facility without improvements to the study area intersections. However,
there is a potential need for signalization of the south ramp terminal intersection of Highway 40 I and
Courtice Road beyond 2016.
4. Watcrmain costs for Clarington 01 site and Clarington 04 sitcs should be revisited. The same unit
price has been used for different size mains.
5. Do we need a 450 mm diameter sanitary sewer at each site? In some areas the proper allocation of
costs may well change the advantage/disadvantage designation for particular indicators. Apparently
the sewer size is based on the TTF vendors' recommendations for a worst case scenario.
It is important to emphasize that infrastructure costs with respect to the TTF are minor in comparison
to the overall cost. As such, it is misleading to emphasize advantages with respect to infrastructure
without giving a relative weighting between infrastructure and air quality, for example. We do not
feel that infrastructure servicing costs should rate highly in the final analysis. It should also be noted
that infrastructure servicing costs cannot be fully estimated unti I such times as a decision is made on
the actual treatment technology to be utilized.
As an example in Table 4.1, Page 4.1, the site specific-capital cost range for sites Clarington 05 and
01 should be increased to reflect an acceptable route built to standards reflected in the Municipality's
Secondary Plan. We would suggest because of this that the designation for Clarington 01 should be
altered from neutral to disadvantage, more in line with the other Clarington sites.
tIH
Memorandum to: Ms. Faye Langmaid, FCSLA, MCIP
Date: November 22, 2007
6.
6. With respect to the assessment for annual haul cost savings; cost differences are diminished by
increased waste haulage volumes. An advantage designation We feel would be a more appropriate
assessment for the East Gwillimbury 01 site, given the relative costs for the short-list sites and the
cost of this component in the larger cost of the overall project. We question why cost savings are
calculated in comparison to the status quo, rather than being calculatcd for each individual site based
on the haul distances and methods detailed in Table 7.2 of Annex 'F'.
7. Under the indicator "Distance from potentia] markets for salc of marketable materials (i.e. heat,
electricity, recovered metals, etc.)", there is considerablc advantagc (with detailed analysis) givcn to
the Clarington 05 and 01 sites. There is less analysis given for the East Gwillimbury 01 site for
direct comparison. (See Section 3.2.2 of Annex 'H')
8. Depending on the scale of operation, i.e. ] 50,000 tonnes or 250,000 tonnes, the initial potential for
heat uSe by adjoining facilities is small for both the Clarington and East Gwillimbury sites.
Accordingly, the cost savings are small compared to, say, a non-SeWer TTF option which would
reduce the East Gwillimbury site servicing costs to zero with reSpect to sanitary SeWer needs.
For comparison purposes, it should be noted that if a TTF option is chosen, which does not require
sanitary sewers, then the cost difference in servicing costs between Clarington 0] and East
Gwillimbury 0] is in the order of $7.5 - 8 million, even allowing for appropriate urban access
construction on the Clarington sitc and signalization in some form on the East Gwillimbury site.
We feel that the disadvantage assessment in Table4.], Page4.] given to East Gwillimbury 01 is not
sustained by the report discussion. The assessment of Cia ring ton 0] with a "Major Advantage" and
East Gwillimbury 0] with a "Disadvantage" based on a heat load indicator, Tablc 4.], Page 4.2,
Anncx 'G', is at odds with this assessment, given that electricity and rccovered metals are considered
equal for all Sh01i-list sites, as indicated in Section 3.2.4, Page 3-7.
9. Further to Item No.6 with respect to conclusions reached in Table 4.1, Page 4.], the neutral rating
for East Gwillimbury under "Distance from Waste Generation etc." Seems somewhat contrived given
the small differences in cost savings for annual haulage.
In addition, there should be a morc detailed breakdown on the recovered costs of marketable
materials. The disadvantage assesscd to the East Gwillimbury sitc appears to be for its alleged
limited market for hcat. This component of the asSessment effectively rules out the East
Gwillimbury site with an overall "neutral" rating.
] O. There should be some form of weighing of a "disadvantage" or "advantage" assessment. These
appear to be given equal weight in the final summary of the site considerations, i.e. cancelling each
other out.
11. We feel there should be a more detailed analysis of the potential "recoverable" costs than that
outlined on Page 3.7, given the importance attachcd to the conclusions in Tablc4.1. The assessment
in Section 3.2.4 should be expanded to reflect a balanced view.
IIH
Memorandum to: Ms. Faye Langmaid, FCSLA, MCIP
Date: November 22, 2007
7.
Conclusion:
It is our conclusion that the methods adopted for site comparison of Annexes 'G' and 'H' do not fully
address the economics and other factors related to each site. It would seem appropriate that a decision be
reached on the type of Thermal Treatment Facility that will be adopted and then proceed to quantify the
logistics of the respective sites. Each site could then be rated in a manner that would allow clearer
comparison and remove any elements of guess work or bias that may otherwise skew results.
As examples, please note the following:
. A traffic analysis should be undertaken for the East Gwillimbury site as is proposed for the Clarington 05
and 0 I sites. Mitigative measures for the East Gwillimbury site should be outlined.
. The matter of mitigation on a number of issues has not been properly handled in the analysis of the sites
and as such is not reflected in the final assessment of advantage/disadvantage under the various
indicators.
. It would seem that a decision on the type of TTF to be used should be made early in the process as to
establish the level of need for site works.
. The attributing of "advantage" and "disadvantage" to site potentials is too vague and there is no
weighting between the various indicators in the analysis.
. There arc too many areas in the analysis which are left for future analysis/study once the preferred site
selection process is complete.
. Ofthe questions that we have raised related to servicing and traffic impacts, twelve responses indicate
that further study and refinement is required once the site selection process is complete. Where such
questions pertain, for example, to capital costs from which an evaluation is derived, it is difficult to
respond to the "advantage"/"disadvantage" assessments based on incomplete data.
(tf4/~~
William McCrae, P.Eng.
Senior Project Engineer
WMc/ym
P :\Dept l2\ 12-29694\Corresp\22454.doc
Cc: Tony Cannella
VH
Attachment 9
To Report PSD-141-07
CI~ilJglOn
MEMO
TO: David Crome, Director of Planning
FROM: Laura Barta, Internal Auditor
DATE: 27 November 2007
RE: Review of EFW Study
Finance staff was asked to review the DurhamlYork Residual Waste Study,
Application of Short-List Evaluation Criteria from a cost analysis prospective. To
this end, the Economic and Financial Considerations: Annex G - Report on
Capital Costs, Operation and Maintenance Costs was reviewed in some detail.
Our review concentrated on reviewing the financial calculations included in a
selection of tables. We did our testing based on each new type of table, not on
testing every table. During the course of the review, the following discrepancies
were noted for Annex G:
CONCERNS:
1. Page 13 and 14 of Appendix A of the report contained calculations that
rounded the Total per Truck Minute cost to two decimal places. The
resulting value shown in both Table 3.3.1and Table 3.3.2 were not the same
number used in the calculation used to arrive at Total Cost per Tonne
Minute of Haul in the tables.
2. Page 15 of Appendix A of the report contained an error in the total for the
value of Annual Haul Cost. The total York number did not include the value
for Georgina Transfer Station of $174,396. This oversight will make the
overall total short by this value as well. The effect of missing this value will
cause an increase in the relative cost saving between scenarios. It was
pointed out that all schedules should be reviewed for this type of error. This
value was used an additional four times in our review of the subsequent
tables.
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO LIC 3A6 T(905)623-3379 F(905)623-0608
3. In an attempt to recreate the Annual Haul cost values shown in table 3.4.1
on page 15, we attempted to cross multiply the numbers and came up with
a difference of close to $300,000. We asked that all schedules be
restructured to reflect numbers that come closer to those you can multiply
out or that more decimals could be shown where necessary to increase the
accuracy of the calculation.
DIALOGUE:
Clarington's concerns were forwarded through the Region to be addressed by
Betsy Vaghese, E.I.T., GENIVAR Ontario Inc. To ensure the public is able to
follow the information in the tables, Clarington staff felt it was important for the
tables to accurately reflect the correct data. The following responses were
received:
1. Ms. Vaghese agreed with Clarington's comments and made the changes to
page 13 and 14 stating that both Table 3.3.1 and 3.3.2 contained a
typographical error. She assured us that the actual calculations were done
correctly.
2. The missing costs for York's Georgina Transfer Station were also adjusted on
the revised tables Ms. Vaghese forwarded. No revisions were provided for
tables that would have been subsequently affected by this change. An
example is Table 4.1.1 or 4.2.1 in the Appendix, summarizing the Haul Cost
Savings for each scenario.
3. Ms. Vaghese has recalculated the Annual Haul Cost Tables to address our
concerns related to rounding. These changes have been used to update
Tables 3.4.1 to 3.4.4 for both 150,000 tpy and 250,000 tpy as shown in
Appendix A. Again, no revisions were provided for tables that would have
been subsequently affected by this change
CONCLUSION:
A review of these tables will necessitate a change in section 3.2.2, Table 3.13
page 3-6 of the Annex itself. The East Gwillimbury site will need to be moved to
the top of the list with the overall system cost savings for Annual Haul Costs for
250,000 tpy Residual Waste. This rating could then have an effect on the overall
ranking of the site. The new shift the Short-List Site Ranking as Follows:
o East Gwillimbury 01 $3,731,775
o Clarington 01/05 $3,641,453
o Clarington 04 $3,525,767
The Values shown in Table 3.12 will also need to be changed although the
ranking will remain the same.
Section 4, Table 4.1 on page 4-1 will need to be re-evaluated. With the change in
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO LIC 3A6 T(905)623-3379 F(905)623-0608
ranking for East Gwillimbury, their neutral status should revisited.
As mentioned, the changes identified in our review do not appear to have been
applied through the balance of the study. We would recommend that this be
followed through. We also did not test the calculations on all tables throughout all
Annexes and would therefore also recommend that this be done.
Cc: Nancy Taylor, Director of Finance
Fred Horvath, Director of Operations
Tony Cannella, Director of Engineering
Dennis Hefferon
Faye Langmaid
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO LIC 3A6 T(90S)623-3379 F(90S)623-0608
MEMORANDUM
TO:
DurhamlYork Project Team
Attachment 10
To Report PSD-141-07
RE:
FINAL - Comments received from Clarington Peer Reviews on the Step 7 Preferred Site
Report
General Observation;
2
The "Annexes" generally reflect a more
comprehensive approach to data collection and
analysis than is reflected in the draft "Results of
Ste T' re ort.
Title Page:
DATE:
November 9, 2007
The following provides the final Consultant Team's responses to comments received from Peer Review consultants
retained by the Municipality ofClarington to review the document entitled "Draft Report ~ Thermal Treatment Facility
Site Selection Process - Results of Step 7: Evaluation of Short-list and Identification of the Consultants Recommended
Preferred Site, September 2001".
FROM:
DurhamlYork Consultant Team
Does Clarington need express written consent to
"use" this report?
3
Section 1, Introduction
Why does the report refer to gasification as specific
to System 2(b) on page 1-4 (1st para) when
gasification (and pyrolysis) is common to both
Systems 2(a) and 2(b) in the fifth and sixth bullets
on page 1-3, and in the RFQ materials? (There
seems to have been an evolution whereby
gasification and pyrolysis were treated as specific
to System 2b when the preferred Alternative "to"
was first announced, whereas they are common to
both systems now.)
The purpose of the Annexes is to provide the detailed
infonnation to support the information presented in the main
body of the report.
Clarington does not need express written consent to review and
provide comments on thi s report.
The note on the title page is provided to ensure that unrelated
third parties do not use the information in the documents for
purposes other than their intended use (e.g. attempts by a real-
estate agent to use the information on Archaeology provided in
Annex E in connection with a real-estate transaction in the
area.
Systems 2(a) and 2(b) are clearly described in the second and
third bullets on page 1-3 namely:
. System 2(a) - Thermal Treatment of Mixed Waste with
Recovery of Materials form the Ash/Char.
This system involves the thermal treatment (by combustion,
gasification or pyrolysis) of the post diversion waste to
produce electricity and heat. The resulting ash would be
processed to recover metals for recycling, with the
remaining ash disposed in a landfill.
. System 2(b) - Thermal Treatment of Solid Recovered Fuel
This system includes mechanical and possibly biological
processing (composting) of the post diversion waste to
recover recyclable materials and produce a solid recovered
fuel (SRF). The SRF is then thermally treated (by
combustion, asification or rol sis to roduce electrici
Jacques Whitford Ltd. . 3430 South Service Road.
Burlington ON. L7N 3T9
Tel: (905) 631-3929 . Fax: (905) 631-8960
Ji
FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
November 9, 2007
Page 2
4
The preferred site, at 12.4 ha, is smaller than the
13.7 ha specified on page 1-7 for a site with all
required infrastructure and buffering within its
boundaries, In Appendix E to Annex H ('1echnical
memorandum on Facility Site Size"), however, the
minimum site size is indicated as 7.3 ha plus
stormwater management (around 1 ha) - a total of
around 8.3 ha. In terrrs of the earlier Step 1-5
process this could mean that some small sites were
missed because prospective "willing sellers" were
told that the minimum size is 10-12 ha, This
appendix provides quite a lot of information on
configuring the facility within each site and
provides concept plans. This information could
have been more effectively applied in the actual
site evaluation and comparison. For example the 1
krn circle used for the land use and air quality
analyses is centred on the centre of the site and not
on the perimeter or the potential location of the
facility as set out in this Section. Also, this material
states the portion ofClarington Site 05 south of the
watercourse is "unusable" for the facility.
Presumably this portion ofthe land could have
been severed and disposed of separately, and yet
the cost of the entire acreage of the site is utilized
in the cost com arison.
and heat. The residues from the processing of the residual
waste and ash/char from the thermal treatment process
would be disposed in a landfill.
In both systems it specifically states that "thermal treatment"
includes combustion gasification and pyrolysis.
This description of the systems is consistent with the
information provided in the consideration of "Alternatives To".
The information presented in the RFQ is also consistent with
this description of the systems.
In the sentence in question namely:
".Many of the technologies that could be used to thermally treat
the solid recoveredfuel (e.g., gasification) in System 2(b) are
regarded as "nelv technologies", with active research and
development, but are less proven than the System 2(a)
technologies that are currently available to combust residual
waste. "
The term "gasification" is used as an example and in no way
implies that there has "been an evolution whereby gasification
and pyrolysis were treated as specific to System 2b when the
preferred Alternative "to" was first announced, whereas they are
common to both s stems now".
The Step 1-5 process to identifY willing sellers included a
Request for Expressions ofInterest (REOI) which identified a
conservative site size of 10-12 ha as being the ideal size for a
"stand alone" facility with all required features and
infrastructure accommodated on the site as well as allowing for
adequate on-site buffer zones and set backs.
The REOl went on to say that a basic facility could be
accommodated on 8-9 ha and further went on to say that if
proponents had a site smaller than described, but with potential
for sharing infrastructure, buffer zones, or other features with
neighbouring property, then those sites could also be submitted
for consideration. Accordingly, the intended purpose of
identifying a site size requirement (Le. sufficient capacity) was
conveyed.
During the short-list site evaluation process, in order to compare
the sites, we used a conceptual plan prepared by Ramboll
consultants to more accurately determine site size requirements.
We noted that Ramboll's plan indicates a size of about 9 ha to
accommodate all features with a moderate buffer zone from the
building perimeter of approximately 60 m. The calculations
based on the Rarnboll concept plan indicated firstly that the
building footprint requires 3.1 ha and secondly the minimum
required site area excluding the stonnwater management facility
and with no bufferin re uires 7.3 ha. The total of 8.3 ha, which
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6
Table 3.1, Evaluation Criteria:
7
The "considerations" included in the circulated
evaluation criteria for Step 7 have been replaced by
the "rationale" in the Ste 7 Re ort.
The "rationale" under "Compatibility with Existing
and/or Proposed Land Uses" mentions a need for
rezoning when the evaluations under this criterion
state that public uses are generally permitted in ail
zones (thongh I understand C1arington staff
consider rezonings to be required for this facility
on sites in that municipality). The land use profile
of the East Gwillimbury site in the Annex does not
discuss the Greenbelt Plan.
There is potential for double counting between the
"Compatibility" and "Residential Areas" criteria.
8
9
There appears to be a conflict in the rationale for
the Institutional Facilities criterion (proximity a
bad or a good thing?), though this appears not to be
an issue in the actual site com arison.
includes the stormwater management facility of 1.0 ha, but still
with no buffer zone, was then compared with the actual site size
to determine surplus area at each ofthe sites. This surplus area
was then used to assess advantages and disadvantages of each of
the sites relative to one another. For example, as a rough
calculation a site size of 13 ha would provide a buffer zone of
approximately 90 m from the building perimeter. Accordingly,
the larger site of 13 ha, providing a buffer of90 m, is
advantaged in this regard over the 9 ha site with a 60 m buffer.
Given the imprecise nature ofthe calculation of building size,
infrastructure requirements, buffer zone needs, etc, up until the
actual site and vendor are detennined we feel that the estimated
numbers we have used throughout the siting process are
consistent and will not have led to the exclusion of any sites
because of size.
The methodology chosen was to estimate the cost of purchasing
land offered by private sellers on the basis of the size of the
parcel offered. The possibility of severing unused portions and
selling it off at some future date was not considered as there is
significant uncertainty regarding the ease with which this could
be accomplished and the price that could be realized in such a
sale.
In response to this question from the reviewer, the implications
of selling off the unused portion of Site 5 are considered in a
cost sensitivi anal sis discussed below.
Further discussion with the reviewer is required to confinn what
is meant by "circulated evaluation criteria"
The EA documentation to be submitted to the Minister will
include a discussion of the Greenbelt Plan as part of the land use
profile.
As the evaluation approach was qualitative in nature the risk of
double counting generally does not apply. A qualitative process
allows for the evaluation to account for, discount and therefore
avoid double-counting. Where necessary, this consideration can
be documented and ex lained in the evaluation text.
We do not consider this aspect to represent a conflict but rather
the reality that an opportunity may exist for creation of a district
heating or distributed energy arrangement which could be
consistent with some munici al olides and the overall conce t
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10 The haul cost analysis is based on savings from the
existing costs of haul to Michigan. This is not a
valid "base line" because this option will no longer
be available Gust as the overall cost evaluation is
not done in relation to the cost of landfilling in
Michigan). The evaluation should be based on
actual costs.
II Acquisition costs for Clarington Site 1 and East
Gwillimbury Site 1 are rated at zero because they
are owned by Durham and Yark Regions,
respectively. This is inappropriate because there
would be an opportunity cost to the public purse of
"losing" either of these sites - they still have value
that should be reflected in the site comparison.
of sustainabili .
The haul cost analysis was based on the assumption that waste
would be hauled and disposed in remote landfills located in
southern Ontario.
The methodology chosen was to not include the opportunity
cost ofthe public sector sites.
In response to this question from the reviewer, the implications
of including an opportunity cost for the public sector sites are
considered in a cost sensitivity analysis discussed below.
Peer reviewers have raised several points with respect to the
estimated land acquisition costs included in the Total Site
Specific Capital Costs.
In particular, these points were:
. That a portion of the Clarington 05 site is not required for
facility development and that this 13.4 ha portion of the
property, could be sold off and thus reduce the lower cost
estimate for acquisition of the site from $3.4 million to $1.7
million.
. That an opportunity cost be assigned for the value of the
publicly owned Clarington 01 and East Gwillimbury 01
sites. For this higher cost estimate, the cost of the
Clarington 01 site is estimated at $1.8 million. Because
acquisition was not required, an estimate for the land price
at the East Gwillimbury 01 site was not developed. Tfthe
Clarington higher land price of $60,OOO/acre were assumed,
the East Gwillimbury site would have a value of$1.7
million.
With these changes in land prices the comparison of capital
costs are summarized in the attached Table 1.
In summary, even with taking into consideration, the points
regarding land prices raised by the peer reviewers, the overall
findin s with reset to the ca ital cost criterion do not chan e.
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12 Operational cost and capital cost "advantages" and
"disadvantages" are treated as equal when there is
no basis for comparing them. Suggest that these
costs be "present valued" so that they can be
compared together, or at least consistently.
13 Operation and maintenance costs include cost of
transportation of ash to a landfill, but the landfill
location is not known.
14 While complexity of required approvals and
agreements was in the TOR, there is a question as
to whether this represents an environmental effect
under the EA Act.
The Approved EA Terms of Reference does not specifY that
capital and operating costs be combined in "Present Value
Analysis" so this was not done.
The Approved EA Terms of Reference does not specifY that
capital and operating costs be combined in a "Present Value
Analysis" so this was not done.
In response to this question a present value analysis was done
utilizing the Site Specific Capital Costs from Annex G Tables
3.9 & 3.10 and the Overall System Operating Cost Savings
presented in Tables 3.12. The Haul Cost Savings analysis for
the 150,000 tpy facility was selected as this is the most likely
size for the facility given that the Dongara facility is currently
under construction in York Region. It is also noted that the
Overall System Cost Savings used in the analysis incorporate a
updated set of numbers as a minor error was identified in the
underlying calculations of Haul Cost Savings. This arithmetic
error did not have any effect on the overall findings presented in
Annex G.
The analysis was performed over a 20 year operating time frame
assuming constant 2007 price levels and using a real (Le.,
exclusive of inflation) discount rate of 4%. The results,
summarized in the Table below, confirm that the Clarington 0 I
is preferred to the other sites under both the "Lower" and
"Higher" Site Specific Capital Cost Assumptions.
Present Value of Lifecycle Costs and Savings ($ X 1,000)
(Savings +ve & Costs -ve)
CLOI
23,308
CL04
21,610
CL05
20,455
EGOl
22,750
Lower Site Spe<:ific
Ca ita! Costs
Higher Site
Spe<:ific Capital
Costs
The cost to dispose of ash is included in the estimated facility
operating costs presented in Table 3.11 of Annex G. Although
the specific site for disposing of these residues has not been
identified yet, a variety of options for disposing of these
residues do exist (e.g. licensed private sector landfill sites). The
estimated costs presented in Table 3.11 include a provision for
haul to one of these sites.
The consideration of legal aspects such as these are considered
to fall within the auspices of the broadly defined environment as
required by the Environmental Assessment Act. Through the
process to date including preparation of the EA ToR and
completion of the EA, the application of this criterion has not
been questioned by the public nor commenting agencies. It has,
however, been identified as a lower fiori com ared to other
19,774
14,163
15,760
15,471
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15 Net effects analysis description on page 3-6:
The draft Step 7 report states that the net effects
analysis was initially done based only on available
data, and yet it is clear from the annexes that the
work was more sophisticated than that (e.g. full site
surveys in the natural heritage report). The Step 7
Report should provide a more accurate description
of the rocess.
16 \Vhat mitigation measures were considered? Table
4,1 (page 4-12) suggests that there were none - so
why describe it as part of the process? The annexes
are also very weak on systematic consideration of
mitigation (e.g. net effects re: archaeology).ln other
areas this is probably at least partly a function of
the Jack of information on the preferred
vendor/technolo
17 Why is the description/definition of advantages and
disadvantages on page 3-6 different from the
descriptions in the Annexes (e.g. Table 2-1, page 2-
2 of Annex "A")?
18 Overall I believe the established approach in
identifying and rating environmental effects first
followed by application oftradeoffs and
interpretation of effects in terms of
advantages/disadvantages is clearer, more traceable
and more consistent with the EA Act than
combining all of this into a single operation.
19 In the Table 3-2 description:
For "Advantage", if impact is "manageable", does
that mean it is mitigable and that there would be no
net effect?
20 Table 4.2 shows "neutral" advantage/disadvantage
arising from a balance of
advantages/disadvantages, which cannot mean
there is no benefit or impact. Also, a cost range is
shown as "neutral" when this should strictly be
applied to zero cost.
21 For "disadvantage" and "major disadvantage", if
mitigation measures are required should this not be
used to derive a net effect before a ranking is
assigned, rather than using it to identify an effect?
22 Is ancilla infrastructure considered onl under
cate ories of the environment.
The modeling and calculations undertaken as part oflhe
analysis was predominantly based on secondary data sources.
Otherwise, limited field reconnaissance is referenced. These
field studies were not considered to be sophisticated compared
to studies that will be completed in the future to confirm the
advantages and disadvantages to the environment (as required
by the EAA) and environmental protection provided by the
preferred site (as required by other legislation such as the EPA
and OWRA ,
The consideration and application of mitigative measures where
applicable will be more clearly outlined in the EA
documentation to be submitted to the MOE.
We acknowledge that the description is different between the
main text and annexes. However, having reviewed both are of
the opinion that the intent of a relative site comparison is
achieved by both. The inconsistency will be rectified in the
final documentation of this ste
Please be advised that the approach we took did involve
identifYing and rating environmental effects first followed by
application oftradeoffs and interpretation of effects in terms of
advantages/disadvantages, In the draft EA document, to be
prepared, the text will be modified to provide a more
comprehensive description of the actual approach applied.
In the more comprehensive description to be provided in the
draft EA document, the meaning of what constitutes an
advantage and disadvantage will be more clearly described.
In the more comprehensive description to be provided in the
draft EA document, the trade-offs between tbe advantages and
disadvantages will be fully described, Where a "neutral" rating
has been applied, additional text will be supplied to describe the
actual trade-offs made.
The intent in this regard was to establish that those sites that
were more reliant on mitigative measures for a particular effect
under consideration exhibited, in relative terms, a disadvantage
compared to those sites not requiring mitigation. The net effect,
after mitigation, was also factored into the determination of
whether or not a relative advanta e or disadvanta e existed.
The nature of the available infrastructure is rovided as an
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( nlllllll..?nts ReeL'I\ cd j](111] Slc\ ell Ro\\ COil :\ I,UIl Repnll
~~w'~"4~~"!""'-~
"""",."..., Iii~__ ",.,_,
"major disadvantage"? Does the ancillary example in Table 3.2. The word "ancillary" is not used in the
infrastructure not form part of the undertaking? examples provided in Table 3.2. Perhaps further clarification of
this comment is reauired with resnect to the word "ancillarv".
23 In the Annex A page 2-2 description: In the more comprehensive description to be provided in the
draft EA document, the meaning of what constitutes an
What is "ability" Of "inability" to meet the advantage and disadvantage will be more clearly described.
evaluation criteria when the criteria include no
values, ranges or thresholds?
24 What is the difference between "ability" and In the more comprehensive description to be provided in the
"significant ability" / "inability"? Ifsomething is draft EA document, the meaning of what constitutes an
not significant, should it be considered? advantage and disadvantage will be more clearly described.
25 In the methodology description: We disagree with the impression that a weighting system was
applied. Priorities were applied in a qualitative sense. In the
Page 3-7, 3-8: Identification ofthe preferred site more comprehensive description to be provided in the draft EA
involves an implicit weighting system. While the document, the trade-offs between the advantages and
results of a public survey are provided, the disadvantages will be fully described.
priorities of the study team (other than
"professional judgement") and the application of
this svstem is not described.
26 Page 3-8 and Page 4-18: There is no demonstration In the more comprehensive description to be provided in the
that the levels of advantage/disadvantage identified draft EA document, the trade~offs between the advantages and
reflect equivalent increments or magnitudes of disadvantages will be fully described.
environmental effects for different criteria and
indicators, and yet they are treated as being the
same or interchangeable (see above re: capital and
operating costs). For example, for CIarington Site 1
a "disadvantage" for stack emissions/ meteorology
cancels out an "advantage" in terms of haulage
emissions (a positive impact??), to result in a
"neutral" overall finding. Impacts are additive and
should not be used to cancel each other out to give
the appearance of no impact. Net impacts should be
identified before tradeoffs are aoolied.
27 Page 3-8: How was best available technology Best available technology was considered as technology capable
considered? (page 3-8) of achieving, and in some cases exceeding, all regulatory
reauirements.
28 Page. 3-8: The proponents appear to be responding In the more comprehensive description to be provided in the
to the negative aspects of complex computer - draft EA document, the trade-offs between the advantages and
generated comparisons by reverting to an disadvantages will be fully described. In this description
essentially intuitive approach with very little in the additional relevant infonnation from the Annexes will be
way of traceability. \Vhile much of the work in the brought into the Main Report.
Annexes is quite comprehensive, there is often no
clear linkage to the tradeoffs in the comparison.
29 Page 3-11, second bullet, again, what mitigation The consideration and application of mitigative measures will
measures were considered in assigning potential be more clearly outlined in the EA documentation to be
effects? None are specifically identified in the submitted to the MOE.
reoort.
30 Page. 3-11, What was the process for obtaining Infonnation on facilities and associated contact infonnation was
infonnation from technolollv vendors? obtained from directories such as:
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31 Page. 3-12 - What is the undertaking as understood
at present? Is it a facility expanding from 150,000
to 250,000 to 400,000 tpa? - if so should say so.
32 Page 4-18 All other things being equal (which they
are not), combining a "neutral" and an "advantage"
to result in an "advantage" (for example) is a
misrepresentation of the data and would distort site
com arisons.
33 Table 4-1, Application oferiteria
Air quality
Based only on regional level data - still to be
verified based on local air uali monitorin.
34 Water quality:
The different environmental effects arising from a
location 600 m vs. 15 m from a watercourse should
be explained, along with their significance
considering mitigation.
35 Environmentally Sensitive Areas:
. 2005-2006 municipal waste combustion in the United
States, Yearbook and Directory; and,
. International Solid Waste Association (lSW A), Working
Group on Thermal Treatment of Waste, Energy from Waste
State ofthe Art Report, 5th Edition 2006
In addition, representatives of several key facility
owner/operators (potential vendors) were contacted by email to
request additional specific information that was not available in
the referenced directories.
The size of the proposed facility is explained in Section 3.4.1. In
summary, "the initial plan is to build a facility in the range of
150,000 tpy to 250,000 tpy to satisfy the immediate and short-
term need, but to seek EA approval for the larger 400,000 tpy
facility, should this expansion be required within the planning
period".
The nature of the undertaking, for which approval is being
sought, will be more clearly specified in the EA documentation
to be submitted to MOE.
Actual trade-offs were made during the evaluation process and
these will be better documented in support of the summary table
4.6.
Comment noted.
Temperature is a major concern in regard to fish and their
habitat, especially where the discharge is to a cold water stream.
Urbanization causes temperature increases in stormwater and
ponds can compound this increase since open water will tend to
acclimate with the ambient air temperature.
There are a number of reports which indicate that urban
development end-of-pipe stormwater facilities increase the
temperature of water before it is discharged to the receiving
waters (Beland, 1991, Galli 1990, Schueler 1992).
In cases where there is a lengthy outlet channel or ditches from
the stormwater facility to the receiving watercourse. The shady
channel or ditch will help minimize temperature increases of the
water discharged to the receiving watercourse. Therefore, the
lengthy convey channel or ditch is more beneficial than the
short distance travellen h.
The indicator utilized refers to the identification of potential for
these s ecies to be im acted b this ro osed develo ment.
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Why would species of conservation concern that
are highly unlikely to occur on the site - Bushy
Cinquefoil (occurs on lake beaches), Red-
shouldered Hawk (dense deciduous forest)
contribute to identification of environmental
im act?
36 If Annex "c" identifies an effect as "minimal".
why is this translated as a "disadvantage"?
37 Why do sites identified as having "minimal"
natural environment effects in Annex "C" (e.g.
Claringlon 04, East Gwillimbury 01) have different
advantage! disadvantage ratings?
38 What disadvantages do hazard lands pose if the
facility can be accommodated on the rest of the
site? Ifnot, shouldn't the site be rejected?
39 Land Use Compatibility:
Shouldn't the proponents know whether a ROPA
would be re uired for East Gwillimbu Site 01 ?
40 Why is a site area of 11,5 ha or 12.4 ha seen as an
advantage when 13.7 ha was the optimal size, now
a arentl reduced to 8.3 ha?
41 1 km distance and land use proximity is calculated
from the centre of the site, not the edge - potential
for inconsistencies depending on where the facility
is ultimately located within the site ~ especially
when the site size annex identifies a conceptual
location for each site.
42 Archaeological:
Advantages/disadvantages with mitigation should
be more clearly described in the Step 7 Report and
the Annex ~ land is designated for development,
effects are mitigable.
43 Economic I Financial and Technical:
There is evidence to suggest that these species are known to
exist in the area and therefore, may be potentially impacted by
this development. Again in a relative comparison of sites, a site
without this potential is advantaged over another with potential
impact.
In a relative comparison, a "minimal" impact is disadvantage
over a site where there is no potential impact identified.
There is no reference in Annex C to either Clarington 04 or East
Gwillimbury 01 as having "minimal natural environmental
effects". The wording minimal has been used specific to certain
features evaluated, however, has not been utilized as outlined in
the comment above. Each feature has been assessed on a
number of different indicators, some of which identified
minimal impact, however the overall evaluation and application
of advantages and disadvantages reflects all of the indicators
a lied not' ust a s ecific feature assessed.
The presence of hazard lands on-site present a relative
disadvantage to other sites without hazard lands regardless of
whether the remainder of the site can accommodate the facility.
The consideration of hazard lands is more than an land area
development consideration but also includes the potential need
for monitoring of impact to the area during construction and
o eration.
At the time of the preparation of this report, the Region of York
was not willing to comment or provide clarification as to
whether a ROPA would be required on the East Gwillimbury
Site 01.
Please see the response above under comment # 4.
Given that this is a relative comparison, the application of a
lkm radius from the centre of the site has been applied
consistently around each site and therefore the relative
comparison holds true. The potential configuration of the
facility on the site, has little impact to the application of this
particular criterion given the size of the facility itself and the
distance within which potential impacts were identified.
The Report and Annex will be reviewed and the description
enhanced where necessary. The mitigative measure applied will
be determined based on the results of the Stage 2
Archaeological Assessment which will be completed on the
preferred site. The landuse designation does not have any
impact on the potential for mitigation. It will be the ultimate
determination of archaeological resources that will dictate the
otential for miti ation.
The available facts re ardin otential heat loads are resented
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Heat load sales and usage are dealt with quite well
in the Annexes but are still uncertain, cannot be
known at this time - how to account for uncertainty
in assigning advantages I disadvantages? Also
uncertainty re: air quality, ash haul
in the documentation and the associated uncertainty is
identified. A potential revenue stream from the sale of heat has
not been included. If it were included, the operating cost
advantage identified for the Clarington Oland 05 sites would be
enhanced.
The cost to dispose of ash is included in the estimated facility
operating costs presented in Table 3.11 of Annex G. Although
the specific site for disposing of these residues has not been
identified yet, a variety of options for disposing of these
residues do exist (e.g. licensed private sector landfill sites). The
estimated costs presented in Table 3.11 include a provision for
haul to one of these sites.
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((11l1ll1enh RC(Cl\ed 11\'111 Sr:1\LS t)1l \1a11l Repult
44 Page 1-5 of the main report - The initial screening This observation reflects the fact that site selection
process ensured that unsuitable areas, such as significant processes narrowing the area of consideration from a
natural features, agricultural lands and existing regional to site specific level of detail rely on data that
residential areas would not be considered further in the initially can be efficiently applied at a regional scale
siting process. Later in page 1-10, the report says that (recognizing that some site specific anomalies may not
One (1) site is located near Natural Heritage Features be specifically represented) followed by the
including; Areas of Natural and Scientific Interest consideration of more detailed site specific data as the
(ANSI), Environmentally Sensitive Areas (ESA), area of consideration is narrowed. At each level of
Wetlands, community parks and residential areas and consideration, previously applied considerations are
was therefore removed from further consideration. This reviewed for the remaining areas based on the more
undermines the effectiveness of the initial screening detailed data and adj ustments made as required. This is
process in removing sensitive sites. The process is not an established and accepted practice in site selection
explained adequately in the Step 7 and Step 1-5 Reports. that recognizes the level of detail that may be afforded
The question is "Could it be possible that potentially to and obtained from various data sources.
suitable sites have been excluded through such a
I oualitative initial screenine: Dfocess?"
45 With respect to separation of siting and competitive With respect to facility siting, the requirements,
process, the report on Step 1-5 says: properties, effects and impacts of all thermal treatment
technologies (i.e. combustion, pyrolysis and
"Completing these processes as part of the same gasification) are all similar.
competitive process could represent an unfair advantage Therefore, the site can be selected prior to choosing a
to those vendors offering both a site and technology specific technology and vendor.
versus only those vendors providing a technology and
thereby jeopardize the success of the competitive This fact was also recognized by MOE when they
process. By "uncoupling" the RFQ and Request for established Regulation 101107. The premise for this
Proposals (RFP) process from the siting process, it "Environmental Screening Process" is that modem
allowed for a more "fair" process to those involved and EFW facilities are expected to have minimal
also allowed for the completion of siting activities in environmental effects and, therefore, such facilities can
advance of a formal RFQ/RFP process for be safely located on sites selected by proponents
technology(ies)." outside of the historic EA process.
We do not see any significant benefit in the completion One of the benefits of selecting a site in advance of the
of siting activities in advance of a formal RFQIRFP RFP process is that firmer prices, and sounder
process for technology(ies). Conducting the siting technical proposals will be obtained if these proposals
process in the absence oftechnology-specific are based on developing a facility on a specific site
information, particularly the information regarding the selected by the Region.
conditions of Certificates of Approval for emission
control levels, HHRA and other technical studies,
introduce a large uncertainty in the comparative site
analysis. Would a fair competitive process, which is an
administrative issue and should be dealt with
appropriately in a separate process, justity the
shortcomings of the analysis due to lack of technology-
soecific information?
46 Further, in our understanding, the separation of With respect to facility siting, the requirements,
technology selection and site selection processes will properties, effects and impacts of all thermal treatment
mean that the site will selected based on generic criteria technologies (i.e. combustion, pyrolysis and
and impact assessment. The site specific information will gasification) are all similar.
be used only to confirm whether the selected site Therefore, the site can be selected orior to choosinl! a
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( llllllllcnts RCCCI\cd fl~1Il1 Sf '\Jr S on \ 1<1111 RCplllT
continues to meet the criteria. However, all sites will not specific technology and vendor.
be compared at this stage to select the best site and in OUf
opinion; this site selection process does not necessarily This fact was also recognized by MOE when they
choose the best site. established Regulation 101/07. The premise for this
"Environmental Screening Process" is that modem
EFW facilities are expected to have minimal
environmental effects and, therefore, such facilities can
be safely located on sites selected by proponents
outside of the historic EA process.
One of the benefits of selecting a site in advance of the
RFP process is that firmer prices, and sounder
technical proposals will be obtained if these proposals
are based on developing a facility on a specific site
selected bv the Re~ion.
47 The report for Steps 1-5 indicates that the areas from The referenced description will be adopted in future
initial screening process consist of primarily industrial documentation to reflect the fact that some areas may
and commercial land uses, located away from city abut some sub-urban communities as set-backs were
centres and suburban communities. This statement is not not applied to constraints at Step 2. It is noted however
accurate as some of the short-listed sites could be that this observation is consistent with the intent of the
considered as close to suburban communities. Step 2 area delineation exercise.
48 The capital cost allocation for infrastructure is associated The cost information presented is consistent with the
with a large uncertainty as it is evident from the Low- criteria and indicators set out in the EA Terms of
Cost and High-Cost estimates in the cost report. In Reference and accompanying Background Documents.
addition, the cost of water connection may be Table 2-3, Step 6 - Evaluation of Short List and
overestimated (water requirements and the pipe size) Identification of Preferred Durham/York Site, of the
while the cost of 44 kV transmission line might be EA Terms of Reference supporting Background
underestimated. All these add to the large uncertainty Document 2-3, Consideration of Alternative Methods
associated with the estimated cost at this level. The base ofImplementing the Understanding identified the
capital cost estimate for the plant was reported in the "indicator" for the capital cost criterion as follows:
order of$200,000,000. At the planning level, in the most "Site development costs, including: infrastructure
optimistic scenario, this cost has at least 30% required, upgrades to existing infrastructure (roads,
contingency, which translates to $200 Mil'" $60 Mil. sewers, etc.) property acquisition and possible site
The difference in capital infrastructure cost estimates for remediations. "
various sites have no statistical significance with respect To do what the reviewer suggests - "Infrastructure
to overall capital costs and therefore infrastructure costs costs should not be used as a criterion for selection at
should not be used as criterion for site selection at this this stage" would not be consistent with the approved
sta~e. Terms of Reference.
49 Use of word "advantage" creates a lot of confusion in Actual trade-offs were made during the evaluation
comparative study. While the intention is to compare the process and these will be better documented in the
advantage of one site or process or procedure, over various discussions and tables.
another, it may tend to imply the improvement in an
absolute sense. The use of "Advantage" for Site We disagree with your opinion on the use of the
Clarington 01 under the heading "Public Health and quantitative methodology. During the preparation of
Natural Environment" may imply that the construction the EA Terms of Reference, the public was consulted
of the incinerator improves the environmental quality and ultimately a qualitative methodology was
surrounding that site vis-a.-vis Clarington 04, which specified. The rationale for this decision was that
maybe Neutral!!!!! In our opinion, the sites should have qualitative methodologies are more easily understood
been ranked using numerical weie:htim! factors rather by the general Dub!ic and have been successfullv used
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(nmmcllt<;;, RCCl:I\cd 110m Sf "'t S nn \1,1111 Repoll
than qualitative comparison criterions and these in a number of complex, comprehensive individual
weighting factors should have been established early on Environmental Assessments (EA's). The use of
through public opinion polls and information sessions. quantitative methodologies in complex, comprehensive
EA's has not been as successful.
50 The major criteria considered for Evaluation of Short- The criteria and indicators for these five categories of
Listed of Sites were: criteria were all developed as part of the approved EA
Terms of Reference.
Public Health and Safety and Natural Environment
Considerations Details on these specified criteria and indicators
Social and Cultural Considerations together with the rationale for these indicators are
EconomiclFinancial Considerations provided in Table 2-3, Step 6 - Evaluation of Short-
Technical Considerations List and Identification of Preferred DurhamNork Site,
Legal Considerations of the EA Terms of Reference supporting Background
Document 2-3, Consideration of Alternative Methods
The last three criteria (3, 4, and 5) are closely related to of Implementing the Understanding.
each other. For example, larger distance to source of
service water with major road crossing would lower the As the evaluation approach was qualitative in nature
rating of site in all these three categories and this ends up the risk of double counting generally does not apply.
triple-counting the same issue. (Compatibility with A qualitative process allows for the evaluation to
Existing Infrastructure; Design/Operational Flexibility; account for, discount and therefore avoid double-
and Legal Considerations) in the overall process and counting. Where necessary, this consideration can be
thereby diluting the importance of Public Health and documented and explained in the evaluation text.
Safety; and Natural Environmental Considerations.
Further, in our opinion, the selected criteria are not
appropriate for evaluation of sites. Firstly, Public health
and safety and Natural environment are two different
issues and need varying weightages. Further, issues
relating to traffic, noise, air quality, odoU!, public
nuisance etc. would be of much greater importance in the
eyes of the community relative to technical
considerations or economic issues. Also, cost and legal
considerations have no role to play in selecting a site
because public does not care for either "the legal
permitting issues are more or less" or "something costs
more or less".
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51 Meteorological Data
The study uses two meteorological stations for wind
speed and direction (Port Cobourg and Butlonville).
Have these two stations be checked to confirm that
they are appropriately sited either by the project team
or through consultation with MOE?
52 How will the meteorological data collected at each
site be compared against the existing meteorological
stations?
Will this be done on long-term data for the other two
stations, or will this be done by comparing data for
the same time period?
53 The Port Cobourg station shows very distinct east-
west wind trends? Has a sensitivity assessment been
done to determine if the predicted maximum impact
areas change as a result ofthis trend?
54 There are other meteorological stations in the area
that are maintained by Darlington Nuclear Station,
Pickerin Nuclear Station and the Port Ho e Low
The Buttonville airport site has been previously reviewed
by Jacques Whitford and the wind rose from this station
was also compared to Pearson Airport, which showed
similar trends. The Port Cobourg meteorological tower
siting was not specifically reviewed, however, the wind
rose from this site was compared to Toronto Island Airport
and the stations show similar trends (Le. more prominent
westerly and easterly winds relative to northerly). The
wind roses from both of these sites were obtained from the
National Climactic Data Centre and the data has been
QA'ed by this organization.
The purpose of displaying these wind roses was to
examine ifthere were discemable differences in the winds
in the region of the Clarington area versus the East
Gwillimbury area. Buttonville and Cobourg wind data
will not be used in the dispersion modelling assessment of
the preferred site.
The data collected on each site will be compared on both a
short-term basis (the same time period as the on-site
measurements) and on a long-term basis to the existing
meteorological stations. The long-term data (on both an
annual and seasonal/monthly basis) from the existing
stations will be compared to the site-specific data to
examine how closely the measured data matches long term
trends. Other available meteorological data will also be
included in the analysis.
The data from the Port Cobourg and Buttonville stations
were only used to qualitatively assess if there were
discemable differences in the winds in the Clarington area
versus the East Gwillimbury area.
The air quality/HHRA screening assessment that was
previously conducted placed the receptors used in the
exposure assessment at the location of the maximum
ground level concentration (regardless of direction), and
thus consenratively ignored wind directionality. The site
specific air quality assessment that will be conducted on
the final site will utilize meteorological data collected at
the site, and the directionality of the winds at the site with
respect to maximum impact areas will be assessed.
A multi-level meteorological tower is currently collecting
data in the immediate vicinity ofthe Clarington 01-05 sites
to su art a otential wind farm stud ,and due to its
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Level Waste Office. Have these been obtained to
determine ifthey are more appropriate than the
Buttonville and Port Cobourg Stations?
55 Background Air Quality
Is there a rationale or guidance for selecting the 90th
percentile as the maximum background level for the
criteria (NOx, PM, S02, CO) contaminants?
56 What monitoring for other parameters is proposed for
the fmal site?
How will backgrounds be established for all other
parameters in the risk assessment and air quality
assessment?
57 Page 4-2. "..results of the site specific monitoring
will be available prior to the final site selection of the
preferred site". This has not happened due to timing.
What evaluation will be done of the data and what
changes in final site selection might occur as a result
ofthe data collection?
58 How will the background data collected at each site
be compared against the existing air quality stations?
Will this be done on long-term data for the other
stations, or will this be done by comparing data for
the same time period?
59 The NPRI summaries provided deal only with criteria
pollutants. Has an background assessment of other
pollutants been undertaken (e.g. heavy metals,
dioxins and furans)?
location, is expected to be the most representative data for
the site. Durham-York is currently contacting the
proponent to acquire data from this tower. Data for the
stations listed above may also be collected for use in the
detailed air quality assessment of the preferred site.
The MOE typically requires that 90 percentile ambient
monitoring data be added to dispersion model predictions
to conservatively account for existing ambient
concentrations when assessing the impact of a project plus
background. The 90th percentile was therefore considered
an appropriate level on which to judge the existing air
quality of each region, as this is the level that would be
used in the site specific assessment.
Background monitoring for dioxins (once per month),
PAHs (once every 12-days) and metals (every six-days)
will be conducted in addition to the continuous monitoring
for criteria air contaminants.
At this stage, the Clarington O! site bas been put forward
as the consultant's recommended site, but has not yet been
accepted by DurhamlY ork. The data from the monitoring
sites will be analysed on an ongoing basis and interim
updates provided to Durham/York. If the monitoring data
suggests that the assessment presented in the report is not
representative of actual conditions, the report and
conclusions would be revised.
We would expect to compare the data collected at each site
to the long-term data at the existing monitoring stations
(on both an annual and a montbly/seasonal basis).!f
ambient data for the same time period from the existing
stations is available from the MaE at the time of the
assessment, direct (same time period) comparisons of the
site data to the existing stations will also be conducted.
Other contaminants were not assessed for the Potential Air
Quality Impacts report, as the focus of the NPRI review
was to supplement the available ambient monitoring data,
which were for criteria pollutants only. Other pollutants
will be assessed in greater detail during the site-specific air
quality study.
60 Page 3-1. Houses, parks, utilities, commercial and
industrial facilities are specifically mentioned. Have
schools, daycares and other "sensitive uses" as
defined in the MOE Dl-D6 Guidelines also been
considered?
All surrounding land uses considered potentially sensitive
to a thermal treatment facility were considered,
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61
The air quality assessment done for the HHERA
indicated that the maximum impact zones were on
the order of 200 to 300 m from the site. As such,
impacts would be greater at that distance than
impacts at 1 kIn (chosen impact zone for assessment).
Has a sensitivity analysis been done to see if site
rankings would change if a 200 or 300 m impact zone
was used?
The Peer Reviewer is directed to the Air Quality
Assessment conducted as part of the Generic HHERA
where the Maximum Ground Level Concentrations ranged
from 300m to less than 800m from the theoretical facility.
As such, in order to maintain a level of conservatism in
our evaluation a 1 km radius was identified to
accommodate this range. A sensitivity analysis has not
been completed, however, based on the way the criteria
were applied we do not believe that the site rankings
would change with the use of a smaller radius.
62
In previous documents the site selection criterion
"capital costs, operation and maintenance costs"
indicated that additional site specific mitigation
requirements might be required for some sites. Why
has this not been addressed in the current report?
63 There is also a statement in the "Generic Human
Health and Ecological Risk Assessment" that if the
site specific risk assessment shows unacceptable risks
that further emission reductions ("enhance the
performance of the technology") could be undertaken
to reduce the risk. This suggests that different sites
might require different air pollution control systems
with associated different financial considerations.
The site specific HHERA has not yet been
undertaken, nor, as noted above, have the background
assessments for criteria pollutants (NOx, S02,
particulate) been completed. In addition, the
background assessments for the key parameters of
concern in the HHERA (e.g. dioxins and furans) have
not been started.
When will these issues be assessed?
Table 2-3, Step 6 - Evaluation of Short List and
Identification of Preferred Durham/York Site, of the EA
Terms of Reference supporting Background Document 2-
3, Consideration of Alternative Methods of Implementing
the Understanding identified "Mitigation Requirements
and Monitoring Requirements" as potential indicators for
the operation and maintenance cost criteria within the
economic/financial category.
These indicators were considered and addressed in Section
3.2.3 Mitigation and Monitoring Requirements (page 3-7)
of Annex G Report on Capital, Operation and
Maintenance Costs.
In summary, no unique site-specific mitigation or
monitoring requirements were identified and therefore no
site-specific costs were included in this indicator.
This finding is also summarized in Table 4.1 (page 4-1) of
Annex G.
The site specific HHERA will be completed for the
preferred site and preferred vendor technology once
selected. This will be completed in support of EAA and
other site specific environmental approvals.
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How will this be undertaken and how will decisions
be made given the timing ofthose assessments
(background and site specific HHERA)?
How will this be linked to the vendor RFP and
selection rocess?
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64
General Comment:
65
The overall site selection process fails to include
the cumulative effects assessment (effects from
neighbouring facilities) while assessing the short-
listed sites. For example the implications of
construction of thermal treatment facility at
Clarington 1 close to Darlington NGS and St. Mary
cement on the future development of energy park
and other land-use categories has not been
addressed ade uatelv.
Annex B: Sections 2.5 and 3.1
66
The conceptual design of the SWM facilities must
include the regional storm in addition to the 2, 5,
20,25,50 and 100 years storm. What was the
len h of modeled storm?
Was the CN kept the same for post-development
conditions? If so, why?
67
100-yr and regional flood plain mapping under
existing and proposed should be outlined in the
report.
68
A description of topography and existing drainage
should be documented.
Why are the drainage areas under post development
conditions less than those under pre-development
conditions?
69
70
In Table 3.1: Explain calculations for permanent
pool and extended detention volumes. Le., specify
requirement guidelines for % imperviousness used.
71
The quality control criteria for Clarington 04 must
be revised to enhanced level 80% suspended solids
removal especially there is a potential for airborne
contaminants that are deposited into the top 10cm
of the surficial soil (as outlined in Table 4-2) which
could be dischar ed to the SWM facili . In
Consideration of cumulative effects related to air quality
will be undertaken as part of the site specific air quality
impact assessment in support of EA and EP A approval.
The length of the modeled stonn was the SCS 24 hour
Type 11 storm with a time step (DT) of 5 minutes. The
Hurricane Hazel storm event will be added at the site
specific stage.
For the post-developed area, we calculated an impervious
site area of 45% and the DESIGN ST ANDHYD was used
for the developed area. For the remaining undeveloped
area, the post-development conditions are still to be the
same as the pre-development conditions and therefore, the
CN value of74 stays the same and the DESIGN
STANDHYD was used
We did not obtain any flood plain mapping because the
process is extensive and lengthy. Floodplain mappings for
the tributary of watercourses may not be available from the
Conservation Authorities. This will be investigated at the
site s ecific 513 e.
All topography and drainage patterns are illustrated on the
ma in rovided in Annex B, A endix D.
The 10 hectare post development drainage area is the area
contributing to the stormwater pond. The remaining area is
considered as pre-development conditions and was coded
as such in the SWMHYMO model, to compute the total
flows discharged to the watercourse. The total site area
under post-development conditions is still the same as
under re-develo ment conditions.
The calculation uses standard figures from the Ministry of
Environment Stormwater Management Planning and
Design Manual (Table 3.2), March 2003. We do have
backup calculations that could be added (attached in an
a endix if re uired.
This would be up to the Conservation Authority (CA). The
Central Lake Ontario CA and Lake Simcoe CA has set the
protection levels within the watershed as "Enhanced
Level" for all Short-Listed sites except for the Clarington
04 site which is set as "Normal Level". Based on the
watershed stud of Bennet Lake, the Central Lake Ontario
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72
addition, MOE design manual did not allow 70%
for warm water fishery. You may wish to elaborate
on why fish habitat in Bennet Creek is not as
sensitive to sediment and siltation.
Table 3.3: "Quality Control Criteria". Clarington
04 was previously mentioned as having "Nannal"
level removal, while Clarington 05 had "Enhanced"
levels. This has been reversed here. Please ex lain.
There is no mention of how outflows from the
SWM pond will be conveyed to the water courses
Le., thrall channels, culverts, existin ditches
Section 3.3
73
74
75
Include PTTW under Approval requirements (this
is for dewaterin u ase.
Section 6
Table 6.1: This indicates the relative distance from
the SWM pond to watercourses as an indicator but
provides no explanation as to the environmental
effect of a shorter distance. Please elaborate.
CA indicated the level of protection as a "Normal"
requirement.
This is a typo. Clarington 04 has "Normal" level removal
and Clarington 05 has "Enhanced" levels.
This will be shown at the detailed design stage of the
preferred site.
Comment noted. Section 3.3 will be revised.
Temperature is a major concern in regard to fish and their
habitat, especially where the discharge is to a cold water
stream. Urbanization causes temperature increases in
stormwater and ponds can compound this increase since
open water will tend to acclimate with the ambient air
temperature.
There are a number of reports which indicate that urban
development end-of-pipe stormwater facilities increase the
temperature of water before it is discharged to the
receiving waters (Beland, 1991, Galli 1990, Schueler
1992).
In cases where there is a lengthy outlet channel or ditches
from the stonnwater facility to the receiving watercourse.
The shady channel or ditch will help minimize temperature
increases of the water discharged to the receiving
watercourse. Therefore, the lengthy convey channel or
ditch is more beneficial than the short distance travel
len h.
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76
Page 1-2. The EA Terms of Reference (ToR). Why
not have some descriptions of the EA Terms of
Reference that are applicable to this report only. The
purpose of these descriptions would be to supplement
information on the decision-making process of the
indicators and rationales presented in Table 1.2 at
page 1-10, as well as Table 2.1 at page 2-2, and
throughout the report. The following questions may
hel the re ort authors to clear! see this oint.
Page 1-10. Table 1.2. Why was the Central Lake
Ontario Conservation Authority (CLOCA) list of
sensitive species (taxa would be a better word)
ignored in the evaluation for the sites? Floral and
faunal sensitive species on the CLOCA list, usually
taxa at a local and regional level, have as much
weight in EAs as those found in the Federal and
Provincial lists. Also, why is the Committee on the
Status of Endangered Wildlife in Canada
(COSEWIC) not mentioned at this time?
77
78
Page 1-10. Table 1.2. 1st column: "Aquatic and
Terrestrial Ecology Impacts". Why is the table
failing to present aquatic indicators along with an
aquatic rationale in the following two columns? Are
the sites not relevant to an aquatic evaluation?
Nothing is said. Was any effort directed at
considering amphibians and reptiles, as well as
mammals (other than white-tailed deer)? Was the
word "wildlife" defined in the re ort?
Page 2-1. Field Work. Field work dates are July 18,
19 and 20. Why field work in that time period? Was
there a particular relevance to have biological
fieldwork performed in that time period for this
project?
79
80
Furthermore, it is said "evaluation of aquatic
habitats... "; "an inventory of aquatic habitats".
These words provide little understanding of the work
that was done. Was electrofishing performed to
know whether fish are present (so that fish habitat are
present on sites) or not (no fish habitat)? This is most
important and has direct implications on this EA.
81
Furthermore, under this section, it is said that the
tasks erformed in the field included "calculation of
Comment addressed in responses below.
Comment noted. We are not aware ofa list of regionally
significant species compiled by Central Lake Ontario
Conservation Authority (CLOCA), and therefore it could
not be used in the evaluation process. Species of
conservation concern ranked as 53, S2 or S 1 or those
ranked by COSEWIC or MNR as Special Concern (SC),
Threatened (THR), Endangered (END) or Endangered-
Regulated (END-R) that are known to occur on-site were
considered under the environmentally sensitive areas and
species impacts criteria.
In the final documentation the indicators for the criterion
'Aquatic and Terrestrial Impacts' will be corrected to
include the aquatic characteristics actually considered in
the evaluation. Section 2.2 and Table 4.1 clearly
demonstrate that aquatic indicators were considered
along with the types of considerations.
The word wildlife was not defined in the report.
Comment noted. Field work is typically conducted
between mid-March and November, and the scheduling
of this project happened to fall during the summer
months. This time period is appropriate, as most plants
are in flower, and birds and wildlife are typically active.
Although this level of effort was deemed appropriate for
the present exercise, more detailed fieldwork will be
undertaken for the preferred alternative to fully
characterise the environment to be otentiall affected.
Comment noted. The sites were surveyed and any
potential fish habitat was noted for each site. No
electrofishing was performed at the sites, and the
presense of fish species has yet to be determined. These
watercourses or lagoons were flagged during the field
survey as providing potential fish habitat. More detailed
fieldwork will be undertaken for the preferred alternative
to fully characterise the environment to be potentially
affected
All distances and lengths of hedgerow were measured
usin eos atial data and GIS a lications.
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82
the distance from the site or haul route to the areas
designated as Natural Heritage Features and Areas",
Was this measured with a tape?; a car odometer?; or
with GIS at the office and not in the field? What was
measured more exactly in the field? What could be
measured in the field? It is said "evaluation of the
amount of woodlands, and hedgerows". H ow was
this evaluated exactly? From the above questions,
what was done in the field? Is the next paragraph,
"This included..." does it provide any relevant
infonnation on the above uestions?
Page 2-1. Last line. "where possible, a handheld
GPS unit was used", Were there locations with a
dense forest canopy at the sites where it was not
ossible to receive a GPS si oal?
Page 2-2. "Potential net effects to the environment
were identified based on the application of the
comparative evaluation criteria identified in the
approved EA Terms of Reference, to identifY the
compatibility of existing land uses... with the
proposed undertaking and potential effects on the
environment. As a stand alone text, how can I
understand and decide on the quality and credibility
of the work if something as important as that is
elsewhere than in the text where it should be? Are
comments above for page 1-10 applicable here? Yes.
What was approved exactly in the EA ToR? Could
the text help the reader to understand what the report
is intended to rovide?
Page 2-3. Table 2.2. Sbould the words "significant
ability", "ability", "inability" and "significant
inability" kept for other uses, and be replace by a less
anthropomorphic term such as "characters" or
"traits", even "parameters"? A site does not have
abili , eo Ie have abilities.
Page 3-1. Para 2 and 3. What is the status on aquatic
aspects? Nothing is said. A ditch is mentioned later
on the next a es.
Page 3-1. Table 3.1. Rare species. Is this table well
applied to the EA? Such table is assembled before
fieldwork to learn what may be found in the general
area, and later verified in the field whether the rare
species are present or not on site. Ifpresent on site,
there is a concern? Yes. Would this information be
better placed in an appendix to note that the rare
species in questions were noted for the general area,
but not found at the site? Why would the rare species
not found at the site be relevant in the evaluation of
the site?
In addition, last si htin dates for the rare s ecies are
83
84
85
86
87
There were no areas on-site with dense forest cover.
The following paragraph in the report and Table 2.1
specifically describe the criteria and indicators used in
the subject assessment. The final documentation will be
edited to include a reference that these are from the
approved EA Terms of Reference.
This adjustment will be considered during preparation of
the final documentation. It will not, however, change the
relative outcomes ofthe assessment.
Comment noted. No watercourses were found on-site,
only a small culvert and dry ditch was found running
south from the access road constructed on the site.
The text and tables presented in Section 3 are intended to
document the study results for each site and the rationale
(induding process logic) for arriving at the relative site
advantages and disadvantages described in Section 4. It
is our professional opinion that the information presented
in Table 3.1 is a requirement ofthe study and that the
supporting text is clear on the role of this information.
Whether or not it is presented in the main text or an
appendix is a matter of style.
Comment noted. An s ecies of conservation concern
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Page 22
provided on MNR NHIC website and should be
provided in Table 3.1, How often are these dates
within the last 25 years? Is it reasonable to mention
Bushy Cinquefoil ifit was observed in 1914? Was
there any discussion with MNR biologist regarding
the above, as well as the "hidden" information for the
next species written as "Sensitive Species". MNR
biologist will tell you if this "sensitive species" is
relevant today, or not. According to the above, was
this section as presented and used in the evaluation
relevant I misleading, and how, to the EA?
88
Page 3-2. Why 10 km, not I or 20 km? Is the
answer presented in the methodology section, or is it
found in the "approved EA ToR"?
89
Page 3-3. Significant Wildlife Habitat. Does this
para need to be rewritten? The word "vulverable" is
not used properly. Are "roosting areas" and
"migratory stop-over areas" (should say for birds?)
"vulverable points"? No. There may be other
aspects to the roosting and stop-over areas that make
them important and vulnerable for a species life
cycle, but not these as stand alone criteria. The
above are rather examples for the next sentence
"Significant Wildlife Habitat does not include
eneral areas ...".
Furthermore, considering the proximity of 3 of 4 sites
being nearly adjacent to the Lake Ontario shoreline,
and knowing how the Lake Ontario shoreline and
adjacent land is important to migratory birds, was
there any consideration / search whether the general
area is flocked by migratory birds in the spring and in
the fall as expected? Was there any discussion with
J\.1NR area biolo ists?
Page 3-3, and other pages in the report. What
"deer"? Is that not the accepted common name for
deer, the ''white-tailed deer"? (See "'HIe web site).
Or was the finding in the field regarding the mouse
deer? What species of "rabbits'''? Why is the
mammal list so short? Was the field survey restricted
to visual records of whole animals, or it included
remains, scats and tracks as facts to be used to
determine presence of mammals at the site?
90
91
known to occur on or in the vicinity of the project area
are noted, no matter how old the record. A field survey
is then conducted to determine whether that species
exists on-site.
Sensitive Species generally involve those vulnerable to
collection (such as herptiles). No herptiles were noted
on-site, and consultation with the MNR has yet to be
conducted.
With regards to the relevance of the information and its
role, please see response provided for previous comment
on Table 3.1.
Comment noted. Jacques Whitford typically employs a
standard radius of 1 0 km around any site during
ecological impact assessments. This practice has been
accepted in past studies as suitable for the purpose of
identi in otential im acts at this level of detail.
Comment noted.
Comment noted. Significant topographical features
(such as a peninsula) that would concentrate any
migrating birds during stopover were not noted in the
area. Therefore, birds are not any more likely to flock to
this site than any other adjacent land. There was no
discussion with an f\1NR area biologist due to the
significant amount of suitable habitat/stopover area
available on ad'acent lands.
Deer is an acceptable reference made to White-tailed
Deer. We presume the reviewer was trying to reference
Deer Mouse in an attempt to show the presence of
confusion. The field survey recorded terrestrial wildlife
observations and obvious signs of wildlife (such as deer
trails or beds). Clarington 01 was the only site where a
terrestrial mammal species was observed (a Raccoon).
Clarington 0 I and 05 showed signs of deer (White-tailed
Deer) trails and beds throughout some of the fields. Scat
and tracks were not recorded. The lagomorph group
(rabbits and hare,) was meant by the term "rabbit",
which was thought to be a better descriptive term than
the technicallagomorph. No lagomorph species (e.g.,
Eastern Cottontail was recorded on-site, however, it was
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
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FINAL - Comments 10 Claringlon Peer Reviews - Preferred Site Report
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92 Page 3-3. 3rd last line. "wood" is referring to what?
93
Page 3-4. 1 st para. Is the '1he drainage ditch"
connected to a watershed or is it a swale? Could we
provide more aquatic inform;ation on the ditch? What
is the CLOCA status ofthis ditch? How many small
mammal species was seen while walking gently near
the ditch?
Page 3-4. Clarington 01 - Conclusion/Summary.
What is the status on the aquatic aspects? Is the
information provided allows for an evaluation in the
EA? Are birds not wildlife?
94
95
Page 4-2, Table 4.1 (also applicable to Table 5.1). In
consideration for the questions raised above, some of
which being applicable to all sites described in the
report (questions from pages 3-1 to 3-4 above), what
are the changes to be made to table 4. I? Is the table
row regarding "species of special concern" not
simply showing "AD V ANTAGE" in each column?
On the next row, "Distance from site...", why not
using 3 Ion as normally done in EAs, instead of 10
km? What is the scientific basis for a 10 km radius?
Why is the "Hazard Lands On-Site" or the
"Floodplain On-Site" called a "DlSADV ANT AGE"?
Why hazard lands and floodplain areas would
disqualifY a site from being selected? Usually, these
features are incorporated with the design of the
undertaking, allowing areas for tree compensation,
rehabilitation, and therefore seen as an advantage, not
disadvanta e.
Page 5-1. The three statements "this site is well
suited given the lack of.. ..waterbodies...". Could
we not address early in the text the fact that Lake
Ontario is at a leg stretch from sites Clarington 01, 04
and 05? Would a reader not feel at odd with these
conclusions?
Table 5.1. See comments for Table 4.1.
96
97
Comment noted. No watercourses are located on
Clarington 01. Birds are a form of wildlife, but due to
the mobile nature of birds, the impact from the loss of
habitat is minimal owing to the amount of suitable
habitat still available in the area. Birds will be displaced
during the construction phase, but as long as clearing is
avoided during the nesting season, there should be little
or no effect on the local bird population. This would be
addressed during the evaluation of the preferred
alternative.
With regard to what constitutes an advantage or
disadvantage for each site under each criterion, it should
be understood that the determination is in relative terms
between sites based on the full slate of indicators per
criterion.
We disagree with the reviewers observations on whether
or not the presence of hazard lands or floodplain on-site
is a disadvantage. Irrespective of the natural or
ecological characteristics of these features, where
possible, their disturbance is typically avoided as part of
planning and land development processes.
These statements will be modified in the final
documentation to read lack of watercourses on or
abutting the property.
See res onse to comments on Table 4.1 above.
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
Burlington ON . L7N 3T9
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98
The dates of traffic counts undertaken by URS in
Clarington were not specified (may be June 2007 as
specified for similar traffic counts undertaken in East
Gwillimb
The lane configuration shown in Figure 3-5 for the
Highway 401 eastbound off ramp intersection with
Courtice Road shows two eastbound through lanes on
the approach to Courtice Road, but it appears that
there is only one receiving lane as South Service
Road is shown on the same figure to be a basic two
lane road; and
Further to the previous point, there is an
inconsistency in the related analysis of this
intersection. For the existing and future a.m. peak
hour analysis, the eastbound approach is analyzed as
one left/through lane and one through/right lane,
which corresponds to the lanes depicted in Figure 3-
5. For the existing and future p.m. peak hour
analysis, the same approach is analyzed as one left
turn lane and one through/right lane. With the very
heavy volume of eastbound left turns that occur
during the p.m. peak hour, it is understood that the
through/left lane could function as a "de facto" left
turn lane and this appears to be what was intended in
the analysis. Depending on the actual number of
receiving lanes on South Service Road opposite the
ramp approach, consideration may be given to
designating the eastbound approach lanes as left and
through/right as used in the analysis. In terms of the
conclusions drawn from the analysis, this
inconsistenc can be considered inconse uential.
Table 1.2, Page 1 - 10
99
100
101
ClaritY the statement - "Generally, the higher the
projected traffic volumes along the route, the lower
the impact along the route and to the community".
102
Page 4-1
The opening statement in paragraph 4 seems to
indicate that the social impact of more trucks and trip
generation has not been considered. The overall
report has the sub-title "Social and Cultural
Considerations". This is confirmed by the statement
under the Section "Haul Distances", Page 7.1, last
paragraph. Some clarification is required in this
section to substantiate the comments.
The counts were undertaken in June 2007.
The current lane configuration of the eastbound approach
at the south ramp terminal intersection includes shared
tbroughlleft and shared through/right lanes. There are
two receiving lanes on South Service Road one of which
terminates a few hundred metres downstream from the
intersection.
The throughlleft lane was assumed to operate as a de
facto left turn lane in the p.m. peak hour considering the
amount ofteft turns during this peak hour (over 500 left
turning vehicles per hour compared to approximately 50
through/rights). In the a.m. peak hour traffic distribution
across the two lanes (through/left and through/right) is
almost equal. As such, during the a.m. peak period these
lanes are likely to function as currently designated:
through/left and through/right.
With the same amount of additional traffic (site traffic),
net impact to a roadway that carries higher traffic
volumes (background traffic) would be lower than to a
roadway with lower traffic volumes. Please refer to the
example provided in the report after the statement in
uestion.
The main purpose of the traffic assessment was to
provide a quantitative and qualitative comparison of the
short-listed site locations based on specific criteria rather
than preparing a detailed traffic impact assessment for
each location under consideration. Social impacts of
more trucks/trip generation associated with the future
Clarington Energy Business park will be considered in
detail at the next stage, should this location be selected
and approved as the preferred one. This future
assessment will not only incorporate anticipated future
auto and truck volumes associated with the full build out
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
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103 5.1 Trip Generation
In Tables 5.1 and 5.2, the number of packer trucks
remains the same for both the 150,000 and 250,000
taTInes per year scenarios for the Clarington sites.
Should this not be adjusted for the East Gwillimbury
site where packer trucks will not deliver directly to
the TTF for the 250,000 tonnes per year scenario?
104 Section 8 - "Maximum Scenario (400,000 tonnes per
year)"
Paragraph 3 opens with the statement: "It is also
important to take into account origin of unbound
trips...... ...". The wording then proceeds by stating
that at the time of the report preparation, origin of
trips associated with additional tonnage was
unknown. Clarification ofthese apparently
conflictin statements is re uired.
105 Section 9 - "Other Considerations"
9.3 Summary of Road Improvements
Costs in Table 9. I should be revised to reflect that
road construction will be to an urban standard. This
is in conformity with the Secondary Plan
recommendations for "Clarington Energy Business
Park". Rural cross section roads are not acceptable.
of the business park, but also incorporate planned and
committed road improvements in the area to
accommodate this growth, which have not been
considered in the preliminary comparison analysis. This
also applies to other sites locations, where a more
detailed assessment would be required. The statement on
Page 7.1 of the report confirms that the haul distances
calculated for each site location were not used in
determining impacts along actual haul routes, but rather
for comparative purposes amongst all potential site
locations provided that longer haul distances would
generally result in higher overall impacts to traffic and
environment.
For a 250,000 tpy TTF at the East Gwillimbury 01 site,
waste will be directly hauled in packer trucks from
Aurora, King, Newmarket, East GwilIimbury,
Whitchurch-StoufIVille and Georgina to the TTF. Waste
will also be transported to the TIP in packer trucks from
northern Durham Region local municipalities (Brock and
Uxbridge).
The number of additional trucks used in this analysis was
based on the maximum tonnage of 400,000 tonnes per
year. However, the origin of this additional waste
(consequently vehicular trips) is unknown, and haul
distances/tonnage-kilometres for each site could not be
calculated. Thus, it is difficult to determine the preferred
site location under this scenario using the haul distance
criteria applied in other annual waste tonnage scenarios.
Preliminary cost estimates were used to compare the
short.listed site locations utilizing existing road
infrastructure and determining required upgrades. South
Service Road currently has a rural cross-section, which
was assumed to require an upgrade to handle more truck
traffic associated with the proposed site, similar to other
site locations. In the context of the Clarington Energy
Business Park Secondary Plan (OPA 46), there will be a
need to eventually upgrade al1 road infrastructure to
urban design. As part of this process, there will
be/should be a cost sharing agreement in place (e.g.
development charge credit) between all future
developments within the Clarington Energy Business
Park and the municipality. Costs of
upgrading/constructing the road(s) to urban design will
be in the $1,000,000-$1,500,000 Ikm range, as
mentioned in the comment. However, only a percentage
of the total cost would be assumed b the sub. ect
Jacques Whitford Ltd. . 3430 South Service Road' Unit 203
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FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
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106 The "Significant Findings from the Traffic Study"
section should be revised on Pa e 10-2.
107 The use of the South Service Road and Osbourne
Road as truck routes to service the TIF is not
acceptable in terms of the road uses envisaged in the
secondary plan for the Clarington Energy Business
Park.
A route following Courtice Road with a southerly
east/west access road north of the CP Rail corridor is
the arrangement envisaged by the Municipality.
Osbourne Road, for example, is promoted within the
Park Plan as a local street built to an urban standard,
complete with sidewalks, landscaped borders and
treed boulevards, a street standard hardly conducive
to hea truck traffic.
development, for reasons discussed above.
In addition, there are still many unknown factors, which
to some extent may affect roadways currently illustrated
in the Clarington Energy Business Park Secondary Plan.
These potential changes include widening of Highway
401 with possible realignment of South Service Road,
improvements to the Courtice Road interchange with
possible changes to the west terminus of the future
Energy Drive. Recognizing that access to the subject site
may change in the future, for the purpose of this
assessment and for consistency purposes, only upgrades/
improvements to exiting roadway infrastructure were
considered in all cases. Costs associated with future road
construction/upgrades will be determined in more detail
at the next stage once the preferred site selection process
is com leted.
This will be addressed as part of the Traffic Impact
Stud in su ort of a roval a lications, as re uired.
The comparison of short-listed sites was based on
specific information available at the time the analysis
was completed.
The detailed site-specific studies and ultimately
documentation for obtaining EP A level and other
approvals will consider the best available information at
that time.
!O8 Section 2: Methodology of Study
In the "Study Approach and Key Assumptions",
capital costs for water supply, sanitary sewer
connection, natural gas and electrical grid
connections have been estimated on the basis of
250,000 tonnes per year. Given that these facilities
may be supplied to the site by installation within
reconstructed roads, it would seem prudent to service
the site initially for the final capacity requirements of
400,000 tonnes. This is what is proposed for
stormwater management facilities. Have the
implications of upgrading services at a later date for
the 400,000 tonne facili been assessed?
109 Table 3,1, Page 3,1
?t:
The maximum size for the initial facility is 250,000
tonnes per year. The expansion to 400,000 tonnes per
year is a possibility in the future. The site itself is sized
to accommodate a facility capable of processing up to
400,000 tonnes per year, The development of the
required servicing infrastructure depends on both the
nature of the existing infrastructure and the requirements
of the facility. Neither the timing of the potential
expansion to 400,000 tonnes per year, nor the nature of
the existing infrastructure at the time of that expansion is
known. Given the uncertainty regarding the potential
expansion to 400,000 tonnes per year, the servicing
infrastructure was based on the more certain capacity of
250,000 tonnes er ear.
General site work includes provisions for parking and
on-site draina e. The estimates for the various facili
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
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110
Does the General Site Works cost include for
parking, internal drainage, engineering design and
administration costs, etc.?
Section 3.1.2, Page 3.1
Road improvement costs should be adjusted to reflect
urban standard construction.
III
With respect to Table 3.4, Cost of Sewer
Connections, it is not clear why such large diameter
sanitary sewers are envisaged. Annex H -
"Technical Considerations" indicates waste water
discharge of63 litres per second. A 450 mm dia.
gravity sewer seems very large for such relatively
small flows.
The costs in Table 3.4, Page 3.2 should be revisited
(Le. the 450 mm dia. sewer proposed west of
Osbourne Street has a projected higher unit price than
the Clarington 04 site sanitary sewer which would be
constructed within existing roadways and involves an
expensive bored/tunnelled crossing of the CPR tracks
and a watercourse .
Section 3 - "Results and Findings"
112
113
We note that the requirement for sanitary sewer
connections is predicated on the type of facility
design proposed, Le. 'dry' air pollution control and
zero process water discharge.
114
There will however still be a requirement for sewer
facilities to accommodate staff "domestic" waste,
which may be handled by a tile bed septic system as
indicated.
Section 3.1.3 - "Stormwater Management Costs"
115
In the Report on Potential Water Quality Impacts,
Annex B, sites Clarington 01 and 05 and East
Gwillimbury 01 require enhanced levels of
stormwater protection due to receiving waters being
cold water fisheries. The costs in Table 3.7 are fairly
similar. Has enough costing been included to allow
for "enhanced protection", including outlets to
receivin waters?
Section 3.1.6 - "Summary of Site Specific Capital
Costs"
components listed in Table 3.1 include provisions for the
associated engineering and related administration.
Recognizing that access to the subject site may change in
the future, for the purpose of the preliminary assessment
of potential site locations (road improvement costs) and
for consistency purposes, only upgrades/ improvements
to exiting roadway infrastructure were considered. Costs
associated with future road construction/upgrades (urban
design) will be determined in more detail at the next
stage once the preferred site selection process is
com leted.
Vendors operating existing lTF provided facility design
data. Vendors suggested a 300 mm diameter sanitary
forcemain which without exact design criteria, was
assumed to be equivalent to a 450 mm gravity sewer.
The assumptions were based on a worst case scenario.
The unit price incorporates the total cost to install the
sewer, including connections and manholes, These costs
represent a greater proportion of the total cost due to the
relatively short length of the sewer required for the
Clarington 04 site and therefore, inflating the unit price.
This cost will be refined at the detailed design stage.
The cost to construct a tile bed septic system would be
common to all four sites and were therefore not included
in the overall costs.
The initial cost estimate in Table 3.7 includes the cost to
construct the stormwater pond. The function of the
stormwater pond is to provide enhanced or normal
protection to the respective watercourses. During the site
specific design stage, we will consider the costs from the
outlet to the receiving watercourse.
The cost to construct a tile bed septic system would be
common to all four sites.
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
Burlington ON . L7N 3T9
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FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
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116
As indicated above, same sewage handling capability
will be required. Table 3.7 should be revised to
reflect the need to provide for staff "domestic" waste
dis osal.
Appendix' A' - Technical Memorandum
On Page 4, Waste Supply Truck Capacity, it is stated
that the location ofthe TTF facility will determine
whether packer trucks will haul directly to the TTF or
to a transfer station.
In the "Status Quo" situation, Table 3.1.2, for
example, all Clarington waste is hauled to the transfer
station on Courtice Road. With the construction of
the TIF in Scenarios 2 and 3, packer truckers will
still haul waste to the proposed TTF. There will be
an impact from the establishment of new haul routes
for packer truckers if they are to haul directly to a
TTF at Location Clarington 04. Clarington 05 and 01
would not alter the haul route patterns for packer
trucks.
It is our understanding for Tables 3.1.2 - 3.1.4 that
packer truck use will still be the preferred haulage
method for some areas, i.e. Brock and Uxbridge.
What change in truck patterns has been allowed for if
a TTF takes the place of a transfer station as the
disposal area for packer trucks, i.e. Brock and
Uxbrid e.
In order to do a comparison of the haul costs, we only
looked at tbe haul costs that changed due to the potential
development of the TTF at a particular short-list site. We
did not look at haul costs that would be the same across
all four scenarios (e.g. waste from Markham will always
be hauled in packers to the Miller Waste transfer station
in Markham).
Depending on where the TTF is located, the haul pattern
of transporting waste in Brock and Uxbridge changes.
For the Clarington sites, waste from Brock and U xbridge
will be hauled to the Miller Waste transfer station in
Pickering (same as the status quo scenario) and
transferred to transfer trailer vehicles. But in the case of
the East Gwillimbury site, this waste will be directly
hauled to the TTF.
117 As previously indicated, waste water discharge is
estimated at 63 litres per second, Section 3.2.2, Page
3.2. How was a 450 mm diameter sewer size arrived
at for such a relatively low flow? Are there other
considerations that have not been incorporated in the
re ort?
118 Section 3.4 - "Road Access and Improvements"
Table 3.4, Page 3.4, should be clarified to indicate
road reconstruction will be to urban standard. Note
also that the South Service Road and Osbourne Road
cannot be used for site access.
1] 9 There has been comment (Steven Rowe) that a large
facility on Short-List Site 5 would displace the
primary entrance to the Clarington Energy Park and
the western part of the "spine" through the park.
There is no indication in Section 3.4 that any major
road issues exist with respect to the assessment of
Site No.5.
Vendors operating existing TTF provided facility design
data. Vendors suggested a 300 mm diameter sanitary
forcemain which without exact design criteria, was
assumed to be equivalent to a 450 mm gravity sewer.
The assumptions were based on a worst case scenario.
This will be addressed as part of the Traffic Impact
Study in support of approval applications, as required.
Only existing road infrastructure was considered for the
preliminary assessment and comparison purposes.
The comparison of short-listed sites was based on
specific information available at the time the analysis
was completed.
The detailed site-specific studies and ultimately,
documentation for obtaining EP A level and other
a rovals, will consider the best available information at
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
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FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
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120
Section 4.2 - "Minimum Required Site Size"
121
The minimum required site size discussed in this
section does not appear to take into account the area
required for stormwater management facilities
(calculated at approximately 1.0 hectare average for
all sites). 11 does appear though that all the Short-List
sites have sufficient area for all requirements
although the extent of buffering requirements are not
clearly defined or what form the buffering will take.
We understand that Drawing 1'0.1-01 in Appendix E
represents a footprint for a 400,000 tonne per year
facili
The "Summary of Cost" Table 3.1 should be revised.
The watermain size projected for Clarington 01 site is
300 mm dia. The projected size for the Clarington 04
site is 400 mm dia. In the table, the unit costs are
indicated as $575/m for each site.
that time.
Table 2-1 in the Facility Site Size technical
memorandum includes area required for adequate
stormwater management.
The unit price incorporates the total cost to install the
watermain, including full engineering design,
connections and valve chambers. The unit price would
be slightly lower than $575/m (approximately $525/m)
due to the reduction in material costs but would not
greatly affect the installation costs. This cost will be
refined at the detailed desi sta e.
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122 From Faye Langmaid:
I have just had a review of Annex B and your SWM
assumptions. To begin with the assumption that you
would be allowed to have the SWM pond on your
own site without participating in the master drainage
plan for the Energy Park is flawed. This will
obviously then affect the anticipated cost estimates
and also carries that flaw into the
advantage/disadvantage rating. Currently you have
site Oland 05 as advantage and neutral respectively
but it is based on the distance to the receiving
stream; once you remove the assumption of using
your own site for the SWM and participate in the
two ponds shown in the master drainage plan I
would think that they both become neutral.
123 Please show transfer stations on overall traffic map
in Annex F.
124 In Table 12.1, the East Gwillimbury site (compared
to the Clarington sites) was at a disadvantage due to
the 2 critical movements at Bales Drive/Woodbine
Ave and at Garfield Wright Blvd/Woodbine Ave.
The peer reviewer commented that this disadvantage
could be mitigated with traffic lights installed at
those intersections and then the overall score would
be neutral instead of disadvantaged.
125 The haul distances and traffic impacts did not factor
in the proposed Highway 407/401 connection.
The methodology employed in the comparison of all the
short-listed sites was to assume the use of, or integration
with, existing infrastructure. In the case of stormwater
management there are no existing facilities on any of the
sites, nor were we aware of specific facilities that had
been properly designed and approved for construction in
the Energy Park. Given this situation we completed the
analysis documented in Annex B. We have reviewed the
comment from the peer reviewer but we do not believe it
provides a basis for changing our methodology as
summarized above. There is therefore no need to revise
the cost estimates or the allocation of
advantages/disadvantages ratings.
The detailed site-specific studies and ultimately
documentation for obtaining EP A level and other
approvals will consider the best available information on
stormwater management available at the time those future
studies are completed.
Transfer stations will be shown on the overall traffic map
to be provided in the updated EA documentation to be
submitted to MOE .
It would be possible to mitigate delays to site traffic by
placing a traffic signal at one ofthe site entrances on
Davis Drive (EG 01). It is important to note; however,
that traffic volumes at this intersection would need to
meet the signal warrant criteria in order for traffic signals
to be installed (traffic volumes at the south ramp terminal
at Courtice Road and Highway 401 are likely to meet the
signal warrant criteria sooner). The new signal on Davis
Drive will reduce delays to site traffic, although introduce
additional delays to through traffic. Similarly, placing a
traffic signal at Courtice (south ramp terminal) will also
introduce additional delays to through traffic on Courtice
Road, although some may argue that due to the fact that
the off-ramp carries significantly more traffic than the
arterial road, the new signals at Courtice would likely
result in an overall reduction in vehicular delays at this
intersection, which may not be the case in East
Gwillimbu .
The methodology employed in the comparison of all the
short-listed sites was to assume the use of existing roads.
The detailed site-specific studies and ultimately
documentation for obtaining EP A level and other
approvals will consider the best available information
on haul routes available at the time those future studies
are corn leted.
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
Burlington ON . L7N 3T9
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Ji
FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
November 9, 2007
Page 31
126
From Faye Langmaid:
1 've had a look at the report and the main focus of it
is on the evaluation of the archaeological potential of
each of the sites. The evaluation was done by Colin
Varley who is the senior archaeologist with Jacques
Whitford.
Page 3-1 of the report notes that the 05 site contains
an occupied house and farmstead in the south west
corner of the site. An abandoned house and remains
of a shed and a barn is identified in the north east
part of the site.
Page 4-1 of the report addresses historic resources
and states that the abandoned house may be the dot
on the 1861 Tremaine map. The 1878 Belden atlas
showed two houses. One is indicated as being the
"identified" house. The second house is on site 01
and is now demolished. There is no mention of the
south in the north west section that is still occupied.
LDO indicates that this house was built circa ]900.
Section 4.1.2 concludes that both these buildings
were occupied as late as 1973 and there is high
potential for the presence of historic period
archaeological resources on sites 01 and 05.
\Vhat is missing from the report is any kind of
cultural heritage evaluation of the abandoned and
occupied house on site 05, and even the demolished
house on site 01. Other than referencing dots on the
maps, and the names written on the maps, there's no
documented information in the report on the
ownership or history of these properties.
It is not listed on our heritage resources listing,
which means the Municipality does not deem it
worthy of preserving.
127 From Laura Barta:
During a review of the above mentioned Study, I
was attempting to work through the Annual Unit
Haul Cost detailed in section 3.3 of Appendix A-
'Technical Memorandum on Haul Cost Analysis'
and was experiencing some difficulty in following
the flow.
In the more comprehensive description to be provided in
the draft EA document, the application of advantages and
disadvantages will be more fully described. In addition,
where mitigative measures and professional judgment
have been utilized, this will be identified in greater detail
as well to provide further traceability. The description,
specific to the particular issue raised will include
justification based on the available data at the time,
however, with the information provided in your
comments, it is likely that the major disadvantage applied
originally with respect to the existing structure on
Clarington 05 will be reduced to a disadvantage, similar
to that on the Clarington 01 site. We have reviewed this
modification with respect to the overall evaluation and
have determined that it will not impact the identification
of Clarington 0 I as the preferred site.
The Haul Cost Analysis was reviewed. The correct cost
per truck minute is $1.79 for packer trucks and $2.06 for
transfer trailers, which was used in all calculations. There
is a typo in the calculation columns for the total cost per
tonne minute ofhau! in both Table 3.3.1 and 3.3.2. This
error was corrected.
In addition, there was an error in the annual haul cost
s readsheets 150,000 t and 250,000 t for the Status
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
Burlington ON . L7N 3T9
Tel: (905) 631-8684 . Fax: (905) 631-8960
Ji
FINAL - Comments to Clarington Peer Reviews - Preferred Site Report
November g, 2007
Page 32
In Table 3.3.1 on page I3 the total per truck minute
is shown as $1.79. On page 14, your calculation
displays the use of a $1.58/truck minute, however
the calculated value appears to be based on the
$1.79. 1 am having the same difficulty following the
flow in Table 3.3.2. On page 14 the total per truck
minute is shown as $2.06, yet your calculation
displays the use of a $1.91/truck minute. Can you
please provide some clarification on these two
tables?
In Table 3.4.1 on page 15 the Annual Haul Cost for
Scenario 1 - Status Quo, how is the column showing
the Annual Haul Cost in ($) calculated?
I have been unable to arrive at the total costs for each
category by multiplying the Unit Haul Cost x Annual .
Tennes x Round Trip Cycle Time.
Is another factor included in this calculation? Would
the same hold true for Table 3.4.2, 3.4.3, and 3.4.4 .
under all scenarios?
I would appreciate your assistance in claritying the
above mentioned issues.
Quo, Clarington 01/05, and Clarington 04 scenarios
(Tables 3.4.1 to 3.4.3). As pointed out by Ms. Barta, a
line item was mistakenly excluded in the total York
Region costs. This item was the annual haul cost
associated with hauling waste from the Georgina Transfer
Station to Green Lane Landfill. The haul cost is the same
($174,108) for these three scenarios. Please note that the
costs originally reported for the East Gwillimbury 01
scenario are correct.
The numbers in the annual haul cost spreadsheets were
rounded to make it easier for readers to follow the flow.
The following numbers were rounded in Tables 3.4.1
through 3.4.4 for both the 150,000 tpy and 250,000 tpy
facility sizes:
.
Unit cost per tonne - minute ($/tonne-min) was
rounded to two decimal places;
Annual tonnes was rounded to zero decimal places;
and,
Round trip cycle time (min) was rounded to zero
decimal places.
Revised Tables 3.4.1 through 3.4.4 for both facility sizes
were provided under separate cover. The tables
incorporate the corrections with respect to the addition
error and the results of rounding the calculations.
Please note there was no change to Tables 3.1.2 through
3.1.5 (Summary of Systems and Quantity of Waste
Transported) and Tables 3.2.1 through 3.2.4 (Total Round
Trip Cycle Time).
The corrected versions of the Tables will be included in
Draft EA Documentation. None of the above mentioned
minor arithmetic changes to the tables affect the findings
or conclusions resented in the documents.
Jacques Whitford Ltd. . 3430 South Service Road. Unit 203
Burlington ON . L7N 3T9
Tel: (905) 631-8684 . Fax: (905) 631-8960
Table I
Cnterla Indicator Clarington Clarington Clarington East GWlllimbury
01 04 05 01
Capital Costs Site development NEUTRAL DISADVANTAGE DISADVANTAGE ADVANTAGE
costs, including: . Site-specific . Site-specific . Site-specific . Site-specific
infrastructure capital costs capital costs capital costs capital costs
required, upgrades range from range from range from range from $3.8
to existing $7.6 to $8.9 to $16.7 $8.9 to $15.5 to $13.1 million
infrastructure $13.1 million million million
(roads, sewers,
etc.) property
acquisition and
possible site
remediation
OVERALL NEUTRAL OISAOVANTAGE DISAOVANTAGE ADVANTAGE
Attachment 11
To Report PSD-141-07
Resolution as adopted by Clarington Council on May 28, 2007:
"THAT Report PSD-070-07 be received;
THAT Staff be instructed to carry out the requirements of Resolution #C-211-07
by preparing the studies in accordance with the scope of work set out Report
PSD-070-07;
THAT Mr. Steven Rowe be retained to undertake the scope of work as outlined in
Section 4.2 (Site Selection) and Section 4.4 (Gap Analysis) of Report PSD-070-
07, and further to advise on the scope of work set out in Section 5.1 (Oversight of
Technology Procurement Process) and 5.2 (Potential Environmental Effects) of
Report PSD-070-07;
THAT SENES Consultants Limited be retained to undertake the scope of work as
outlined in Section 5.1 (Oversight of Technology Procurement Process) of Report
PSD-070-07, and further to assist with the scope of work set out in Section 5.2
(Potential Environmental Effects) of Report PSD-070-07;
THAT AMEC E&C Services Ltd. be retained to undertake the scope of work as
outlined in Section 5.2 (Potential Environmental Effects) of Report PSD-070-07;
THAT C.B. Richard Ellis Ltd. be retained to undertake the scope of work set out
in Section 6.1 (Impact on Clarington Energy Business Park) and Section 6.2
(Impact on Assessment Base) of Report PSD-070-07 and further to assist with
the scope of work set out in Section 6.3 (Community Stigma);
THAT the Director of Finance be authorized to retain a multi-disciplinary
accounting firm to undertake the scope of work set out in Section 6.3
(Community Stigma) and Section 6.4 (Host Community Agreement) of Report
PSD-070-07;
THAT the Municipal Solicitor and Consulting Engineer (Totten Sims Hubicki)
provide information, professional opinion, estimates and advice as deemed
appropriate;
THAT the Directors of Finance and Planning Services be instructed to strike a
committee comprised of Clarington staff and consultants similar in composition to
the Region of Durham's committee in order to facilitate discussions related to the
Host Community Agreement on a without prejudice basis to the Municipality's
decision on whether to be a willing host;
THAT the Directors of Finance and Planning Services be instructed to take any
additional actions or retain any additional consultants deemed necessary to
ensure the Municipality has carried out its due diligence;
THAT the Region be requested to work in cooperation with Clarington Staff to
improve the public engagement process as noted in Section 4.3 and the Air Shed
Study process as noted in Section 5.2;
THAT the Purchasing By-Law 2006-127 be waived;
THAT the Director of Planning Services and the Director of Finance be
authorized to negotiate and approve contracts with the consultants deemed
necessary to complete the due diligence for the Municipality as identified in
Report PSD-070-07;
THAT Council authorize the Mayor and Clerk to sign the necessary by-laws to
engage the consultants and execute the contracts deemed satisfactory by the
Director of Planning Services and the Director of Finance;
THAT the peer reviews and studies referenced in Report PSD-070-07 be
deemed to be part of the "necessary studies" to complete due diligence as
referenced in the motion approved by Durham Region Council on April 18, 2007,
and that the Director of Finance be directed to recover these due diligence costs
from the Region of Durham as set out in their motion;
THAT Staff report regularly to Council on the progress and findings of the peer
reviews and analyses being undertaken, and the Host Community Agreement
discussions; and
THAT all interested parties be notified of Council's decision including the Regions
of York and Durham Councils and the Joint Waste Management Committee."
Attachment 12
To Report PSD-141-07
Resolution for PSD-097-07
Resolution C-455-07
THAT Report PSD-097-07 be received;
THAT Section 33 and Attachments 6 and 8A to Report PSD-097-97 be
approved as the Municipality of Clarington's comments to date for the Site
Selection segment of the EA process;
THAT Section 34 and Attachments 7 and 88 to Report PSD-097-97 be
approved as the Municipality of Clarington's comments to date on the
Generic Human Health and Ecological Risk Assessment, a component of
the EA process;
THAT Clarington request that the Region provide the other reports
including the Traffic Impact Analysis Archeological Assessment Air and
Groundwater Monitoring Environmental Impact Study Land Use
Infrastructure and Servicing Assessments with sufficient time given to the
Municipality and other store view and comment prior to completing their
analysis and selecting a preferred site;
THAT a copy of Report PSD-097-97 be forwarded to the Region of
Durham the Region of York and Ministry of Environment; and
THAT all interested parties including the Regions of York and Durham and
the Joint Waste Management Committee be notified of Council's decision.
CARRIED AS AMENDED
LATER IN THE MEETING
Resolution C-457-07
THAT the foregoing Resolution C-455-07 be amended by adding a new
paragraph 5 as follows;
THAT the Region of Durham be requested to provide to the Municipality of
Clarington written confirmation of the minimum guaranteed operating
standard for emissions and that a 247 emissions monitoring systems is to
be required in the RFP.
CARRIED
Attachment 13
To Report PSD-141-07
Resolutions: GPA 632-07 and C-592-07
WHEREAS the Consultants retained by the Regions of Durham York
Proponent to oversee an Environmental Assessment EA to site an Energy
From Waste EFW facility have identified a property located in the
Municipality of Clarington as the preferred site for said EFW facility
WHEREAS such EFW facility is to be developed and operating on a date
that appropriately relates with the scheduled closure of the US State of
Michigan border to all Canadian Municipal residual waste shipments
WHEREAS the Municipality of Clarington believes that the Proponent of
the EFW facility shall be fully responsible for all costs and risks associated
with the development and operation of the EFW facility
WHEREAS the Ontario Ministry of Environment must approve the
Environmental Assessment process which includes a site specific Human
Health and Environmental Risk Assessment and issue to the Proponent a
license to operate the EFW facility
WHEREAS it is standard practice in North America that a Host Community
Impact Agreement be entered into between the Proponent and the Host
Community for any type of Municipal residual waste processing facility
NOWTHEREFORE the Municipality of Clarington resolves that staff is
authorized to Undertake without prejudice negotiations with Durham
Region and that the Regions of York and Durham are requested to
1 Agree to protect the health and safety of the residents of Clarington
and Durham by incorporating into the design and installation of the
EFW facility the most modern and state of the art emission control
technologies that meet or exceed the European Union EU monitoring
and measurement standards
2 Agree to continue to support an aggressive residual waste diversion
and recycling programs in order to achieve and exceed on or before
December 2010 a 70 diversion recycling rate for the entire Region and
such aggressive programs shall continue beyond 2010
3 The Host Community Impact Agreement shall address but not be
limited to the following major areas of concern and requirements
. Provide24/7 emission monitoring systems easily accessible
by the public
. Restrict the quantities types and sources of waste i.e. no City
of Toronto Waste will be allowed
. Establish a Community Liaison Committee including local
Physicians
. Provide infrastructures to facilitate economic development in
Clarington
. Absorb all Clarington costs that are related to the
development and operations of the EFW facility
. Compensate Clarington for any detrimental costs if any
associated to an EFW facility sited within Clarington borders
. Assume all risks and liabilities associated with the EFW
facility
. Provide a royalty and/or revenue sharing arrangement to
Clarington for the life of the EFW facility in appropriate
amounts and suitably indexed
. The project shall have no adverse impacts on payments in
lieu of taxes
. No ash from the facility shall be deposited in any landfill site
located within Clarington borders
4 To alleviate the concerns of the people of Clarington and Durham by
acknowledging the foregoing and agreeing to negotiate with
Clarington in good faith.
5 Staff is directed to forward this resolution to the Regions of York and
Durham FORTHWITH
Attachment 14
To Report PSD-141-07
Maximum Achievable Control Technology
(MACT)
Short Definition
Technology-based standards based on the best-performing similar facilities in
operation.
Background
Ontario Ministry of the Environment Guideline A-7 (Combustion and Air Pollution
Control Requirements for New Municipal Waste Incinerators) indicates that it was
developed on the basis of "Maximum Achievable Control Technology," (MACT), human
health considerations and the approaches taken by other jurisdictions. However, the A-7
Guideline does not define MACT.
The term MACT seems to have been originally used by the U.S. Environmental
Protection Agency (EPA). The EPA originally controlled hazardous air pollutants by
setting standards for each pollutant based on an individual basis according to its
particular health risk. In 1990, the federal government directed the EPA to replace this
original approach with one based on what technology could currently achieve, and that
the technology-based approach be followed by a risk-based approach to address any
remaining, or residual, risks.
Maximum Achievable Control Technology (MACT)
In 1999, the EPA adopted the MACT approach for controlling hazardous air emissions.
Under this approach, the standards for each industry group are based on the emission
levels that are already being achieved by the better-controlled and lower-emitting
sources within the group.
U.S. MACT standards are designed to reduce hazardous air emissions to a maximum
achievable degree, taking into consideration the cost of reductions and other factors.
When developing a MACT standard for a particular source category, the EPA looks at
the current level of emissions achieved by best-performing similar sources through
clean processes, control devices, work practices, or other methods. These emissions
levels set a baseline (MACT floor). At a minimum, a MACT standard must achieve,
throughout the industry, a level of emissions control that is at least equivalent to the
MACT floor. The EPA can establish a more stringent standard when it makes economic,
environmental, and public health sense to do so.