HomeMy WebLinkAboutPD-31-92 THE CORPORATION OF THE TOWN OF NEWCASTLE
DN:LEACHATE.GPA REPORT
Meeting: General Purpose and Administration Committee File#
Date: Monday, January 20, 1992 Res.
By-Law#
Report#: #: OPA 89-97/D
Subject: APPLICATION TO AMEND THE DURHAM REGIONAL OFFICIAL PLAN
APPLICANT: LAIDLAW WASTE SYSTEMS (DURHAM) LTD.
FILE: OPA 89-97/D (LEACHATE FORCEMAIN PROPOSAL)
Recommendations:
It is respectfully recommended that the General Purpose and
Administration Committee recommend to Council the following:
1. THAT Report PD- 31 -92 be received;
2 . THAT Official Plan Amendment Application 89-97/D submitted by
McDermott' and Associates Limited on behalf of Laidlaw Waste Systems
(Durham) Ltd. to permit the construction of a forcemain to
transport leachate to the Graham Creek Water Pollution Control
Plant and to allocate capacity in the Plant for the treatment of
leachate created by landfilling operations at their proposed Major
Expansion Site in Part Lots 11 and 12 , Concessions 2 and 3 , former
Township of Clarke, be recommended for DENIAL to the Region of
Durham; and
3 . THAT a copy of this Report and Council's decision be forwarded to
the Region of Durham Planning Department, the Ministry of municipal
Affairs, and the Honourable Ruth Grier, Minister of the
Environment; and
4 . THAT the interested parties listed in this report and any
delegation be advised of Council's decision.
1. APPLICATION DETAILS
1. 1 Applicant: McDermott & Associates Limited on
behalf of Laidlaw Waste Systems
(Durham) Ltd.
1. 2 Official Plan Amendment: to allocate capacity in the Graham
Creek Water Pollution Control Plant
for the treatment of leachate created
by Laidlaw's Major Expansion proposal
and to permit the construction of a
sewage forcemain beyond the
REPORT NO. : PD-31 -92 PAGE 2
boundaries of the Newcastle Small
Urban Area. Laidlaw seeks an average
design capacity of 64 , 000 gallons per
day and a peak capacity of 270, 000
gallons per day at the Water
Pollution Control Plant.
2 . LOCATION
2 . 1 Existing and Proposed Landfill Operations
2 . 1. 1 Laidlaw's existing landfill site is located in Part Lots 11
and 12 , Concession 3 , former Township of Clarke. Laidlaw has
indicated that the Major Expansion proposal would occupy
approximately 48 ha (118 . 6 acres) in Part Lot 11, Concession
2 , and Part of Lots 11 and 12, Concession 3 , former Township
of Clarke (Attachment No. 1) .
2 . 2 Proposed Leachate Forcemain
2 . 2 . 1 Laidlaw has proposed to run the forcemain a distance of 12 . 2
km (7 . 6 mi) from the site of their existing landfill operation
to the Graham Creek Water Pollution Control Plant (W.P.C.P. )
in Newcastle Village. Laidlaw has indicated that the forcemain
is intended to only transport leachate from their Major
Expansion Proposal.
3 . EXISTING AND SURROUNDING USES
3 . 1 The forcemain route, as proposed, would run through primarily
rural and agricultural areas.
4 . BACKGROUND
4 . 1 The application as originally submitted by Laidlaw in August
1989 proposed to treat leachate created by landfilling
operations at both the Existing/Infill Site and the Major
Expansion to the landfill proposed by Laidlaw.
4 . 2 On July 26, 1989, Laidlaw's solicitor forwarded a letter to
the Environmental Assessment Board requesting that a
REPORT NO. : PD- 31 -92 PAGE 3
Consolidated Hearing be scheduled in respect of the following:
the application for interim expansion (Infill Proposal)
pursuant to Part V of the Environmental Protection Act;
the rezoning application related to the Infill Proposal;
the Official Plan Amendment application related to the
Infill Proposal;
the application for consent pursuant to Section 144 (3)
of the Regional Municipality of Durham Act;
the application for construction and installation of a
forcemain pursuant to Section 24 of the Ontario Water
Resources Act.
4 . 3 In March 1990, Laidlaw's solicitors indicated, in
correspondence to the Consolidated Hearings Board, that their
client did not intend to proceed at that time, with the
Official Plan Amendment application and the Ontario Water
Resources Act application related to the leachate forcemain
proposal. Staff note however, that the July 26, 1989 letter
from Laidlaw's solicitor to the Environmental Assessment Board
did not refer to the Official Plan Amendment application
related to the leachate forcemain. This application was not
submitted to the Region until August 16, 1989.
4.4 By letter dated May 4 , 1990, Laidlaw's solicitor advised the
Region of Durham that the Official Plan Amendment application
related to the leachate forcemain was not being withdrawn and
requested that it be dealt with in due course.
4 . 5 Laidlaw has indicated in recent documentation that the
leachate forcemain is intended to serve the proposed major
expansion of their landfill site. Staff note that no
applications in respect of the Laidlaw's Major Expansion
Proposal have yet to be submitted to the Town or the Region.
REPORT NO. : PD- 31 -92 PAGE 4
5. RELATED APPLICATIONS
5. 1 Major Expansion Proposal
5. 1. 1 Laidlaw has indicated their intention to proceed with a major
expansion of their landfill site, and to proceed with a full
environmental assessment under the provisions of the
Environmental Assessment Act. As of the writing of this
report, the draft Environmental Assessment (EA) documents had
yet to be submitted to the Ministry of the Environment, the
Town or the Region. Applications for Official Plan Amendment
and Rezoning have also not been submitted.
5. 1. 2 Staff note that Laidlaw had indicated as far back as January
3 , 1989, that the draft EA documents would be submitted in
April 1989, with the applications for Official Plan Amendment
and Rezoning being submitted in late February or early March
1989 . More recently, in June 1991, Laidlaw indicated that work
on the draft EA would be completed during the spring of 1991.
There has been no recent indication as to the expected timing
of the applications for Official Plan Amendment and Rezoning
in relation to the Major Expansion Proposal.
5. 2 Application Pursuant to the Ontario Water Resources Act
5. 2 . 1 Section 24 of the Ontario Water Resources Act states that the
approval of the Ministry of the Environment is required for
the establishment of any sewage works by any municipality or
any person. Laidlaw has submitted an application to the
Ministry of the Environment for approval of the proposed
leachate forcemain.
6. OFFICIAL PLAN POLICIES
6. 1 1976 Durham Regional Official Plan
6. 1. 1 The 1976 Durham Regional Official Plan does not specifically
address the matter of allocation in a sewage treatment plant
for the treatment of leachate from publicly or privately
operated landfill sites. Section 6 . 2 . 1 e) states that the
utilities and services provided for by the Plan are intended
to meet the needs and requirements of the various Settlement
t"� 0
REPORT NO. : PD- 31 -92 PAGE 5
Areas within the Region. Section 14 of the Plan, being
'Utilities and Services' , provides specific policies relating
to the provision of Regional services.
6.2 1991 Durham Regional Official Plan
6 . 2 . 1 The 1991 Regional Plan also does not address sewage allocation
for the purposes of leachate treatment. Section 5 (Cultural,
Health and Community Facilities, Services and Utilities) does
however, encourage the provision of Regional municipal
services in an orderly and efficient fashion.
6 . 3 Draft Amendment to the Durham Regional Official Plan
6. 3 . 1 The draft amendment submitted by the applicant (Attachment
No. 2) proposes to include a clause in Section 14 of the 1976
Official Plan to permit additional capacity in the Graham
Creek W.P.C.P. to be allocated for the treatment of leachate
from the Laidlaw landfill, and to provide for the construction
of the leachate forcemain.
6. 3 . 2 The draft amendment also indicates that, where the sewage
forcemain and any related facilities are owned by the Region,
the forcemain and related facilities may be oversized to
provide for the future extension of sanitary sewers to the
Hamlet of Newtonville.
6. 3 . 3 Laidlaw has indicated that it accepts all financial
responsibility for the design and construction of the
forcemain and for the design and allocation of treatment
capacity. Laidlaw has also indicated that, with the
cooperation of the Town and the Region, the forcemain could
be oversized to accommodate the needs of both the residents
of Newtonville and Laidlaw. Otherwise, the costs associated
with any extension of sanitary sewers to the hamlet would be
the responsibility of the Region.
REPORT NO. : PD- 31 -92 PAGE 6
7 . SUPPORTING TECHNICAL DOCUMENTS
7 . 1 A technical report in respect of the proposed leachate
forcemain, prepared by Henderson Paddon and Associates Limited
for Laidlaw, was submitted in support of the Official Plan
Amendment application. The Report is dated August 9, 1989 and
therefore predates Laidlaw's withdrawal of the leachate
forcemain application as it relates to the Infill proposal at
their existing landfill site.
7 . 2 The Report notes that, to protect the environment, namely
Graham Creek, Laidlaw wishes to pipe the leachate to the
Graham Creek W.P.C.P. in Newcastle Village which has an
outfall to Lake Ontario. Oversizing of the forcemain is
proposed to serve both the existing landfill site with the
proposed infill and the proposed major expansion.
7 . 3 The Report also noted that route selection studies were
undertaken which involved the evaluation of eleven separate
possible routing alignments. The various alternatives were
evaluated based on engineering criteria, environmental
considerations and social impacts.
7 . 4 The following alternatives to the leachate forcemain were also
considered: on-site leachate treatment, and trucking leachate
by tanker trunk to the Graham Creek W.P.C.P. or other
treatment plants. The Report indicated that both alternatives
were felt to be inferior to the forcemain alternative due to
increased risk to the environment, and other undesirable
impacts such as increased truck traffic.
8 . PREVIOUS REPORTS AND RESOLUTIONS
8 . 1 Resolution # GPA-433-89
8 . 1. 1 On May 15, 1989 , Committee considered a letter from Henderson
Paddon and Associates which requested, on behalf of Laidlaw,
the Town's permission to construct and operate the forcemain
in part along Town-owned road allowances. Committee, acting
�: 6
REPORT NO. : PD- 31 -92 PAGE 7
as Council, adopted the following resolution:
" WHEREAS the firm of Henderson, Paddon and Associates
Limited, on behalf of Laidlaw Waste Systems Limited, by
letter dated April 26, 1989, has applied for permission
to construct and operate a forcemain from the Laidlaw
Site to the Graham Creek Water Pollution Control Plant
in part along Town-owned road allowances; and
WHEREAS the Town Council has resolved on several previous
occasions that it is opposed to any proposal to expand
in any way the existing capacity of the Laidlaw Site;
NOW THEREFORE BE IT RESOLVED FORTHWITH BY THE COUNCIL OF
THE CORPORATION OF THE TOWN OF NEWCASTLE:
1. THAT the request of Henderson, Paddon and Associates
Limited on behalf of Laidlaw Waste Systems set out
in the letter addressed to the Town dated April 26,
1989, be refused; and
2 . THAT Mr. F. Ford, of the firm Henderson, Paddon and
Associates Limited, and Laidlaw Waste Systems be so
advised. "
8 . 2 Regional Planning Commissioner's Report 90-80
8. 2 . 1 Regional Planning Committee considered this report at its
meeting of April 10, 1990. The Report noted that the design
for the expansion of the Graham Creek W.P.C.P. had been
started. The proposed expansion is intended to accommodate
urban development as part of the Newcastle Village Urban Area.
In view of the large number of proposed subdivisions in
Newcastle and the proposed urban area expansion being
considered in the Regional Official Plan Review process, it
is proposed to oversize the plant capacity regardless of
Laidlaw's request. If and when the Official Plan Amendment
application for sewage capacity is approved, Laidlaw would be
required to pay for an appropriate amount of capacity cost.
The Report noted that any reallocation of sewage capacity to
Laidlaw would reduce the capacity available for urban
development resulting in the advancement of further expansions
to the plant.
17
REPORT NO. : PD- 31 -92 PAGE 8
8 . 2 . 2 The Report recommended that Laidlaw be advised that the
consideration of the allocation of sewage capacity within the
Graham Creek W.P.C.P. to their landfill proposals cannot be
considered until the related Official Plan Amendments have
been dealt with by Regional Council. Planning Committee
adopted the Report's recommendation which was subsequently
endorsed by Regional Council on April 18 , 1990.
9 . AGENCY COMMENTS
9 . 1 The subject Official Plan Amendment application was circulated
by the Region of Durham Planning Department to various
agencies for comment.
9 . 2 The following Agencies indicated that they had no comments on
or no objection to the proposed amendment:
C.P. Rail
Ganaraska Region Conservation Authority
9. 3 The Region of Durham Department of Health Services recommended
approval of the proposed amendment, but further noted that
their comments are restricted to on-site sewage disposal
rather than environmental concerns regarding the landfill.
9.4 C.N. Rail offered no objection in principle to the Official
Plan Amendment, but requested that detailed Design Drawings
for the forcemain crossing of their line be provided. They
also noted that, due to the volume of rail traffic on this
rail line, an open cut installation should not be considered
as indicated in the Report.
9 . 5 The Ministry of Transportation indicated that detailed plans
must be submitted to their office to evaluate the impact of
the forcemain on their Highway No. 2 right-of-way. Issues
regarding the future responsibility of the forcemain must be
resolved prior to the issuance of any permits from the
Ministry.
REPORT NO. : PD- 31 -92 PAGE 9
9 . 6 The Ministry of Natural Resources indicated that they had no
objections to the principle of the amendment, but noted that
any concerns they may have regarding the actual use of the
land for the leachate collection system and the location of
the forcemain will be addressed through the review of the
conceptual plan and stormwater management plan.
9 . 7 . 1 The Region of Durham Works Department, in comments dated
November 2 , 1989, indicated that the proposed leachate
collecting system as submitted, is technically feasible. The
cost for providing the additional facilities to handle the
landfill leachate, such as an equalization tank and additional
Sewage Treatment Plant capacity, is estimated to be
$510, 000. 00, including engineering fee.
9 . 7. 2 The Works Department further noted that the applicant must
post an irrevocable Letter of Credit for $510, 000. 00 at this
stage to allow the Department to proceed with the design of
the plant including the aforementioned additional facilities.
In the case that this project cannot proceed due to the denial
of the official plan amendment, they will return $350, 000. 00
of the posted Letter of Credit and the remainder would be
retained to cover the engineering cost of design and redesign
of the Graham Creek W.P. C.P.
9 . 7 . 3 The Works Department concluded that they have no objection to
the servicing aspects of the proposal subject to the
aforementioned financial conditions being satisfied.
9. 8 The Ministry of the Environment noted in comments dated June
28 , 1990, that further investigation into the status of the
allocation of capacity for the forcemain with the Region of
Durham Works Department indicated that allocation of capacity
for the forcemain expansion plans has not been provided. The
Ministry indicated that, in light of the Works Department
comments, the application would appear to be premature.
5 91 9 19
REPORT NO. : PD- 31 -92 PAGE 10
10. PUBLIC SUBMISSIONS
10. 1 A large number of submissions in respect of the leachate
forcemain have been received (Attachment No. 3) . The following
is a summary of the concerns expressed by the public:
the central issue in the review of the forcemain, Infill
and Expansion proposals is the suitability of the Laidlaw
site for a landfill;
consideration of the forcemain proposal is premature
pending resolution of the Infill and Expansion proposals
under the Environmental Protection Act and the
Environmental Assessment Act respectively;
the need for the leachate forcemain if the leachate
problem at the landfill site is not supposed to be
serious;
by proposing the forcemain, Laidlaw is admitting the site
has inadequate natural attenuation;
the forcemain should be subject to a full Environmental
Assessment under the Environmental Assessment Act;
the Ministry of the Environment had declined the request
to have the proposed forcemain subject to the
Environmental Assessment Act;
disposing of the leachate in Lake Ontario is not
acceptable;
the proximity of the outfall for the Water Pollution
Control Plant to the water intake for Newcastle Village;
the Graham Creek Water Pollution Control Plant does not
have the facilities to treat the toxins in the leachate
from the Laidlaw landfill site.
11. STAFF COMMENTS
11. 1 Laidlaw has indicated that the proposed forcemain and the
proposed expansion to the Graham Creek W.P.C.P. are
respectively intended to transport and treat the leachate
generated at the proposed Major Expansion of their landfill
site. However, as of the writing of this report, Laidlaw has
not submitted the applications for Official Plan Amendment or
> 7 2U
REPORT NO. : PD-31 -92 PAGE 11
rezoning to the Region or the Town, nor has the company
provided any indication as to when these applications will be
forthcoming. Regional Works Staff have recently advised that
Laidlaw have not submitted the requested Letter of Credit.
As well, the capacity allocation requested by Laidlaw has not
been incorporated into either the design plans for plant
expansion or the Class Environmental Assessment.
11. 3 Ministry of the Environment Staff have also advised that they
have not had a recent indication from Laidlaw as to when the
draft Environmental Assessment documents in respect of the
proposed Major Expansion will be submitted.
11. 4 It is apparent, from the review of the agency comments and
the submissions made by the public in respect of the subject
Official Plan Amendment, that consideration of the proposed
leachate forcemain and the allocation of capacity in the Water
Pollution Control Plant to treat the leachate cannot be
considered in isolation from Laidlaw's Major Expansion
proposal. Given the uncertainty as to the timing of the
required applications to amend Regional and local planning
documents in respect of the Major Expansion, as well as the
Draft EA documents, there does not appear to be any compelling
reason to keep the Official Plan Amendment application file
in respect of the leachate forcemain open.
Respectfully submitted, Recommended for presentation
to the Committee
Franklin Wu, M.C. I.P. Lawren Kotseff
Director of Planning Chief d nistrative
and Development Officer
JAS*DC*FW*df
8 January 1992
Attachments
# 1 Laidlaw lands & proposed forcemain route
# 2 Draft Official Plan Amendment submitted by Laidlaw
# 3 Summary of Public Submissions
5n
REPORT NO. : PD- 31 -92 PAGE 12
Interested parties to be notified of Council and Committee's decision:
Mr. Michael J. Pullen, P.Eng. Mrs. Helen MacDonald
Laidlaw Waste Systems Ltd. R.R. # 1
3410 South Service Road Newtonville, Ontario
P.O. Box 5057 LOA 1J0
Station A
Burlington, Ontario
L7R 3Y8
Mr. John McDermott Mrs. J.A. Metcalfe
McDermott & Associates Limited R.R. # 3
Pickering Corporate Centre Newcastle, Ontario
1305 Pickering Parkway LOA 1H0
Suite 406
Pickering, Ontario
L1V 3P2
Mr. Normunds Berzins, Chairman Mr. Glenn Stapleton
Committee of Clarke Constituents 2100 Stapleton Road
Box- 20028 R.R. # 8
Newcastle, Ontario Newcastle, . Ontario
L1B 1M3 L1B 1L9
Mr. John Veldhuis, Chairman Mrs. Patricia Vickery
Port Granby-Newcastle 43 Thorncliffe Park Drive
Environment Committee Apt. 712
R.R. # 1 Toronto, Ontario
Newtonville, Ontario M4H 1J4
LOA 1J0
`e�
PROPOSED LEACHATE C�KEO
M."tf PUMPING STATION EXISTING
LANDFILL
SITE
115 PROPOSED F
MAJOR `-
EXPANSION
3
C cif Q
17 O
z 18
� � d
w
�. J
•� a.
h
fV co 2
C1� NEWCASTLE HIGHWAY No.2 NEWTONVILLE
o
a
O
HIGHWAY 401
1 401
z
in a
METC ST. R- CONCESSION ROAD 1
GRAHAM CREEK
WATER POLLUTION
CONTROL PLANT n
S
PROPERTY OWNED BY LAIDLAW
uuuuun� PROPOSED LEACHATE FORCEMAIN ROUTE
Lake Ontario C
Attachment No. 2
DRAFT OF PROPOSED AMENDMENT TO THE REGION OF
DURHAM OFFICIAL PLAN.
(AS PROPOSED BY LAIDLAW)
THAT Section 14, entitled "Utilities and Services" forming part of
the Official Plan of the Regional Municipality of Durham be amended
insofar� as is necessary to incorporate a new subsection which shall
read as follows:
"Notwithstanding any other provision of this Plan to
contrary, a reserve capacity based on an average
discharge of 64 , 000 gallons per day and a peak flow of
270,000 gallons per day shall be incorporated into the
design capacity of the Graham Creek water pollution
control plant in Newcastle in excess of the design
population equivalent delineated on Map "C" to this Plan.
This capacity shall be allocated to the treatment of
leachate from the Landfill Operation located in part of
Lots 11 and 12 of Concessions 2 and 3 of the Town of
Newcastle and shall not be used to sustain development
beyond the design population equivalent indicated on Map
"C".
It shall further be the policy of this Plan to provide
for -the construction of a sewage forcemain from the
Landfill Operation in part of Lots 11 and 12 , Concessions
2 and 3 in the Town of Newcastle to the Graham Creek
water pollution control plant. The forcemain shall be
constructed to provide for the treatment of leachate from
the aforementioned landfill site only and shall not be
designed to accommodate the servicing of existing
development or new development of lands adjacent the
forcemain.
Notwithstanding the foregoing, where the sewage forcemain
and any related facilities are owned and operated by the
Regional Municipality of Durham, Regional Council may
provide for the oversizing of the forcemain and related
facilities to provide for the future extension of
sanitary sewers to . the Hamlet of Newtonville. Such
oversizing shall not be used to provide for the servicing
of existing development or the development of lands
adjacent the forcemain outside of the Newcastle Small
Urban Area or the Hamlet of Newtonville. "
r 2,`t
l
Attachment No. 3
PUBLIC SUBMISSIONS REGARDING LEACHATE FORCEMAIN PROPOSAL
Mr. David Scott on behalf of the Committee of Clarke Constituents
1) Letter to the Region of Durham (October 10, 1989)
the central issue in the review of the forcemain, Infill and
Expansion proposals is the suitability of the Laidlaw site
for a landfill
by proposing the forcemain, Laidlaw is admitting the site
has inadequate natural attenuation
consideration of the forcemain proposal is premature pending
resolution of the Infill and Expansion proposals under the
Environmental Protection Act and the Environmental Assessment
Act respectively
2) Letter to the Provincial Minister of the Environment (October 13,
1989)
objecting to the proposed disposal of leachate from the
Laidlaw site in Lake Ontario
requesting that the forcemain be subject to a full
Environmental Assessment under the Environmental Assessment
Act
3) .Letter to Premier David Peterson (March 15, 1990)
expressed concern that the Ministry of the Environment had
declined the request to have the proposed forcemain subject
to the Environmental Assessment Act, and that the Ministry
was apparently expediting its review of Laidlaw's applications
Mrs. Helen MacDonald
1) Letter to Laidlaw (July 19 , 1989)
objected to the proposed disposal of leachate in Lake Ontario, and
the proximity of the proposed forcemain to the water intake for
Newcastle Village
2) Letter to the Region of Durham (October 11, 1989)
objecting to the proposed disposal of leachate from the
599 � 5
Laidlaw site in Lake Ontario, and indicating that the leachate
forcemain proposal should not be dealt with until the Infill
and Expansion proposals have been resolved
Mrs. Patricia Vickery
1. Letter to Town (received October 4 , 1989)
indicated concern that the Graham Creek Water Pollution
Control Plant does not have the facilities to treat the toxins
in the leachate from the Laidlaw landfill site
Mr. Glenn Stapleton
1. Letter to the Town (October 4, 1989)
questioned why Laidlaw is proposing a leachate forcemain if
the leachate problem at the landfill site is not supposed to
be serious
Mrs. J.A. Metcalfe
1. Letter to the Region of Durham (September 26, 1989)
questioned why Laidlaw is proposing a leachate forcemain if
there is no supposedly leachate problem at the landfill,
questioned the ability of the Graham Creek Water Pollution
Control Plant to treat the toxins in the landfill
Mr. John Veldhuis, Port Granby-Newcastle Environment Committee
1. Letter to the Region of Durham (October 12 , 1989)
stated that disposing of the leachate in Lake Ontario is not
acceptable
both the Infill and Expansion proposals should be examined
under the Environmental Assessment Act prior to the leachate
forcemain proposal being considered
`' � Z6
THE CORPORATION OF THE TOWN OF NEWCASTLE
Memorandum
JAN 20 3 19 PN 192
To: Patti Barrie, Town Clerk
From: Janice Szwarz, Senior Planner, Strategic Planning
Date: 20 January 1992
Subject: Interested Parties - Report PD-25-92 (Laidlaw Infill)
and Report PD-3.1-92 (Laidlaw Leachate Forcemain)
Please make the following changes to the List of Interested Parties for the following
reports:
Report PD-25-92
1. Contact person at TransCanada Pipelines is changed to:
Mr. Fraser Mowat
2. Please add:
Mr. Paul T. Hasoulas
55 Limevale Crescent
Scarborough, Ontario.
M1 E 2K5
Report PD-25-92 and Report PD-31-92
1. Suite # for McDermott & Associates: please change from #406 to #704.
2. Please add the following name:
Mr. John Chipman
Fasken Campbell Godfrey -
Barristers and Solicitors
Toronto Dominion Bank Tower
P.O. Box 20
Toronto-Dominion Centre
Toronto, Ontario.
M5K 1 N6
Thank you for your attention to this matter.
Janice.
JAS*df