Ministry review of the Elliot Lake Waste Management Plan environmental assessment

Environmental Assessment Act, R.S.O. 1990, Subsection 7(1)

This Ministry Review is subject to the provisions of Ontario Regulation 616/98 which sets out a deadline for the completion of this document. The deadline for the completion of the Review was April 29, 2016. Pursuant to Subsection 7(3) of the Environmental Assessment Act, a five-month extension to the deadline for completing the Review was granted by the Director to allow time for the proponent to submit amendments to the Environmental Assessment, and for the Ministry of the Environment and Climate Change (MOECC/ministry) to review the amendments.

The Review documents the ministry’s evaluation of the Environmental Assessment and takes the comments of the government agencies, the public and Aboriginal communities into consideration.

Executive Summary

Who

The City of Elliot Lake

What

Ministry Review of an amended Environmental Assessment (EA) for the proposed undertaking which is to expand the active fill area at the City of Elliot Lake Municipal Landfill site in a southeast direction by approximately 0.79 hectares, which represents an increase of about 13% to the total landfilled area. This expansion would provide 300,000m³ (375,000m³ with final cover) of capacity over a 25-year time period for solid, non-hazardous waste, after municipal waste diversion.

When

The EA was submitted on February 5, 2016 and was subject to a seven-week public and agency comment period. An amended EA was submitted on July 13, 2016 to address EA deficiencies identified by the ministry. The comment period for this Ministry Review and amended EA is from November 18 to December 23, 2016.

Where

The City of Elliot Lake Municipal Landfill Site is located on Scott Road (Treatment Plant Road). It is a 15.7 hectare (ha) site with a landfill area of 7.41 ha.

Why

The City of Elliot Lake Municipal Landfill began operations in 1982. It is expected to reach capacity in 2020. The landfill expansion is part of a long-term strategy to manage the City of Elliot Lake’s residual solid waste over a 25-year planning period.

Conclusions

This EA was prepared generally in accordance with the approved Terms of Reference and the Environmental Assessment Act. The EA process was transparent and logical, and the EA report contained sufficient information to assess the environmental effects of the proposed undertaking

Environmental assessment process

The Environmental Assessment Act (EAA) provides a proponent-driven planning process designed to incorporate the consideration of the environment by assessing the effects of an undertaking on the environment. In Ontario, the EAA sets out the general contents for the preparation of an Environmental Assessment (EA), as well as the Ministry of the Environment and Climate Change’s (MOECC/ministry) evaluation process. For those proponents and undertakings subject to the EAA, approval under the EAA is required before the undertaking can proceed.

Proponents address a wide range of potential effects on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. Through the EA, the proponent determines, on the basis of the environmental effects, if an undertaking should proceed, and if so, how environmental effects can be managed.

In the EA, the proponent identifies a problem or opportunity, considers alternative ways of addressing the problem or opportunity, evaluates the environmental effects of the alternatives, and selects a preferred undertaking from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with interested stakeholders including government agencies, the public, and affected Indigenous communities to evaluate the alternatives and determine the preferred undertaking. Once the undertaking is approved, the proponent is required to monitor to demonstrate compliance with standards, regulations, and the EAA approval.

1.1 Terms of reference

Completing the EA process involves two separate steps: the Terms of Reference (ToR) and the EA. The first step requires the proponent to prepare and submit a ToR to the ministry for review and approval by the Minister. The ToR is the work plan or framework for how the EA will be prepared.

On March 11, 2009, the Minister approved the City of Elliot Lake’s Waste Management Plan ToR. In the ToR, the City of Elliot Lake (City) described how it would assess the environmental effects of alternatives, and consult with stakeholders and Indigenous communities during the preparation of the EA. In the ToR, the City established the framework for creating a long term (20 to 25 year) waste management plan to guide the disposal of residual solid waste after the application of at-source waste diversion programs. The ToR also included an outline of how the City would:

• Evaluate the alternatives to addressing long term waste disposal needs;
• Identify and evaluate alternative methods for carrying out the proposed undertaking;
• Assess and mitigate the environmental effects of the proposed undertaking; and,
• Consult with the public, interested stakeholders, government agencies, and Indigenous communities during the preparation of the EA.

Environmental assessment

Once the ToR is approved by the Minister, the proponent can proceed to the second step of the EA process and carry out the EA. The EA must be prepared in accordance with the approved ToR and the requirements of the EAA. After the proponent has carried out the EA, including consultation activities, the EA is submitted to the ministry for review and a decision by the Minister.

On February 5, 2016, the City submitted the City of Elliot Lake Solid Waste Management Plan EA to the ministry, and made the EA available for a seven-week public comment period. The comment period ended March 25, 2016. During this period, Indigenous communities and the public had an opportunity to review the EA and submit comments to the ministry. The EA was also circulated for review to the Government Review Team (GRT). The GRT, comprised of federal, provincial and local agencies, reviewed the EA to ensure that the information and conclusions of the EA were valid based on the mandates of each respective agency. All comments received by the ministry during this formal comment period are considered by the Minister before a decision is made about the proposed undertaking.

1.3 Ministry review

The EAA requires the ministry to prepare a review of the EA, known simply as the Ministry Review (Review). The Review is the ministry’s evaluation of the EA. The purpose of the Review is to determine if the EA:

1. has been prepared in accordance with the approved ToR;
2. meets the requirements of the EAA, and,
3. provides sufficient information on the evaluation of alternatives and environmental effects to allow the Minister to make a decision about the proposed undertaking.

In the Review, the ministry outlines whether the information contained in the EA supports the recommendations and conclusions for the selection of the proposed undertaking. Ministry staff, with input from the GRT, evaluate the technical merits of the proposed undertaking including the anticipated environmental effects from the undertaking, and proposed mitigation measures. In the Review, the ministry also provides an overview and analysis of public, agency and Indigenous community comments on the EA and the proposed undertaking.

The Review itself is not the decision making mechanism. The Minister considers the conclusion of the Review when making a decision. The Minister’s decision on the undertaking described in the EA will be made following the end of a five-week Review comment period, and is subject to the approval of the Lieutenant Governor in Council.

The Review comment period allows the GRT, the public and Indigenous communities to see how their concerns regarding the EA and the proposed undertaking have been considered. During the Review comment period, anyone can submit comments on the EA, the proposed undertaking, and the Review. In addition, anyone can request that the Minister refer the EA, or any matter relating to the EA, to the Environmental Review Tribunal for a hearing if he or she believes that there are significant outstanding environmental effects that the EA has not addressed. Requests for a hearing can only be made during this comment period. The Minister will consider all requests and determine if a hearing is necessary.

A Notice of Completion of the Review was published in the Elliot Lake Standard indicating that this Review has been completed and is available for a five-week comment period starting November 18, 2016 to December 23, 2016. Copies of the Review have been placed at the same public record locations where the EA was made available, and copies have been distributed to GRT members, and potentially affected or interested Indigenous communities. Members of the public who submitted comments during the EA comment period also received a copy of the Review.

The proposed undertaking

2.1 Background

2.1.1 Landfill site and vicinity

The City of Elliot Lake is located mid-way between Sudbury and Sault Ste. Marie, north of the TransCanada Highway. The City owns and operates the City of Elliot Lake Municipal Landfill Site, which is 1.5km south of the City of Elliot Lake and 1.0km north of Esten Lake in the Township of Esten (see Figure 1). The landfill currently accepts 12,000m³ (about 6,700 tonnes) of residential, industrial, commercial and institutional (IC&I) solid waste each year. The landfill began operation on October 12, 1982 and is expected to reach its approved capacity of 842,000m³ in 2020.

The facility operates under the Amended Provisional Certificate of Approval Number A560810 issued on October 31, 2006. The total approved site area is 15.7 hectares (ha) with an active landfill area of 7.41ha. Major site components at the landfill consist of a berm at the toe of the landfill to pond leachate, and a drain system between the berm and landfill that conveys leachate via gravity to an elevated sand filter bed (with a surface area of 1,500m²) at the western part of the site. There are no significant compliance issues at the site.

The existing landfill is in a relatively isolated area surrounded by forest that is designated as parkland in the City of Elliot Lake’s Official Plan. The closest facility to the landfill is the City’s municipal wastewater treatment plant which is less than a kilometre away to the southeast. The Elliot Lake Municipal Airport is approximately 6km to the west of the landfill site. The City has determined that the expansion and continued operation of the site will not pose a risk to the airport.

The physical geography of the landfill site controls the groundwater and surface water flow. The bedrock beneath the site slopes in two directions. The western part of the site slopes westward towards marshland adjacent to First Creek - a watercourse that joins Angel Creek prior to flowing into Esten Lake. As a result, surface water and groundwater movement at this part of the site follows this bedrock slope west towards the marshland. The eastern part of the site slopes eastward towards the access road and site entrance. Surface water at the eastern part of the site is collected via a surface drainage channel near the site entrance. This channel conveys surface water southward to a stream along the north side of the municipal wastewater treatment plant that eventually drains into Esten Lake to the southwest.

The landfill was designed as a natural attenuation type of disposal facility which relies on natural soils to filter, dilute, or otherwise prevent leachate from contaminating groundwater. In 1998, the City installed a sand filter treatment system, consistent with the ministry’s landfill standards contained in Ontario Regulation 232/98 (Landfilling Sites), on the west side of the site as a preventative measure to avoid landfill-related impacts on groundwater and surface water.

2.1.2 Existing waste management

The City of Elliot Lake provides waste collection services to a population of approximately 11,200 people. The City of Elliot Lake currently offers the following solid waste management programs to its residents:

• Weekly garbage collection;
• Seasonal leaf and yard waste collection;
• Bi-weekly two-stream recycling collection (for fibres and containers);
• A recycling depot;
• Household Hazardous Waste Drop-off Days; and,
• Electronic waste depot.

The City also hosts an annual Spring Clean-up Week during the month of May which allows residents to set out large items and debris that do not normally qualify for collection during the year. Approximately 22% of residential solid waste is currently being diverted from the landfill. This diversion rate is below the provincial average for residential waste diversion which was 48% in 2014 according to Waste Diversion Ontario. The annual diversion rate for IC&I waste generated within the City of Elliot Lake is unknown.

2.1.3 Solid waste management plan

In 2012, the City completed a review of its existing residential waste management programs and services, and assessed future waste disposal needs. A report titled City of Elliot Lake Solid Waste Management Plan (SWMP) published in 2012 documented the recommended options for long term solid waste diversion and disposal. The SWMP also presented a preliminary evaluation of alternative waste disposal options that guided the preparation of the EA. Recommendations in the SWMP to increase waste diversion included:

• Expansion of the existing leaf and yard waste composting program, allowing residents to drop off leaf and yard waste at a municipal depot;
• Development and implementation of a comprehensive waste management promotion and education strategy;
• Design and implementation (in phases) of a source-separated organics collections and composting program; and,
• Optimization of the existing blue-bin recycling program.

According to the analysis, an additional 33% of the City’s residential waste can be diverted from landfill with the implementation of the above-mentioned recommendations to bring the City’s residential waste diversion rate to approximately 55%. However, the City indicated that while diversion programs will help the City divert more waste from the landfill in the long term, the required time to implement the programs and to bring them up to maturity will not significantly delay the closure of the current landfill, which is why additional waste disposal capacity is needed.

The SWMP only addresses residential solid waste diversion, and does not address the diversion potential of non-residential solid waste, even though non-residential IC&I and construction and demolition waste accounts for approximately 62% of the total waste disposed annually at the City’s landfill. The SWMP states that IC&I waste management is outside the City’s jurisdiction, and was therefore not considered in the plan.

2.1.4 Waste diversion considerations

The Minister introduced the draft Waste-Free Ontario Strategy in November 2015, and new waste diversion legislation, Bill 151, Waste-Free Ontario Act (short title), which was passed by the Ontario Legislature in June 2016. The objectives of the Waste-Free Ontario Act and draft Strategy are to

• Boost recycling in the IC&I sector;
• Lower recycling costs while giving consumers access to more convenient recycling options;
• Reduce greenhouse gases from landfills and the amount of organic materials going to landfills; and,
• Require producers to take full responsibility for products and packaging.

The City has been reviewing how it can implement the recommendations in its SWMP in an economically feasible manner to increase residential waste diversion to approximately 55% based on a recyclables capture rate of 70%. The capture rate is the percentage of recyclable materials that is diverted from landfill and captured in the recycling stream; whereas the diversion rate is the percentage of all outgoing materials (i.e. waste and recyclable materials) that is diverted from landfill and recovered.

The annual solid waste disposal rate in the City is expected to decrease over the next 25 years, as population continues to decline and as residential waste diversion programs mature. The City forecasts that the current waste disposal rate of approximately 6,700 tonnes per year (12,000m³) will decrease to approximately 5,300 tonnes per year (9,500m³) by 2038 based on current population and residential waste diversion projections.

The City of Elliot Lake is seeking approval for an additional 300,000m³ of disposal capacity at the existing landfill (375,000m³ with final cover) over a 25-year period which assumes a worst-case scenario disposal rate of 12,000m³ per year. The City’s position is that additional waste reduction or diversion efforts over the 25-year planning period will benefit the community by increasing the length of time the City can provide waste disposal services for the health and safety of its residents at the existing landfill before it has to again consider alternate disposal options.

Ontario municipalities are setting ambitious goals for solid waste diversion that are well beyond the national average of 22%. To achieve these goals, municipalities are encouraging and working with the IC&I sector to develop waste reduction programs. As over 60% of the solid waste generated within the City of Elliot Lake is from non-residential sources, the introduction of policy and program initiatives in the City’s SWMP to promote IC&I waste diversion would have a strong potential to decrease solid waste disposal rates and further prolong the operating life of the existing landfill. If the EA is approved, the ministry may include a condition of approval that requires the City to develop strategies and programs to encourage waste reduction and diversion in the IC&I sector.

The ministry is also considering a condition of approval which requires the City to decrease the annual solid waste disposal rate of 12,000m³ by continually striving to increase waste diversion rates through the implementation of the recommendations in the SWMP. The annual solid waste disposal rate will also be reviewed again by the ministry when the City applies for Environmental Compliance Approvals to expand the landfill, if the EA is approved.

2.2 Description of the preferred undertaking

During the EA process, the City considered five alternatives to the undertaking to address the need for additional waste disposal capacity after the implementation of additional at-source waste diversion efforts. These were:

• Thermal processing;
• Mechanical biological treatment (biological and physical processing);
• Landfill (expansion and new landfill);
• Additional at-source diversion; and,
• Export of waste.

The landfill alternative, in particular the expansion of the existing landfill, was the preferred undertaking, after an assessment of the alternatives from natural, economic/financial, technical, social/cultural, and legal perspectives. Expanding the existing landfill would have the lowest potential for negative impacts to the natural environment and social environments, thereby making this alternative the most socially acceptable to the residents of the City of Elliot Lake. The continued operation of the existing landfill also offers the lowest cost per tonne of waste disposed.

The City considered five alternative methods for expanding the landfill area within existing property boundaries:

• North/south expansion;
• Westward expansion;
• Eastward expansion;
• Southeast expansion; and,
• Vertical expansion.

Expansion of the existing landfill area to the southeast by approximately 0.79ha was the preferred method based on site topography and geography considerations (see Figure 2). The expanded landfill area will have maximum side slopes of 4 horizontal to 1 vertical (4:1) on the west side of the site, and 8:1 at the east side of the site, with a top slope of approximately 5% (see Figure 3).

The perimeter of the new landfill footprint area will include a 1.5m to 2.0m high soil berm with 1:1 side slopes to contain leachate within the expanded area. The leachate will likely be directed to the existing sand filter leachate treatment system situated west of the landfill area. A new leachate system (toe drain, leachate sump pump, and forcemain) would be constructed east of the landfill area if it is determined during design that leachate from the eastern portion of the landfill will drain easterly and not westerly towards the existing sand filter system. Under this scenario, leachate collected from the eastern portion of the site would either be conveyed to the sand filter system or to the City’s wastewater treatment plant. Leachate collection and treatment options will be evaluated in greater detail during design. Activities related to the expansion of the existing landfill including leachate collection and treatment will be subject to Environmental Compliance Approvals (ECAs) under the requirements of Ontario Regulation 232/98 of the Environmental Protection Act.

Figure 1: City of Elliot Lake solid waste management plan EA study area

This map shows the study area boundary (coordinates of the boundary corners: N 5154997, E 359811; N 5154624, E 389229; N 5125816, E 389296; N 5125774, E 360263) and the location of the current landfill site, sewage treatment plant, Elliot Lake municipal airport, and the surrounding municipalities.

View a larger version of this map (PDF)

Figure 2: Preferred undertaking

This map shows the property boundary of the undertaking (CL 2854, Part 1), as well as the boundaries of the existing approved limit of fill and the proposed expanded limit of fill. The fill boundaries are located approximate 300m from the northern property boundary, 345m from the eastern property boundary, 580m from the southern property boundary (Esten Lake shore), and 880m from the western property boundary.

View a larger version of this map (PDF)

Figure 3: Proposed landfill expansion waste contours and cross section

This figure shows the elevation contours of the proposed landfill from both an overhead and cross section point of view.

View a larger version of this map (PDF)

Results of the ministry review

The Review provides the ministry’s analysis of the EA. The Review is not intended to summarize the EA, nor present the information found in the EA. For information on the EA process, please refer to the EA itself. The EA and supporting documentation outlines the EA planning process and demonstrates how the proponent has selected the preferred undertaking.

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry coordinated an analysis of the EA with the GRT that looked at whether the requirements of the ToR have been met. The ministry concludes that the EA has addressed most of the commitments made in the ToR and satisfies the requirements of the EAA.

Appendix A summarizes this analysis and identifies how EAA requirements have been addressed in the EA.

3.1.2 Consultation

One of the key requirements of the EAA is consultation during the preparation of the EA. Consultation is the responsibility of the proponent and must be undertaken prior to the submission of the EA to the ministry, and must be completed in accordance with the consultation plan outlined in the ToR.

During the preparation of the EA, the City carried out a consultation process that shared information on the study and provided opportunities for the public, GRT agencies and Indigenous communities to provide specific or general input. Consultation activities included:

• Establishing and maintaining a stakeholder and Indigenous community contact list;
• Publishing notices in the local newspaper and posting documents on the website to inform the general public of study milestones;
• Conducting an open house for the general public to obtain input on the evaluation of waste disposal options and the selection of the preferred option; and,
• Providing a draft EA for GRT agencies and Indigenous communities to review and comment.

In accordance with the requirements of Subsection 6.1(2) of the EAA, consultation activities are described in Section 13 and documented in Appendix E (Record of Consultation) of the amended EA report.

When the EA is submitted to the ministry, ministry-driven consultation occurs in the form of the seven-week EA comment period. The GRT, the public and affected or interested Indigenous communities are provided with the opportunity to review the EA and to submit comments to the ministry regarding the fulfillment of ToR requirements, the EA itself, and the proposed undertaking.

All comments received by the ministry during the seven-week EA comment period from February 5, 2016 to March 25, 2016 were forwarded to the City for a response. Summaries of all comments and the City’s responses are included in Tables 1 through 3. Copies of the submissions are available in Appendix B.

During the preparation of this Review, the City had the opportunity to amend the EA report based on ministry comments regarding the EA planning process and documentation. The amended EA report that was submitted to the ministry on July 13, 2016, is provided in Appendix C of this Review.

Government Review Team

During the preparation of the EA, the City sought input from members of the GRT including provincial ministries, federal departments, and municipal agencies who: a) may have a potential interest in or mandate(s) related to the proposed undertaking; b) issue approvals or permit requirements administered under their respective jurisdictional authorities; and, c) may have potential concerns about the proposed undertaking.

The GRT consisted of the following agencies in addition to the MOECC: Ministry of Natural Resources and Forestry (MNRF); Ministry of Municipal Affairs and Housing (MMAH); Ministry of Health and Long-Term Care (MHLTC); Ministry of Tourism, Culture and Sport (MTCS); Transport Canada; and, Algoma Public Health. The City consulted with the GRT through written and electronic correspondence to confirm their interest in the project and to request a review of the draft EA report. A summary of the consultation process carried out during the preparation of the EA with members of the GRT is provided in Section 13 of the amended EA.

The City provided the draft EA to the GRT for review and comment between June 22, 2015 and July 17, 2015. Comments from the GRT on the draft EA and the City’s responses can be found in Appendix E (Record of Consultation) of the EA.

Following the formal submission of the EA to the ministry, GRT members were provided copies of the EA for final review during the seven-week EA comment period from February 5 to March 25, 2016. All comments received by the ministry during the EA review period were forwarded to the City for a response (see Table 1).

Public consultation

The objective of public consultation is to inform and seek input from interested members of the public on the EA process and the proposed undertaking. A detailed summary of the public consultation process carried out during the preparation of the EA can be found in Section 13 of the amended EA.

Members of the public, which includes the general public, communities, local organizations, interest groups and property owners, were provided with an opportunity to participate and provide input during the preparation of the EA. The City carried out public consultation in a variety of ways including hosting a public open house, publishing newspaper notifications of EA milestones, and posting the final EA to the City of Elliot Lake landfill web page. Prior to the formal preparation of the EA, members of the public also had an opportunity to comment on waste diversion and waste disposal option recommendations at two open houses held during the development of the SWMP.

In the ToR, the City stated a commitment to form a citizen-based Site Liaison Committee (SLC) consisting of resident, agency and other interested representatives to review and provide input on site-specific studies. The purpose of the SLC was to report to the Public Services Committee and City council on matters related to a new waste disposal facility site. The City indicated that a SLC was not formed due to a lack of interest since the SWMP recommended landfill expansion as the preliminary preferred waste disposal option rather than a new site. The City reported directly to its Public Services Committee for project updates and briefings instead.

Members of the public had the opportunity to review and comment on the EA during the seven-week EA comment period. During this time, only one member of the public, a resident of the City of Elliot Lake submitted written comments. The member of the public provided suggestions to the City for installing an organic waste composting facility within the existing landfill site, moving public works operations towards net zero carbon emissions, and developing climate change action plans that include waste reduction education. The ministry forwarded the comments to the City for a response (see Table 2).

Indigenous community consultation

In addition to public consultation, proponents are required to consult with Indigenous communities that have credibly asserted Aboriginal or treaty rights that may be negatively affected by the project. Indigenous peoples include First Nations, Inuit, and Métis peoples of Canada.

During the preparation of the EA, the City contacted Indigenous and Northern Affairs Canada, the Ontario Ministry of Aboriginal Affairs (now the Ministry of Indigenous Relations and Reconciliation), and the MOECC for assistance with developing a list of Indigenous communities to be consulted in the EA process.

Indigenous communities were contacted at key milestones during the preparation of the EA and were provided with a copy of: the Notice of Commencement; the draft EA; the Notice of Submission; and, a copy of the final EA report.

The following Indigenous communities were identified by the MOECC as having a potential interest in the proposed undertaking. These communities received the Notice of Submission and a hard copy of the final EA:

• Mississauga #8 First Nation;
• Sagamok Anishnawbek First Nation;
• Serpent River First Nation;
• Métis Nation of Ontario (MNO) North Channel Métis Council;
• MNO Historic Sault Ste. Marie Métis Council; and,
• Bar River Métis.

The MOECC followed up with each of the six Indigenous communities to confirm receipt of the final EA. With the exception of the MNO Historic Sault Ste. Marie Métis Council, which did not respond to the MOECC’s follow-up emails or phone calls, all of the Indigenous communities confirmed receipt of the final EA. The MOECC did not receive any formal comments from Indigenous communities on the EA during the seven-week inspection period.

Ministry conclusions on the consultation program

The consultation activities carried out generally met the commitments outlined in the approved ToR. The consultation plan and elements of the communications strategy in the ToR were specifically developed to address issues surrounding the selection of a new disposal site had this alternative been considered as the preferred undertaking. Since the preferred undertaking determined from the EA process is the expansion of the existing municipal landfill site, the scope of the consultation activities completed during the EA was less extensive than the scope outlined in the ToR. Despite this, the ministry believes that the City provided sufficient opportunities for the public, interested stakeholders and Indigenous communities to provide input during the preparation of the EA.

3.1.3 Conclusion

The ministry is satisfied that the consultation carried out by the City meets the requirements of the EAA and was completed generally in accordance with the approved ToR.

3.2 EA Process

EA is a planning process that requires a proponent to identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the potential effects of alternatives against select criteria, and to select a preferred alternative. The City carried out an EA to identify and address ways to provide the City with a long term solution for managing residual solid waste over a 25-year planning period because the existing municipal landfill will reach capacity by 2020.

The study area for the EA is the area within the municipal boundaries of the City of Elliot Lake serviced by the municipal landfill. The City reviewed background information within this municipal (regional) study area, including an assessment of the municipality’s long term solid waste disposal needs and natural environment features. The City also carried out technical studies for the existing landfill site (also known as the local study area) which included a natural heritage inventory, and a groundwater and surface water impact assessment.

The City followed a traceable process to select landfill expansion as the preferred undertaking. In the EA, the City evaluated both alternatives to the undertaking, and alternative methods for implementing the preferred landfill expansion undertaking. Below is a summary and ministry evaluation of the process the City followed, including the study area(s) considered, and the method used for assessing alternatives and environmental effects.

3.2.1 Alternatives assessment

Alternatives to the undertaking

The City assessed post-diversion, solid waste disposal alternatives (thermal processing, landfilling, waste export etc.) following the methodology outlined in the ToR. Alternatives presented in the ToR were further refined in the EA. Biological and physical processing alternatives were combined as one alternative, mechanical and biological treatment, and the landfilling alternative was separated into two alternatives: landfill expansion, and a new landfill site. Additional at-source diversion, although identified as an alternative to the undertaking in the ToR, was not included in the screening of alternatives since this was already assessed in the SWMP. Minor modifications to assessment approaches and the addition of alternatives or evaluation criteria during the EA, are permitted according to Section 12 of the ToR.

The City screened solid waste disposal alternatives using natural, economic/financial, technical, social/cultural, and legal criteria identified in the ToR. Landfill expansion, was selected as the preferred alternative after a qualitative comparison of the potential net effects of each alternative and their relative advantages and disadvantages.

Alternative methods

Following the selection of the preferred alternative, the City identified five alternative methods of carrying out the landfill expansion, and screened them based on geological constraints and feasibility. Two of the five methods: eastward expansion and southeast expansion were carried forward for further evaluation.

The methodology outlined in the ToR for evaluating alternative methods of carrying out the undertaking was intended for the selection of a new waste disposal facility site within the municipal study area. The methodology involved:

1. applying siting constraints to the study area to screen out unsuitable lands;
2. identifying a long list of siting opportunities based on minimum site size requirements;
3. short-listing the alternative sites; and,
4. evaluating the short-listed sites by comparing advantages and disadvantages using the comparative evaluation criteria listed in the ToR.

Even though this methodology was developed specifically for the selection of a new waste facility site, the City made an effort to apply the methodology and comparative evaluation criteria to select the preferred landfill expansion method. A description of how this methodology was applied is provided in Section 8.1 of the amended EA. The comparative evaluation criteria listed in the ToR and two additional natural environment criteria, were used to evaluate the two short-listed landfill expansion alternatives: eastward expansion and southeast expansion. The two additional criteria applied were:

• Geological - Topographical constraints based on underlying geological features; and,
• Geotechnical - Feasibility to manage geotechnical constraints/site considerations.

Geological considerations were the key differentiator in the evaluation of alternative methods. Landfill expansion to the southeast was considered as the preferred method since this option conforms to natural geological surfaces and would therefore require the least amount of excavation; whereas eastward expansion would require excavation into a slope. As a result, the capital cost for southeast expansion would also be lower than the capital cost for eastward expansion.

3.2.2 Assessment of environmental effects

The City evaluated the potential net effects of expanding the landfill area to the southeast within existing property boundaries, and rated the effects from nil to high. The net effects analysis considered the environmental components and associated evaluation criteria listed in the ToR. Overall, the effects of the undertaking were considered to be low for the following natural and social environment components after the application of mitigation measures (in sub-bullets):

• Air quality and noise;
  • Minimize nuisance odours from waste or landfill gas with daily cover
  • Apply dust and noise controls during construction
• Ground and surface water;
  • Continue to use the existing leachate collection and treatment system with additional drainage swales to prevent leachate release to ground and surface water
• Environmentally sensitive areas and species;
  • Site landfill expansion away from the wetland at the western part of the site
  • Time construction activities to avoid breeding periods for Species at Risk (Northern Myotis and Bald Eagle)
• Impacts on vegetation;
  • Plan vegetation clearing within already disturbed areas where feasible
  • Implement measures to protect adjacent vegetation and habitats during clearing
• Archaeological and cultural resources;
  • Retain a licensed archaeologist and notify MTCS if deeply buried archaeological finds are discovered during construction activities
• Traffic impacts (including avian impact on local airports);
  • Maintain the current amount (number of trips) of waste being delivered to landfill
  • Apply daily cover to deter scavenging birds.

The proposed undertaking is not expected to impact the following financial technical, social and legal environment components:

• Operation and maintenance costs;
• Disruption to businesses;
• Compatibility with existing infrastructure;
• Design and operational flexibility;
• Conflicts with land uses;
• Residential areas;
• Parks and recreational areas;
• Institutional facilities; and,
• Properties (acquisition).

The proposed undertaking will cost the City approximately $2.42 million to design and construct.

3.2.3 Key issues

Key issues regarding the EA process and documentation were identified by the ministry during draft EA review and during the EA review comment period. The main EA process-related issue raised by the ministry was that the planning process for the development of the solid waste management plan and the evaluation of alternative methods did not precisely follow the process set out in the approved ToR. The City’s original intention was to develop a long term waste management master plan concurrently with the EA process so that alternatives to the undertaking would be evaluated as integrated waste management systems. Instead, the City completed its SWMP in 2012 which recommended landfill expansion as the preliminary preferred waste disposal option, prior to the formal commencement of the EA in 2013. Another issue was that the summary of stakeholder and Indigenous community consultation in the EA report was not sufficiently detailed.

All comments received during the EA review comment period and the preparation of the Ministry Review, with responses, are enclosed in Appendix B and tabulated in Tables 1 to 3. No key issues were raised by members of the public or Indigenous communities on the EA process.

Planning process

The approved ToR stated that the purpose of the undertaking is to create a long term (20 to 25-year) waste management master plan to guide the management of wastes that remain after the application of at-source waste diversion programs. The long term waste management master plan was intended to be developed as part of the EA process and consider integrated waste management system alternatives. However, the City completed the City of Elliot Lake Solid Waste Management Plan in 2012 before the formal commencement of the EA process. The City’s rationale for completing the SWMP separately was so that the SWMP would provide the technical direction and support for the EA. By completing the SWMP separately, the EA assessed individual waste disposal alternatives after at-source diversion objectives were achieved, rather than considering waste disposal alternatives as part of integrated waste management systems. This modified planning approach differs from the approach referenced in the approved ToR.

The approved ToR stated that the evaluation of alternative methods of carrying out the preferred undertaking would be comprised of a facility site selection process. Therefore, the steps outlined in the ToR for evaluating alternative methods were developed specifically for locating a new processing or disposal facility. Expansion of the existing landfill was a new alternative to the undertaking identified during the preparation of the SWMP after the ToR was approved; and as a result, the steps for selecting a new site were not entirely compatible for evaluating landfill expansion methods. Even though the City made best efforts to apply the comparative evaluation criteria for site selection to assess landfill expansion options; the methodology as outlined in the approved ToR was not followed due to a change in circumstances.

It is possible for circumstances to change as new information arises during the course of the EA. Section 12 of the approved ToR contains provisions to accommodate minor modifications to the approaches and methodologies described in the ToR, which can be undertaken at the direction of the City in consultation with the public and relevant agencies, including the MOECC. Significant changes to methodologies presented in the ToR need the Minister’s approval. The changes to the approved ToR mentioned above did not dramatically change the purpose or the intent of the undertaking, which is to develop a long term plan to manage residual waste after the application of waste diversion programs. Therefore, these changes were considered minor modifications by the City. The City has provided additional clarification and rationale on the changes to the overall EA planning process, in addition to justification for the process it followed for the evaluation of alternative methods in the amended EA report (see Appendix C).

Consultation documentation

The summary of stakeholder and First Nation and Métis consultation in the original EA report submitted to the ministry lacked:

1. a comprehensive description of the consultation activities undertaken as part of the EA;
2. a list of all government agencies and Indigenous communities consulted; and,
3. a summary table of consultation results showing how comments received influenced the City’s EA planning process.

The EA also did not present a chronological narrative of how Indigenous communities were identified nor include documentation in the record of consultation to demonstrate that special efforts were made to follow-up with Indigenous communities after requests for consultation/comments were sent. The City has subsequently addressed these issues in the amended EA report.

3.2.4 Conclusion

Overall, the ministry, in consultation with the GRT, is generally satisfied with the City’s EA process to select landfill expansion in a southeast direction as the preferred undertaking. The identification and evaluation of alternatives to the undertaking was completed in accordance with the approved ToR. This evaluation considered the advantages and disadvantages of the alternatives based on potential net environmental effects after mitigation as required by the EAA. Although the identification and evaluation of alternative methods followed a process that did not precisely follow the methodology outlined in the approved ToR, the preferred undertaking of expanding the existing landfill area to the southeast does keep with the purpose of the EAA for the protection, conservation and wise management of the environment, since landfill expansion within existing property boundaries will have fewer environmental impacts than constructing a waste processing or disposal facility at a new site.

Please refer to Appendix A of this Review for the ministry’s analysis of whether the EA met the requirements of the EAA.

3.3 Proposed undertaking

The proposed undertaking involves the expansion of the existing City of Elliot Lake Municipal Landfill to allow for an additional 300,000m³ of disposal capacity, plus an additional 75,000m³ for final cover, for a total expansion volume of 375,000m³. The existing landfill area will be expanded to the southeast by approximately 0.79ha. This area will be excavated and graded, and waste will be deposited to the contours shown in Figure 3. The new landfill area will be designed so that the flow of leachate is directed towards the existing sand filter leachate management system, and clean surface water is directed away from the new fill area and leachate management system. The perimeter of the expanded fill area will include a soil berm to contain leachate. An access road to the new landfill area, with a grade of less than 10%, will also be constructed.

The steps for carrying out the landfill expansion activities are as follows:

1. Undertake a detailed topographic survey of the landfill area and surrounding area to complete final detailed design drawings;
2. Clear and grub the new landfill area and removal of stockpiles in the area;
3. Construct the perimeter berm, drainage swales and culverts;
4. Grade the landfill area to promote leachate flow to the sand filter system;
5. Relocate access roads and construct new roads;
6. Relocate site facilities and construct new operating/storage areas; and if necessary,
7. Construct a new leachate collection and treatment system.

3.3.1 Key issues

Issues regarding the proposed undertaking were raised by the GRT during draft EA review and during the EA review comment period. Comment submissions and Acknowledgement of Receipt forms from the GRT, the public, and Indigenous communities are included in Appendix B. All comments, along with the City’s responses and the ministry’s level of satisfaction are presented in Tables 1 through 3.

Leachate management

One key area of concern for GRT reviewers is the uncertainty in the approach for the collection and treatment of leachate from the expanded landfill area. In the EA, the City indicates that the additional leachate generated from the expanded landfill will be directed to the existing sand filter, with consideration for the construction of an additional leachate collection system at a later time if deemed necessary. The City expects that the existing sand filter will be able to manage an increase in the quantity of leachate generation on the order of 13%, equivalent to the proposed increase in new landfill area. In the EA, the City also discussed the possibility of constructing a new leachate collection system east of the landfill if it is determined during design that leachate from the expanded area will drain easterly and not westerly towards the existing sand filter system. The leachate collected east of the landfill would either be pumped to the sand filter, or transferred to the nearby municipal wastewater treatment plant by truck or pipe The City indicated in the EA that the details of additional leachate management approaches and design will be confirmed at the ECA application stage under the Environmental Protection Act, if the EA is approved.

The MOECC commented that the existing groundwater monitoring program at the landfill site should be improved to assess the performance of the existing leachate collection system and its ability to handle additional leachate, as well as to monitor the efficacy of the leachate management system after the proposed landfill expansion. Ministry staff also recommended that the City investigate whether there are existing leachate effects on the marshland west of the disposal area adjacent to the sand filter.

The ministry is considering a condition of approval that would require the City to develop and implement an improved groundwater and surface water monitoring program, with specified locations for additional monitoring well installations and sampling points, that will be applied to assess the efficacy of the site’s existing leachate management system and to identify leachate effects on the wetland to the west of the disposal area.

Algoma Public Health commented that if the option of leachate transfer to the wastewater treatment plant is considered a feasible option at a later stage, the City should thoroughly consider the risk and potential occurrence of spills (i.e. pipe leaks or truck spills), the severity of consequences on groundwater and surface water contamination, and develop mitigation measures to reduce risks. If leachate transfer to the municipal wastewater treatment plant is selected, the ministry may include a condition of approval requiring the City to prepare a Spill Contingency and Pollution Prevention Plan that will be submitted as part of the ECA application.

3.3.2 Conclusion

In the EA, the City identified potential environmental effects, mitigation measures, and monitoring programs for managing residual effects from the proposed landfill expansion. The key issue from GRT reviewers concerned the collection and treatment of the additional leachate that will be generated, and the improvement of existing monitoring programs to assess the effectiveness of leachate management system(s) to ensure that groundwater and surface water are protected. An appropriately designed, constructed and maintained leachate management system can mitigate the environmental effects that could reasonably be expected with the proposed landfill expansion. The ministry is satisfied that the leachate management system will be designed and operated to comply with the ministry’s standards and that the environmental effects of the proposed undertaking can be managed through the commitments made in the EA, through conditions of approval, or through additional work that must be carried out by the City in support of future approval applications, if the EA is approved. A condition of approval may be for the City to submit to the ministry for review: information on the feasibility of alternate leachate collection and treatment options, details of the preferred leachate management option, and, updated monitoring plans in support of the ECA application for expanding the landfill.

3.3.3 Climate change considerations

The Ontario Government commits to taking action to reduce greenhouse gas emissions through the Climate Change Action Plan and to move Ontario towards a circular economy through the Waste-Free Ontario Act. The Action Plan also commits to updating the environmental assessment process to account for climate change. This section of the Review assesses how climate change was considered in the EA with respect to:

• climate change mitigation, i.e. reducing the likelihood that climate change will occur or its severity; and,
• climate change adaptation, i.e. ensuring that projects, when built, are prepared for future changes to climate.

Climate change mitigation

The City considered measures to mitigate greenhouse gas emissions in the evaluation of waste disposal alternatives. Measures to reduce greenhouse gas emissions from the proposed landfill expansion included the recovery or reduction of biodegradable waste (organics diversion) and landfill gas capture.

Diverting organic materials such as food and yard waste from landfills by methods such as composting or anaerobic digestion reduces the production and emission of methane, a potent greenhouse gas, to the atmosphere. The City acknowledges in the EA that organics recovery is an option that could be implemented as a future greenhouse gas mitigation measure.

The EA identified the need to assess the feasibility of organic waste recovery and landfill gas capture measures on an on-going basis; however, no commitment to do so was made in the EA. The ministry recommends that the City investigate the feasibility of organic waste diversion programs, and explore methods to reduce greenhouse gas emissions during landfill operation. The ministry is also considering including a condition of approval that requires the City to assess the feasibility of diverting organics from the landfill, if the EA is approved.

There is currently no landfill gas collection system at the existing site. The EA indicates that the proposed expanded site will not meet the 1.5 million cubic metre threshold set out in of Ontario Regulation 232/98 under the Environmental Protection Act, to necessitate a system to manage atmospheric landfill gas emissions during site operation and following site closure. Therefore, there was no further discussion on landfill gas capture for greenhouse gas mitigation. As current and future greenhouse gas emissions from the landfill site are unknown, if the EA is approved, the ministry may include a condition of approval requiring the City to assess landfill gas emissions from the expanded landfill site as part of an air emissions and dispersion modelling study that will be submitted to the MOECC as part of the ECA application. Based on greenhouse gas emission estimates, the ministry may also include a condition of approval requiring the City to assess the feasibility of landfill gas management options.

Climate change adaptation

The Code of Practice for Preparing and Reviewing Environmental Assessments in Ontario (2014) states that the EA should attempt to examine the interrelationships between components of the environment and the undertaking, for example, how the project could interrelate with a changing climate over time. The EA report did not identify the potential impacts of extreme weather attributed to climate change on major site components such as the proposed stormwater management system, the sand filter leachate treatment system, nor waste pile slope stability. The ministry recommends that the City assess whether the expanded landfill and associated site components will have the resiliency to withstand impacts from weather events of increased frequency and intensity as a result of climate change, and consider more stringent hydrologic design criteria.

If the EA is approved, the ministry may also impose conditions of approval that require the City to assess whether the proposed stormwater management, and leachate collection and treatment systems, have the resiliency to withstand impacts from weather events of increased frequency and intensity as a result of climate change, in addition to assessing the vulnerability of waste piles to side slope failure.

3.3.4 Source water protection considerations

The City of Elliot Lake Municipal Landfill is not located within or adjacent to any nearby source protection areas that delineate designated vulnerable areas for the protection of municipal drinking water systems such as: Wellhead Protection Areas, Intake Protection Zones, Highly Vulnerable Aquifers, or Significant Groundwater Recharge Areas, according to provincial standards set out under the Clean Water Act.

The existing landfill is in a relatively isolated area with no known active municipal and private drinking water sources. The closest known private well is located 2.2 kilometres away on Esten Drive North, upgradient of the existing landfill site. This well, installed in 1959, has likely been abandoned subsequent to the City’s provision of municipal water to homes and businesses.

A program is currently in place to monitor leachate, groundwater and surface water quality, in accordance with the Amended Provisional Certificate of Approval number A560810 for the landfill site, and Industrial Sewage Works Certificate of Approval number 3-1055-98-996.

Summary of the ministry review

The ministry’s analysis of the amended City of Elliot Lake Solid Waste Management Plan EA is explained in this Review, and concludes that:

• The EA meets the purpose of the EAA;
• The EA was prepared generally in accordance with the approved ToR and the EAA;
• The ministry is satisfied with the consultation opportunities provided;
• All EA process and documentation issues have been addressed through amendments to the EA;
• The EA provides sufficient information about the undertaking and its potential impacts for the Minister to make a decision;
• Issues regarding waste diversion, and climate change mitigation and adaptation, can be addressed through conditions of approval for the EA; and,
• Outstanding concerns regarding leachate management, groundwater and surface water monitoring can be addressed at the ECA application stage.

If an undertaking is approved under the EAA, there are several standard conditions that will be imposed, such as the requirement to conduct and report the results of compliance monitoring and to develop a protocol for responding to complaints received during all phases of the undertaking.

In addition, during the five-week Review comment period and prior to forwarding a recommendation to the Minister about this EA, conditions of approval specific to the landfill expansion undertaking may be proposed to ensure that the environment remains protected. Below is a preliminary list of potential conditions of approval that may be recommended to the Minister for consideration to further support the commitments made in the EA and the purpose of the EAA:

• Conduct a feasibility study of alternate leachate collection and treatment options that identifies the preferred leachate management option for the expanded landfill for submission to the MOECC as part of the ECA application;
• Prepare a Spill Contingency and Pollution Prevention Plan for the municipal wastewater treatment plant leachate transfer option, if selected as the preferred option, to be submitted to the MOECC as part of the ECA application;
• Develop and implement an improved groundwater and surface water monitoring program, to be submitted to the MOECC for review, with specified locations for additional monitoring well installations and sampling points, which will be applied to assess the efficacy of the site’s leachate management system and any leachate effects on the wetland to the west of the disposal area;
• Conduct an air emissions and dispersion modelling report with detailed information on landfill gas emissions, fugitive dust, and odour for the expanded landfill site to be submitted to the MOECC as part of the ECA application;
• Assess the feasibility for diverting organics and landfill gas management to reduce greenhouse gas emissions;
• Assess whether the proposed stormwater management, and leachate collection and treatment systems have the resiliency to withstand impacts from weather events of increased frequency and intensity as a result of climate change. The assessment will include a discussion of potential contingency plans to address extreme weather events in the future;
• Assess landfill vulnerability to side slope failure due to extreme weather events and identify appropriate mitigation and contingency measures to address such a failure;
• Develop strategies and programs to encourage waste reduction and diversion in the IC&I sector; and,
• Decrease the annual solid waste disposal rate of 12,000m³ by setting targets for implementing the residential solid waste diversion recommendations outlined in the City’s SWMP.

What happens now

The Review will be made available for a five-week comment period. During this time, all interested parties, including the public, the GRT and Indigenous communities can submit comments to the ministry about the proposed undertaking, the EA and/or the Review. At this time, anyone can make a written request that the Minister refer either all or part of the EA to the Environmental Review Tribunal for a hearing if their environmental concerns have not been considered.

At the end of the Review comment period, ministry staff will make a recommendation to the Minister concerning whether the EA has been prepared in accordance with the ToR, if the requirements of the EAA have been met, and whether the proposed undertaking should be approved. When making a decision, the Minister will consider the purpose of the EAA, the approved ToR, the EA, the Review, the comments submitted during the formal comment periods, and any other matters the Minister may consider relevant. The Minister will make one of the following decisions:

• Give approval to proceed with the undertaking;
• Give approval to proceed with the undertaking subject to conditions; or
• Refuse to give approval to proceed with the undertaking.

Prior to making that decision, the Minister may also refer either part of or the entire EA to mediation, or refer either part of or the entire EA to the Environmental Review Tribunal for a decision.

If the Minister approves the EA, approves the EA with conditions or refuses to give approval to the undertaking, the Lieutenant Governor in Council must approve the decision.

5.1 Additional approvals required

If EAA approval is granted, the City will still require other legislative approvals to design, construct and operate this undertaking. Section 12 of the amended EA outlines additional approvals that may be required. These approvals may include:

• An ECA obtained from the MOECC, as per Section 27 of the Environmental Protection Act (EPA);
• An ECA obtained from the MOECC, as per Section 53 of the Ontario Water Resources Act (OWRA) for the leachate collection system that discharges to surface water;
• Permits to Take Water from the MOECC (under the OWRA) for the taking of water greater than 50,000 litres per day;
• Endangered Species Permit from the MNRF (under the Endangered Species Act) for the management of activities related to SAR; and,
• A Clearance Letter from the MTCS (Heritage Act) to confirm that appropriate archaeological studies and mitigation, if required, have been completed for the undertaking.

These approvals cannot be issued until approval under the EAA is granted.

5.2 Modifying or amending the proposed undertaking

The EA Code of Practice identifies a process to address minor and major changes to the undertaking if approval is granted. Any proposed change to the undertaking would have to be considered in the context of the EAA and Ontario Regulation 101/07 (Waste Management Projects), in addition to other mandatory EA requirements before any change to the undertaking can be implemented.

Public record locations

The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office:

Ministry of the Environment and Climate Change
Environmental Approvals Branch
135 St. Clair Avenue West, 1^st floor
Toronto, Ontario

• Tel: 416-314-8001
• Toll-free: 1-800-461-6290
• Fax: 416-314-8452

The Review and Notice of Completion are also available at the following locations:

Ministry of the Environment and Climate Change
Sudbury District Office
1201-199 Larch Street
Sudbury, Ontario
P3E 5P9
Toll-free: 1-800-890-8516

City of Elliot Lake
45 Hillside Drive North
Elliot Lake, Ontario
P5A 1X5
Telephone: 705-848-2287

Elliot Lake Public Library
99 Spine Road
Elliot Lake, Ontario
P5A 3S9
Telephone: 705-848-2287

Making a submission

A five-week public review period ending December 23, 2016 will follow publication of this Review. During this time, any interested parties can make submissions about the proposed undertaking, the Environmental Assessment or this Review. Should you wish to make a submission, please send it to:

Director
Environmental Approvals Branch
Ministry of the Environment and Climate Change
135 St. Clair Avenue West, 1^st floor
Toronto, Ontario
M4V 1P5
Fax: 416-314-8452

Re: City of Elliot Lake Solid Waste Management Plan EA

Attention: Carolyn Lee, Project Officer

All personal information included in a submission – such as name, address, telephone number and property location of requester – is collected, maintained and disclosed by the ministry for the purpose of transparency and consultation. The information is collected under the authority of the Environmental Assessment Act or is collected and maintained for the purpose of creating a record that is available to the general public as described in section 37 of the Freedom of Information and Protection of Privacy Act. Personal information that is submitted will become part of a public record that is available to the general public unless a request is made that personal information remain confidential. For more information, the ministry’s Freedom of Information and Privacy Coordinator can be contacted at 416-327-1434.

Appendix A: Environmental Assessment Act requirements

Analysis of the EA

The EA contains a one-page summary of the environmental assessment. The summary describes some of the matters set out in subsection 6.1 (2) of the Act, in particular:

• Description of the purpose of the undertaking;
• Description of and a statement of the rationale for the undertaking;
• Description of the alternatives to the undertaking;
• Description of the alternative methods considered;
• Description of the environment that will be affected, effects that will be caused, and mitigation measures;
• Description of the evaluation of the advantages and disadvantages to the environment of the proposed undertaking; and,
• Description of consultation about the undertaking by the proponent.

Conclusion: completed

Analysis of the EA

Section 3.2 of the EA contains a list of studies and reports that were reviewed or prepared as part of the EA process. The list includes studies related to the undertaking that were carried out by the proponent.

Conclusion: completed

Analysis of the EA

Section 3.2 of the EA contains a list of studies and reports that were reviewed or prepared as part of the EA process. The list includes reference reports that are related to matters associated with the undertaking, but were not prepared by the proponent.

Conclusion: completed

Analysis of the EA

Two 215mm × 280mm (8.5inch × 11inch) maps of the location of the undertaking were provided in the EA. Figure 1 shows the landfill site relative to the EA study area. Figure 8 shows the landfill expansion area relative to the site’s property boundaries.

Conclusion: completed

Analysis of the EA

The purpose of the undertaking is to provide the City of Elliot Lake with a long term solution of managing the City’s residual solid waste over a 25-year planning period, as stated in Section 2.1 of the EA.

Section 2.2 explains that the existing municipal landfill has operated since 1982 and is anticipated to reach capacity by 2020. The undertaking would provide the city with solid waste disposal capacity to the year 2045.

Conclusion: completed

Analysis of the EA

A reasonable range of waste disposal alternatives to were considered and evaluated. The EA provided a description and rationale of five alternatives to which were:

• Thermal Processing;
• Mechanical Biological Treatment (biological and physical processing);
• Landfill Expansion;
• New Landfill; and,
• Export of Waste.

The do nothing alternative was included in the screening of alternatives in section 6.3 of the EA. The preferred alternative to selected was landfill expansion after a net effects comparative analysis of the five alternatives.

Conclusion: completed

Analysis of the EA

Five alternative methods for expanding the existing landfill were identified in Section 8.2 of the EA:

• North/South expansion;
• Westward expansion;
• Eastward expansion;
• Southeast expansion; and,
• Vertical expansion.

The decision-making process in Section 8.1 of the EA explains how the City of Elliot Lake adapted the methodology for evaluating alternate waste disposal sites in the approved ToR to evaluate alternative landfill expansion methods.

A reasonable range of alternative landfill expansion methods were identified. Alternative landfill expansion methods were screened according to evaluation criteria and indicators. The advantages and disadvantages of the two short-listed methods, eastward expansion and southeast expansion, were compared and landfill expansion to the southeast was selected as the preferred undertaking.

Conclusion: completed

Analysis of the EA

The study area is limited to the municipal boundaries of the City of Elliot Lake. Section 4 of the EA provides a description of the environment within the study area that considers the following environmental components:

• Natural;
• Economic/financial;
• Technical/infrastructure;
• Social/cultural; and,
• Legal/jurisdictional.

The EA also describes the local environment within the existing landfill site in Section 7 to be able to assess environmental impacts and prescribe methods to manage or mitigate the impact of landfill expansion.

Conclusion: completed

Analysis of the EA

Positive and negative effects, and the resulting net effects after mitigation from the five alternatives to the undertaking were discussed in Section 6.4.1 of the EA.

Potential environmental effects of alternatives to the undertaking and alternative methods were evaluated throughout the EA. The EA described the methodology and evaluation criteria used to assess the impacts of both alternatives to the undertaking (waste disposal systems) and alternative methods (landfill expansion options). These methodologies were clear, traceable and replicable.

Conclusion: completed

Analysis of the EA

Potential environmental effects and mitigation measures were considered in the evaluation of alternatives to the undertaking in Section 6.3 of the EA.

Section 9 of the EA describes mitigation measures and potential residual environmental effects for the preferred undertaking of expanding the landfill.

Conclusion: completed

Analysis of the EA

Advantages and disadvantages of alternatives to the undertaking to the environment were evaluated in Section 6.4 of the EA. Table 14 of Section 6.4.3 compares the advantages and disadvantages of each alternative waste disposal system to all aspects of the environment.

Conclusion: completed

Analysis of the EA

Section 13 of the EA discusses consultation during the preparation of the EA. Consultation records are in Appendix E of the EA. Consultation methods used include:

• Notices in the local newspaper and proponent website;
• A project newsletter;
• A public information centre;
• Meetings; and,
• Written letters.

Consultation records show that the proponent contacted the Ministry of Aboriginal Affairs, Indigenous Affairs Canada and the Ministry of the Environment and Climate Change to identify Aboriginal communities to be consulted. The proponent sent a consultation request letter to Aboriginal communities and distributed copies of the draft EA for their review. No comments on the EA were received from Aboriginal communities.

The proponent also circulated copies of the draft EA to government agencies, which was the main point of agency contact.

No conflicts with stakeholders occurred during the EA.

Conclusion: completed

Analysis of the EA

Section 6.4.2 of the EA described the comparative evaluation of net effects for each waste disposal system and the associated numerical scoring. Landfill expansion had the least impacts on the environment and the most favourable score. The key advantages of landfill expansion are summarized in Section 6.4.3 of the EA.

Details of the proposed undertaking, including leachate and stormwater management for the expanded landfill, are provided in Section 10 of the EA. Section 10 also states the rationale for the undertaking, which is to accommodate the waste disposal needs for the City of Elliot Lake for an additional 25 years by expanding the existing landfill. The proposed expansion will allow for an additional 300,000 m³ of waste disposal capacity plus an additional 75,000 m³ for final cover (a total expansion volume of 375,000m³. The proposed expansion would provide the city with solid waste disposal capacity to the year 2045.

Conclusion: completed

Analysis of the EA

Section 11 of the EA describes the monitoring and reporting commitments during the design, construction and operation stages of the project. Types of commitments include:

• Construction site inspections;
• Ground and surface water monitoring;
• Leachate management;
• Noise, air & dust monitoring;
• Pest management;
• Litter management; and,
• Predictive (trigger level) & contingency monitoring during operation.

Conclusion: completed

Analysis of the EA

Section 12 of the EA discusses the required MOECC approvals for landfill development in Ontario.

Conclusion: completed

Appendix B: Submission received during the initial comment period

Submissions are available in hard copy at the public record locations listed in this ministry review.

Table 1: Government Review Team comments

Comment PO1

The EA should have an executive summary. In accordance with Regulation 334, all environmental assessments must contact a brief summary of all the main points of the document. It should be consistent with the way in which the environmental assessment is organized.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

ES added.

Status

The ministry is satisfied.

Comment PO2

The EA should have a glossary of frequently used terms or list of abbreviations.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Added from TOR.

Status

The ministry is satisfied.

Comment PO3

The Environmental Assessment is referred to as the Environmental Study Report (ESR) on page headers. ESR typically refers to the final report for Schedule C Class EAs.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Corrected.

Status

The ministry is satisfied.

Comment PO4

The official EA submission date should be February 5, 2016 in Table 1 and Figure 2.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Corrected.

Status

The ministry is satisfied.

Comment PO5

Section 3 (Planning Process) should explain how the development of the City of Elliot Lake Solid Waste Management Plan (SWMP) fits into the overall Individual EA process. The preparation of the SWMP and EA appear to be two separate processes. The SWMP is also presented as an appendix to the EA (Appendix C).

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Planning process clarified. Supporting minutes/ correspondence not available. This was before exp was involved with the project.

Status

The ministry is satisfied. Section 3 of the amended EA clarifies the planning process for the SWMP and EA.

Comment PO6

Section 3.1.3 (Environmental Assessment Process) should list the evaluation of alternatives to and alternative methods steps.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Section 3.1.3 expanded to include evaluation steps.

Status

The ministry is satisfied.

Comment PO7

Table 3 should list all ToR Requirements. There are requirements missing from the following ToR Sections, in particular:

• 10.1 Parties to be Consulted during EA Study
• 10.2.1 Communications Strategy
• 10.2.2 City of Elliot Lake Waste Management Newsletter
• 10.2.4 Meetings/Presentations
• 10.3 Issues Resolutions
• 12 Modifications to This Terms of Reference
• 13 Identification of Other Approvals Required

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Updated.

Status

The ministry is satisfied.

Comment PO8

Section 4 (Description of Study Area Existing Environment). The following components of the environment are missing from Section 4:

The description of the study area in Section 4 should build upon the Description of Environment Potentially Affected in the approved ToR. The detailed description of the environment must address all components of the environment (natural, social, economic, cultural, built) as defined in the Environmental Assessment Act.

This section should also list the studies/research used to provide the description of the environment.

• Technical/Infrastructure (e.g. transportation, municipal services)
• Legal/Jurisdictional (e.g. land use, official plans)

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Description expanded to include tech/infra and legal/jur. Builds on text from approved ToR. List of information used in the EA is provided in Section 3.2.

Status

The ministry is satisfied.

Comment PO9

Section 5.4 (Additional At-Source Diversion) should reference the Long Term Solid Waste Management Plan in Appendix C.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Reference to appendix C added.

Status

The ministry is satisfied.

Comment PO10

Section 5.5 (Export of Waste) should identify the possible locations for waste disposal considered for this alternative.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Added.

Status

The ministry is satisfied.

Comment PO11

Section 6 (Evaluation of Alternatives To). There should be a description of the method used to screen alternatives to. A figure or outline of the steps in the systematic evaluation of the alternatives to would assist the reader in following the methodology used for selecting the preferred undertaking.

Section 8.1 or the ToR outlines a step-by-step methodology for the net effects analysis of alternatives to. This methodology should be described in the EA.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Text from ToR incorporated into Section 6.1.

Status

The ministry is satisfied.

Comment PO12

The criterion, from ToR Table B-1: Potential air quality and noise impacts – related to haul routes and sites, is missing from EA Table 4 (Evaluation Criteria for Alternatives To).

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Clarification provided.

Status

The ministry is satisfied.

Comment PO13

The evaluation criteria in Table 4 should be followed by indicators that identify how the potential environmental effects will be measured for each criterion. An outline of the data sources for the criteria and indicators is also required in the environmental assessment.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Indicators (and data sources) added.

Status

The ministry is satisfied.

Comment PO14

Section 6.1 (Screening Criteria). This section should document how input from the public and government review agencies on the proposed evaluation steps and evaluation criteria were considered during the screening of alternatives to.

Section 8.1.1 of the ToR states that Prior to initiation of the evaluation of ‘Alternatives to’ the undertaking, the proposed evaluation methodology and criteria will again be reviewed in consultation with the public and government review agencies. This review will again seek input on the proposed evaluation steps and evaluation criteria presented in the EA ToR and will seek to confirm the priorities to be considered during the evaluation.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

No feedback on criteria provided during EA. Feedback on criteria during SWMP included in appendix E.

Status

The ministry is satisfied.

Comment PO15

Table 7: Evaluation of Landfill Expansion Alternative, should identify measures to mitigate greenhouse gas emissions resulting from an expanded landfill.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Additional measures noted.

Status

The ministry is satisfied.

Comment PO16

Table 9: Evaluation of Waste Export Alternative, should identify environmental impacts and risks associated with the siting and operation of a new solid waste transfer station.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Issues relating to new transfer station clarified.

Status

The ministry is satisfied.

Comment PO17

Section 6.3 (Recommended Alternatives to the Undertaking). The discussion on the net effects of the alternatives on the natural environment only addresses environmental burden at a global or macro-environmental scale. The discussion should also compare the net effects of the alternatives on:

• Consumption/preservation of non-renewable resources
• Potential for destruction or disruption of sensitive terrestrial and/or aquatic habitats at an eventual site
• Potential to increase diversion rate from disposal and/or make best use of residual (post-diversion) waste materials
• Potential air quality and noise impacts

The net effects of the landfill options alternatives (expansion/new site) should also be discussed.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Section 6.4 (formerly 6.3) includes greater discussion on the evaluation.

Status

The ministry is satisfied.

Comment PO18

Section 6.3 (Recommended Alternatives to the Undertaking). The discussion on the net effects of the alternatives on the economic/financial environment should also address the following criteria:

• Net system costs per tonne of waste managed including facility costs, residual disposal, etc.
• Sensitivity of system costs and affordability to external financial influences
• Potential for local economic development

A quantitative comparison of the capital and operating cost estimates for each alternative in table format would assist in the discussion.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Discussion on economic net benefits expanded.

Status

The ministry is satisfied.

Comment PO19

Section 6.3 (Recommended Alternatives to the Undertaking). The discussion on the net effects of the waste management alternatives on the technical environment should address all technical screening criteria:

• Technical risks associated with waste management alternative
• Proven track record of alternative
• Ease of implementation

The description of the net effects resulting from a new landfill on the technical environment appears to be missing.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Discussion on technical risks expanded.

Status

The ministry is satisfied.

Comment PO20

Table 11: Summary of Alternative Disposal System Advantages and Disadvantages, should present the relative differences and key impacts of each waste management alternative in a systematic manner to enable the reader to clearly understand the trade-offs for selecting landfill expansion as the preferred undertaking.

PIC’ #3 evaluation summary panels in Appendix E show a more systematic numerical scoring assessment based on a scale of 1 to 5. This evaluation method differs from Table 11 that shows moon-shaped symbols.

Table 11 should also assess the advantages and disadvantages of the do nothing alternative for comparison.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Table showing numerical scoring of net effects added.

Table summarizing advantages and disadvantages revised.

The do nothing option was screened out in Section 5.6.

Status

The ministry is satisfied.

Comment PO21

Section 7 (Identification and Evaluation of Alternative Methods) should describe the process for identifying alternative methods and the evaluation methodology. This section should be expanded with additional detail and figures for each method.

Section 8.2 of the ToR states that the evaluation of alternative methods of carrying out the undertaking will be comprised of a facility site selection process. As the alternative methods considered in the EA are options for expanding the City’s existing landfill, a rationale should be provided as to why alternative landfill site selection was not undertaken as part of the evaluation of alternative methods.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Section 8.1 (section 7 is now section 8) describes how the screening/ evaluation process for alternative methods described in the ToR was applied to the screening/evaluation of alternative methods in the EA.

Status

The ministry is satisfied.

Comment PO22

Section 7 of the EA should also mention if the public and government review agencies provided input into the proposed evaluation methodology and evaluation criteria for the assessment of alternative methods.

Section 8.2.1 of the ToR states that Prior to initiation of the evaluation of ‘Alternatives Methods’ and after a preferred approach (alternative to) has been identified by the EA study, the proposed evaluation methodology and criteria will again be reviewed in consultation with the public and government review agencies. This review will seek input on the proposed evaluation steps and evaluation criteria presented in the EA ToR and will seek to confirm the priorities to be considered during the evaluation.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Clarified.

Status

The ministry is satisfied.

Comment PO23

Section 8 (Description of the Local Environment) should describe in detail, all the components of the environment (as mentioned in Section 6 of the ToR) that will be potentially affected by the undertaking. Aspects of the environment that should be described in detail in this section include:

• Economic/Financial
  • Landfill operating costs
  • Disposal (tipping) fees
• Technical/Infrastructure
  • Description of existing facility (e.g. surface area, approved capacity)
  • Information on the operation of the existing landfill (e.g. leachate and stormwater collection systems, odour management)
• Legal/Jurisdictional
  • Land ownership
  • Adjacent land uses

The EA should explain the purpose of the description of the larger study area in Section 4, and the purpose of the description of the local environment which comprises of the landfill site and its immediate surroundings in Section 8.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Information clarified. OP land use schedule map added.

Status

The ministry is satisfied.

Comment PO24

Section 8.3 (Area Geology and Hydrogeology). The EA should limit the use of jargon. The terms used in the description of area geology are difficult for the lay reader to understand. This section would also benefit from the addition of a figure. Geotechnical borehole investigation and hydrological information from Appendix G (Groundwater and Surface Water Assessment) should also be referenced in this section.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Groundwater and Surface Water Assessment noted to be in Appendix G. Figure 3 topographical map updated with labeled surface water features. Waterbodies already labeled.

Status

The ministry is satisfied.

Comment PO25

Section 9 (Evaluation of Alternative Methods). Table C-3 of the ToR lists the preliminary comparative evaluation criteria for the short-listing of alternative landfill sites. Section 9 of the EA should define each criterion used for the evaluation of alternative landfill expansion methods, including any additional criteria (e.g. geological and geotechnical), followed by indicators that identify how the potential environmental effects of each were measured for each.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

ES added.

Status

The ministry is satisfied.

Comment PO1

The EA should have an executive summary. In accordance with Regulation 334, all environmental assessments must contact a brief summary of all the main points of the document. It should be consistent with the way in which the environmental assessment is organized.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

New table added identifying indicators used for evaluation criteria.

Status

The ministry is satisfied.

Comment PO26

Section 11 (Identification of the Undertaking). The 25-year planning period covered by the SWMP and the EA should be clarified since these reports were completed in different years (2012 and 2016 respectively). The August 2014 project newsletter in Appendix E states that the landfill expansion will provide the City with disposal capacity until about 2041. Also of note, is that the approved ToR, dated October 2008 states that the purpose of the proposed undertaking is to create a long-term (20-25 year) waste management master plan, to commence no later than 2010, that will guide the management of wastes that remain after the application of the at-source waste diversion (reduction, reuse, recycling and composting) programs.

Additional clarification is needed on the estimated remaining volume of the existing landfill. Section 11.1 mentions that the remaining volume in the landfill site until closure from an April 2012 survey by Paul H. Torrance Surveying Limited was approximately 145,000m³; whereas in Appendix G (Groundwater and Surface Water Assessment), the remaining site volume estimated by Pinchin Environmental as of March 2012 was 60,000m³. Based on an annual fill rate of 12,000m³/year, the remaining life span of the landfill would be 12 years from 2012 (until 2024) according to Paul H. Torrance’s survey, and only 5 years (until 2017) according to Pinchin Environmental’s estimates.

Additional clarification is also needed for the future required waste disposal capacity. Section 11.1 states that the expansion would allow for an additional 300,000m³ of capacity; whereas the August 2014 newsletter in Appendix E states that the expansion will provide an additional 345,000m³ of landfill space from its currently approved capacity of 842,000m³.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Remaining capacity clarified.

Status

The ministry is satisfied.

Comment PO27

Section 12 (Commitments and Monitoring). This section only focuses on monitoring program activities during the operation of the expanded landfill. The monitoring program should consider all phases of the proposed undertaking: planning, detailed design, tendering, construction, operation, and closure (where appropriate). This framework must include compliance monitoring, and where appropriate, effects monitoring.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Updated.

Status

The ministry is satisfied.

Comment PO28

Section 12 (Commitments and Monitoring). This section should include a plan that sets out how and when all commitments made in the EA document and any conditions of approval will be fulfilled, in addition to how the proponent will report to the ministry about compliance. This information should be summarized in a single table, with columns for a brief description of all commitments and timing for completion.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Table added.

Status

The ministry is satisfied.

Comment PO29

Section 12.3 (Pests). Appendix F (Natural Heritage Report) recommended black bear management as part of future natural heritage mitigation reporting, or the development of an Elliot Lake Bear Hazard Assessment/Management Strategy. Section 12.3 should mention whether this recommendation has been accepted by the proponent.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Updated.

Status

The ministry is satisfied.

Comment PO30

Section 13 (Required Approvals). This section should mention approvals required from other government agencies and local authorities. Permits and approvals required for landfill leachate conveyance to the municipal wastewater treatment plant via truck or pipeline should also be mentioned.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Updated.

Status

The ministry is satisfied.

Comment PO31

Section 14 (Stakeholder Consultation). This section should provide an overview of the communication plan, followed by a comprehensive description of the consultation activities that took place during the preparation of the EA. The plan followed should be based on the Communications Strategy outlined Section 10.2.1 of the ToR.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

TOR communications strategy noted. Consultation section updated.

Status

The ministry is satisfied.

Comment PO32

Section 14 (Stakeholder Consultation). This section should include a list of government agencies, members of the public (personal names not required) and Aboriginal communities consulted during the preparation of the EA and information on how they were notified.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Consultation section clarified/updated.

Status

The ministry is satisfied.

Comment PO33

Section 14 (Stakeholder Consultation). A detailed description of how Aboriginal communities were identified and special efforts undertaken to consult them is required. The MOECC’s letter to the City of Elliot Lake dated June 1, 2015 identifies First Nations communities who may be adversely impacted by the project, and Métis communities who may be interested in the project. This letter should be included in the Record of Consultation in Appendix E.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Consultation section clarified/updated. Letter dated June 1 2015 added.

Status

The ministry is satisfied.

Comment PO34

Section 14 (Stakeholder Consultation). This section should document how consultation results were considered in the proponent’s planning and decision-making process. The summary of any comments received and the proponent’s responses should be presented in a table. As appropriate, included in the table should be an indication of where in the EA the concern is addressed, organized by public, GRT agencies, aboriginal communities. Any outstanding concerns should be identified.

Appendix E should also include copies of written comments from interested persons collected from PICs’, letters/emails sent to the proponent, and PIC’ summary reports.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Consultation section clarified/updated. Written comments added to Appendix E.

Status

The ministry is satisfied.

Comment PO35

Section 14 (Stakeholder Communication). ToR Section 10.2, Table 10-1, mentions the provision of opportunities to form a Site Liaison Committee consisting of resident, agency and other interested representatives to review and provide input on site specific studies, as well as focused information sessions. Please confirm if these opportunities were provided.

ToR Section 10.2.4 proposed meetings with the Public Services Committee to review the information obtained, based on the completion of all work program tasks and the results of the PICs. Please confirm if these meetings were held.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Clarified.

Status

The ministry is satisfied.

Comment PO36

Appendix C (Solid Waste Management Plan). Section 7 of the SWMP in Appendix C recommends the review of thermal treatment as a means to reduce the amount of waste for disposal in five years, once the landfill expansion is complete. Establishing a thermal treatment site or changing a waste disposal site to become a thermal treatment site, are activities subject to an Individual EA (Part II of the Environmental Assessment Act) as per the Waste Management Project Regulation 101/07.

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

No change.

Status

The ministry is satisfied.

Comment PO37

Other

• Section 4, footnote 4 is missing
• Table 12: Comparative Evaluation of Alternative Methods is missing from the List of Tables
• Sections 7 and 9 should be combined into one section describing the identification and evaluation of alternative methods.
• Appendices should be separated by dividers with labelled tabs

Submitted

MOECC, Environmental Approvals Branch, Project Coordination Unit

Proponent’s response

Section 8 has been moved and is now section 7. Section 7 and 9 have been merged and are now section 8. Graphic added to differentiate appendix divider page.

Status

The ministry is satisfied.

Comment WM1

The Report specifies the required capacity for the proposed expanded site to service the City’s waste disposal needs over the 25-year planned period is approximately 300,000 m³ and therefore would employ the Ontario Regulation 232/98, Landfill Standards, A Guideline on the Regulatory Requirements for New or Expanding Landfilling Sites, in the design, operation, closure and post-closure care of the site. The EA document has satisfactorily committed to consider and follow all applicable ministry policies, standards and guidelines such as Reasonable Use Policy (Guideline B-7), etc., in the design and development of the Site under EPA.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged.

Status

The ministry is satisfied.

Comment WM2

As previously requested, the EA document/report has included an estimation of the volumetric capacity 300,000 m³ required over the planned period, and the remaining capacity of the existing waste disposal site, as well as the volumetric capacity for the expanding fill area of 0.79 hectare. The information provided addresses my comment. However, it should be noted that with the EPA application, the proponent is required to (1) provide detailed calculations based on the geometric design of the site; and (2) to confirm the sufficiency of the expanded space within the City-owned land of the 15.7 hectares site. Again, please note: except for limitation on final contours, if applicable, the volumetric capacity for the landfill does not include the volume of the final cover.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Understood. As noted in Section 10.2, the EPA application will include the detailed calculations and will confirm the sufficiency of the expanded space.

Status

The ministry is satisfied.

Comment WM3

The EA document/report satisfactorily included a conceptual general site plan, defining the existing waste fill area, the proposed expansion waste fill area and the final contours, buffer/contaminant attenuation zones and the overall landfill site boundaries.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged.

Status

The ministry is satisfied.

Comment WM4

The Report specifies Comparative Evaluation Criteria for selection of the preferred alternative to deal with the potential for adverse effects on components of the natural environment - groundwater and surface water quality/quantity, among others - and the mitigation included natural attenuation within the underlying thin overburden soil and/or the existing infrastructure (assumed to be the existing 1500 m² sand filter bed and its associated systems (system)). As noted in the report, it is expected that the EPA application will include the final design of the site and that the final design in that application will include an evaluation of the system performance by modelling or alternative appropriate method to ensure adequate attenuation of the increased leachate generation due to the landfill expansion. I am satisfied that the EA report acknowledges and has committed to address the issue at the appropriate stage of application under the EPA.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged. As noted in 10.3 of the EA report, the EPA application will include the final design of the site. The final design in that application will include an evaluation of the system performance by modelling or alternative appropriate method to ensure adequate attenuation of the increased leachate generation due to the landfill expansion.

Status

The ministry is satisfied.

Comment WM5

The Comparative Evaluation Criteria for selection of the preferred alternative to deal with potential for adverse effects on components of the natural environment, lists examples such as geologic and hydrogeologic features and conditions, groundwater/surface water quality and quantity, etc. These components for the evaluation have included a geotechnical feasibility of the preferred alternative, particularly, the feasibility of achieving stable subgrades for waste disposal in areas of thin overburden with possible high phreatic surface. The EA document has addressed this comment.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged.

Status

The ministry is satisfied.

Comment WM6

Section 11.2 of the report lists the final design considerations to be applied under all relevant regulatory requirements. The EA Report undertakes an evaluation of all design considerations required by Ontario Regulation 232/98, under the EPA application, of which the list in section 11.2 of the report is only partial.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged. As noted in Section 12 [of the amended EA], design considerations will be confirmed with MOECC during the detailed design phase.

Status

The ministry is satisfied.

Comment WM7

The EA report satisfactorily clarified and committed to provide in the EPA application, the design for the proposed leachate management system and the perimeter berm, including the soil properties such as permeability.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Acknowledged.

Status

The ministry is satisfied.

Comment WM8

The EA Report describes the preferred site as having part of the active landfill site area poorly drained and containing marshy soil - wetland and possibly standing water. The EA and hence the design of the preferred site must ensure and confirm compliance with the Adams Mine Lake Act- EPA, Section 27(3.1).

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Section 27(3.1) of the EPA states that Despite subsection (1), no person shall use, operate, establish, alter, enlarge or extend a waste disposal site where waste is deposited in a lake. 2004, c. 6, s. 7 (1).

As noted in Section 10.2, the landfill expansion will not extend this waste disposal site into any of the nearby lakes, and is therefore in compliance with Section 27(3.1) of the EPA.

Status

The ministry is satisfied.

Comment WM9

Referenced Figures (e.g. Figures 4, 5, 6, etc.) which were not available in the draft EA report, were included in the report and found to be satisfactory. However, as previously noted in the review comment on the draft of the EA document, it is noticed there are repetitive designations for Appendices in the EA document/report due to the use of same letters of the alphabet for Appendices in the main body of the report as well as its attached documents. This formatting issue in the report remains unchanged and continues to causes confusion that could be avoided by use of appropriate designations to differentiate the appendices in different places in the document/report.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

The formatting in the revised EA report for the main appendix title changes were updated to include a large colour graphic swash extending from the bottom right corner and covering a large portion of the page. This graphically distinguishes the appendix title page from those used in the attached reports.

Status

The ministry is satisfied.

Comment WM10

Last three paragraphs of section 11.2 of the EA report describes preparatory works in the waste fill area, to be carried out in 2016 or later, to allow continued waste disposal at the site without interruption. Please, note that any work related to the expansion or alteration of existing approved condition or component, require the approval of the Director appointed under EPA or OWRA.

Submitted

MOECC, Environmental Approvals Branch, Waste Reviewer

Proponent’s response

Understood.

Status

The ministry is satisfied.

Comment GW1

The alternatives assessment initiated in the 2012 waste management plan and continued in the environmental assessment (EA) appears reasonable from a hydrogeology perspective. The alternatives assessment concluded that increased waste diversion and the expansion of the current landfill is the preferred option to meet the future waste disposal needs of the City. More specifically, the most appropriate expansion has been determined to be towards the east-southeast requiring leachate management, which appears to be a reasonable conclusion from a hydrogeology perspective.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agree.

Status

The ministry is satisfied.

Comment GW2

The EA concluded that there is a significant risk that leachate-impacted groundwater will seep and discharge to ground surface downgradient of the proposed waste expansion area.  I concur with this conclusion given the thin (generally less than 1 m) overburden and apparent low fracture density bedrock. The EA does acknowledge leachate collection and treatment will be required in the proposed expansion area.  I believe that appropriately designed, constructed and maintained leachate management will help to mitigate the environmental effects that could reasonably be expected with the proposed landfill expansion. The details of the leachate management approach and design will be required in the environmental compliance (ECA) or amendment application.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Acknowledged. As noted in Section 11.3, the details of the leachate management approach and design will be included in the environmental compliance (ECA) application.

Status

The ministry is satisfied.

Comment GW3

Section 11.3.1 of the EA states that the sand filter/wetland treatment system were installed at the west boundary of the landfill in 1998.  It is not reasonable to refer to the wetland as a treatment system as the wetland was not constructed for the purposes of leachate filtration and has been defined as a natural wetland within the EA and the 2014 WQMA. The wetland shall not be referred to as a treatment facility and the discharge to the wetland is considered a discharge to surface water.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agree. The term wetland treatment was removed.

Status

The ministry is satisfied.

Comment GW4

Photos and discussion provided in the EA suggest likely leachate effects in the wetland west of the disposal area. These effects should be investigated and mitigation/remediation measures proposed, if required, and an assessment of the efficacy of the leachate management system should be provided in the approval application. The efficacy of the existing leachate collection and treatment system is currently estimated by comparing leachate quality monitoring results collected from a sample hatch upgradient of the treatment system, to downgradient groundwater quality monitoring results. The use of additional groundwater monitoring wells to assess the efficacy of the existing and any future leachate treatment system should be considered.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agree. Section 11.2 notes that details of the monitoring program for the Site expansion - including establishment of new monitoring wells onsite - will be outlined during the EPA approval process. Recommendations for additional groundwater and surface water monitoring wells/stations were recommended in the groundwater and surface water assessment (appendix G)

Status

The ministry is satisfied.

Comment GW5

Methods through which leachate generation could be reduced were discussed in the EA. These methods include progressive placement of cover, use of impermeable tarps or alternate daily cover systems; and spray irrigation. However, the proposed expansion to the landfills disposal area would likely result in an increase in leachate production. The EA states that it is expected that the sand filter should be able to manage this increase in the quantity of leachate.  Contaminated surface runoff and leachate flowing toward the west are to be directed to the existing leachate management system that would be expanded if needed. The EA suggests that a new system would be constructed east of the disposal area if it is determined that leachate from the east part of the landfill drains easterly and not westerly toward the existing sand filter system. This new leachate management system could include a toe drain, potential leachate sump and pump, or forcemain. It is proposed that all leachate collected from the Site would be treated using the existing or expanded sand filter system or conveyed directly to the City’s wastewater treatment plant (WWTP). The EA states that the WWTP would have sufficient capacity to manage leachate from the landfill, and that the WWTP may be able to accept leachate without pre-treatment.  The collected leachate could be transported to the WWTP in one of two ways proposed in the EA: via pipeline; or via truck. While specific details of the proposed expanded leachate management system have not been provided in the EA, the options discussed appear reasonable and have the ability to mitigate environmental effects that could reasonably be expected from leachate resulting from the proposed waste disposal area expansion. Specific details of the efficacy of the existing leachate management system and the proposed design for the expanded leachate management system will be provided in the approval application for review by the Ministry of the Environment and Climate Change (MOECC).

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Acknowledged. As noted in Section 11.3, specific details of the efficacy of the existing leachate management system and the proposed design for the expanded leachate management system will be provided in the ECA approval application.

Status

The ministry is satisfied.

Comment GW6

There are currently 2 groundwater monitoring wells onsite, LW1 and LW2, which are located at the western toe of the existing waste disposal area. I was not able to find borehole logs and the monitoring well designs are not clear. This information should be provided in all future reports. Leachate samples are collected from the leachate collection system upgradient of the sand filter bed. There is a well approximately 800 m southeast of the Site at the City’s WWTP that has been monitored since 2013 to provide information on background groundwater conditions.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Acknowledged. We [exp] will advise the City that the MOECC requests borehole logs for LW1 and LW2 and information on the well designs be included in future landfill monitoring reports.

Status

The ministry is satisfied.

Comment GW7

The 2014 WQMA states that the current groundwater monitoring well network is not considered adequate for evaluating the groundwater quality at the Elliot Lake Landfill, and it is recommended that a proper groundwater monitoring well network be established for the Site.  I concur with these statements. However, it was further stated that due to the marginal RUC exceedances (non-health related) observed at these two wells, as well as the assessment of surface water west of the Site, further downgradient wells are no deemed necessary at this time.  I do not agree with this statement as I do not consider the observed Guideline B-7 (formerly Policy 15-08, entitled "Incorporation of the Reasonable Use Concept into MOEE Groundwater Management Activities", dated April 1994, as amended) criteria exceedances as marginal (some up to 50 times greater than the criteria). While it is noted that the observed exceedances were generally of non-health related parameters, it is my opinion that at least one monitoring well downgradient of these wells toward the west is required to assess compliance with Guideline B-7 and estimate loadings to the surface water receiver in this area.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Understood. Monitoring well recommendations will be confirmed during the detailed design/ECA application stage, as noted in Section 11.2 of the EA report.

Status

The ministry is satisfied.

Comment GW8

The EA suggests that proximal and downgradient groundwater monitoring wells will be needed east of the proposed disposal area expansion and a background monitoring well should be installed onsite. I concur with these suggestions. The groundwater monitoring program needs to be improved for the Site, with consideration given to monitoring that will help define the performance of the leachate collection system(s) on an ongoing basis. The revised groundwater monitoring program, including proposed locations for future monitoring well installations, should be provided in the application for the associated approval for review by the MOECC.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agreed. As noted in Section 11.2, a revised groundwater monitoring program, including proposed locations for future monitoring well installations, will be provided in the application for the ECA approval for review by the MOECC.

Status

The ministry is satisfied.

Comment GW9

Where groundwater is believed to discharge to surface water (e.g., west boundary of the fill area) groundwater monitoring results shall be compared to Provincial Water Quality Objectives (PWQOs) and/or Aquatic Protection Values (APVs) to assess impacts to the surface water receiver in all future submissions. Loading estimates should also be provided in the approval application and all future monitoring reports.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agreed. As noted in Section 11.2, loading estimates will be provided in the ECA approval application and future monitoring reports.

Status

The ministry is satisfied.

Comment GW10

No contingency plan or trigger criteria exist for the Site. A contingency plan including trigger criteria should be developed and included in the approval application and in all future monitoring reports.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agreed. As discussed in Section 11.7, a contingency plan including trigger criteria will be developed and included in the ECA approval application and noted in future monitoring reports.

Status

The ministry is satisfied.

Comment GW11

Based on the findings during the 2014 monitoring season and historical results, the 2014 WQMA provides 2 recommendations: continue with routine monitoring and analysis during the spring, summer and fall at all available water quality monitoring points; and groundwater monitoring shall be completed with analyses for the parameters specified in the site-specific CofA.  I concur with these recommendations; however, groundwater monitoring requirements should be applied to the additional well installations as recommended herein.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agreed. The ECA approval application will note that groundwater monitoring requirements should be applied to the additional well installations as recommended herein.

Status

The ministry is satisfied.

Comment GW12

Upon review of the photo appendix provided in Appendix F—Natural Heritage Inventory Report, there appears to be Site stewardship issues, specifically wayward waste outside of the disposal limits in the Hemlock forest and near the Pine forest. I recommend that the property be maintained as appropriate.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Understood. The Commitments and Monitoring section of the EA Report notes application of litter mitigation measures (see Section 11.6).

Status

The ministry is satisfied.

Comment GW13

Based on my review of the 2014 WQMA I have recommendations for future work relating to the protection and monitoring of groundwater.

1. Where groundwater discharges to surface water, monitoring results shall be compared to PWQOs or APVs and contaminant loading estimates shall be provided in all monitoring reports.
2. A contingency plan including trigger criteria and contingency measures shall be provided in all monitoring reports.
3. Waste disposal shall be limited to the approved disposal area and wayward waste shall be cleaned up as necessary.
4. In the event that the next monitoring report (due March 31, 2017) is submitted prior to the landfill expansion approval application, an upgraded groundwater monitoring program shall be proposed in the next monitoring report and should include, among other items, proposals for: a background monitoring well location onsite; at least one monitoring well location downgradient of LW1 and LW2, with consideration given to assessing effects and estimating contaminant loadings to the surface water receiver west of the disposal area; and consideration of the need for groundwater monitoring wells in assessing efficacy of the existing leachate management system. Additional well installations shall be incorporated into the existing monitoring program as defined in the CofA.
5. I concur with the recommendations provided in the 2014 WQMA to continue monitoring and analysis thrice annually at all available water quality monitoring points, and to complete groundwater monitoring and analyses for the parameters specified in the CofA.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Agreed. Recommendations noted will be addressed during the ECA application or in future monitoring reports, as applicable.

Status

The ministry is satisfied.

Comment GW14

The proposed trigger levels [in the draft amended EA report] are not adequate for the purposes of permitting this project from a groundwater perspective.

It appears as though the proponent may have calculated the Guideline B-7 (formerly Policy 15-08, titled Incorporation of the Reasonable Use Concept into MOEE Groundwater Management Activities, dated April 1994, as amended) criteria and suggested these as values for trigger levels for the monitoring program at boundary monitoring wells. This method is not sufficient since it could allow contaminants in the groundwater to become elevated to levels that would be out of compliance with Guideline B-7, and thus out of compliance with the Ontario Water Resources Act, before any actions would be taken. Trigger criteria must be developed to identify potential non-compliance issues prior to their development such that the need for mitigation measures can be assessed and measures can be implemented as required to maintain compliance.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Understood. Trigger criteria will be developed during the approval application. This is noted in Section 11.2 of the EA report.

Status

The ministry is satisfied.

Comment GW15

While a contingency plan was provided in the [draft] amended EA report, it was lacking a list of feasible contingency measure options. I recommend that such a list be required for the EA, but specific details of these options will not be required until the permitting phase.

While section 11.7 does list steps that would be taken in the event that trigger levels are exceeded, the MOECC expects to see a list of feasible contingency measures that could be implemented at this site in the event that they are deemed necessary through the investigation and consultation phases of the plan. Such contingency measures typically include, but are not limited to, covering of the waste disposal area to reduce infiltration, expansion of the contaminant attenuation zone, enhanced monitoring, installation of a leachate collection system, or installation of a pump and treat system.

Submitted

MOECC, Northern Region, Technical Support, Water Unit (Groundwater)

Proponent’s response

Understood. Section 11.7 of the EA report was updated to include a list of feasible contingency measure options, the details of which will be provided in the permitting phase.

Status

The ministry is satisfied.

Comment EA1

The assessment determined that expansion will generate more leachate, which is to continue being directed to the existing sand filter, with consideration of an additional leachate collection system constructed at a later time if deemed necessary. The Draft EA Report did not confirm the feasibility of both of these leachate options as they should have been considered as part of the preferred alternative. The Draft EA Report suggested that it would be addressed as part of the Part V Environmental Compliance Approval (ECA) process.

Submitted

MOECC, West Central Region, Technical Support, Resource Planner & EA Coordinator

Proponent’s response

Correct.

Status

The ministry is satisfied.

Comment EA2

Section 11.3 of the Final EA Report speaks to leachate management and has provided a more detailed discussion to show that the existing sand filter should be able to treat anticipated volumes of leachate resulting from the expansion. Also discussed is the possibility that a new sand filter may need to be constructed in the event that leachate from the expansion area does not naturally flow westward to the existing sand filter. Finally, the Final EA Report has also addressed the possibility of trucking leachate to the City’s WWTP and has received confirmation from the facility operators that sufficient capacity is available for leachate generated at the landfill.

Submitted

MOECC, West Central Region, Technical Support, Resource Planner & EA Coordinator

Proponent’s response

Correct.

Status

The ministry is satisfied.

Comment EA3

Comments on the Draft EA suggested that clarification be provided in the Final EA document as to whether changes to any of the monitoring programs would be pursued through the applications to amend existing approvals. If so, it was expected that a discussion would be provided to explain the need for changes, and the implications of making changes to any of the monitoring programs.

Submitted

MOECC, West Central Region, Technical Support, Resource Planner & EA Coordinator

Proponent’s response

Acknowledged.

Status

The ministry is satisfied.

Comment EA4

Comments on the Draft EA indicated that the record of stakeholder and First Nation and Métis consultation was somewhat scant. It is noted that in the Final EA document contains a more detailed record. Appendix E:  Record of Consultation contains the complete record of all Notices; PIC information boards; and the August 2014 Project Newsletter. Appendix E also contains all correspondence between the project team and Aboriginal Affairs and Northern Development Canada, the Ministry of Aboriginal Affairs and MOECC that were received to assist in the compilation of First Nations and Métis groups for notification and consultation. The list of contacted groups is included and any responses that were received on the Draft EA Report have been compiled into a table.

Submitted

MOECC, West Central Region, Technical Support, Resource Planner & EA Coordinator

Proponent’s response

Correct.

Status

The ministry is satisfied.

Comment EA5

Based on what has been included in the Final EA Report, it appears that the proponent has yet to receive responses from all of the identified Aboriginal communities as provided by the MOECC in June of 2015. In addition to continuing to provide these communities with the required notices under the EA process, the proponent is encouraged to reach out to the communities to confirm they received the project notices/information. These additional communication efforts need to be captured as part of the consultation record. Furthermore, the proponent should continue to adhere to the general consultation advice previously provided by the MOECC in its June 1, 2015 letter.

Once the proponent has provided additional documentation on communication efforts and required notifications (e.g. circulation of the Notice of Commencement, Notice of Public Information Centres), the consultation record can then be reviewed for its completeness and adequacy.

Submitted

MOECC, West Central Region, Technical Support, Resource Planner & EA Coordinator

Proponent’s response

Proof of delivery of both the draft EA report and the EA report posted for public review confirm that the First Nations / Aboriginal organizations were received, confirming they received the documents.

Status

The ministry is partially satisfied. Other than courier delivery confirmations, the proponent does not have records of additional calls or e-mails made to the Aboriginal communities on the contact list after the consultation letter and draft EA were sent. Special efforts to follow-up with Aboriginal communities during the EA should have been carried out and documented. Aboriginal communities should also have been invited to attend public information centres.

Comment

No comments.

Submitted

MOECC, Environmental Approvals Branch, Noise Reviewer

Proponent’s response

N/A

Status

N/A

Comment

Thank you for circulating the final Environmental Study Report (ESR), dated Jan 2016, for the above-noted project and providing MTCS with the opportunity to review it. The items we raised in our email of 17 December 2015 have been addressed. We have no further comments to make at this time. Please continue to include MTCS in all phases of the project, as it progresses through the EA process.

Submitted

Ministry of Tourism, Culture and Sport

Proponent’s response

N/A

Status

N/A

Comment

No comments.

Submitted

Ministry of Health

Proponent’s response

N/A

Status

N/A

Comment

1. Ensure that air quality is monitored and maintained below any standards, for the incineration option and the leachate trucking option in particular.
2. Ensure that the groundwater protection plan is sufficient to provide protection for ground and surface water especially in the expanded option and the piping of the leachate options.
3. Transfer of the leachate to the waste water treatment plant thoroughly consider the risk of occurrence (pipe leaking, truck spilling) and the severity of outcome (ground water contamination and volumes) and frequency of events (number of potential spills from the trucking option vs the number of potential breaks in piping). If piping is chosen to ensure the system has a double barrier to protect against potential breaks.

Submitted

Algoma Public Health

Proponent’s response

Thank you for your interest in the project and your comment. In response to your comments:

• The incineration option was not preferred, and therefore the City will not be proceeding with that option.
• The detailed design process will assess the best approach for managing leachate. It is anticipated that pumping leachate from the eastern portion of the landfill site to the west side’s sand filter would likely be the preferred approach; however, if the preferred approach turns out to be to transport the leachate the 700m from the landfill site to the wastewater treatment plant, whether it be truck or pipe, then the design process will consider the aspects you mention. However, it will be a number of years before the eastern edge of the landfill site expands to a point where the transport of leachate for treatment is required.

Status

The ministry is satisfied.

Comment

No comments.

Submitted

Ministry of Natural Resources and Forestry, Sault Ste Marie District Office

Proponent’s response

N/A

Status

N/A

Comment

Acknowledgment of Receipt Form indicated no comments.

Submitted

Ministry of Municipal Affairs and Housing

Proponent’s response

N/A

Status

N/A

Comment

No comments.

Submitted

Transport Canada

Proponent’s response

N/A

Status

N/A

Table 2: Public comment summary table

Comment #1

I think it would have been good if you had decided to include the requirements necessary to add in community organic waste collection and composting, as far as area required to handle and manage the amount of compostable material that the community generates on an annual basis. Identifying and allocating this area within the existing landfill site would ensure there is adequate space to manage all waste in 1 site when community wide organic waste collection is implemented.

The other point I thought may be worth mentioning is the relevance of climate change mitigation actions that will be required by communities over the next 25 years, with regards to all municipal activities, but in this context, with respect to waste management specifically. Moving towards net zero carbon emissions will be a challenge with our current stock of fossil fuel powered industrial vehicles to haul our waste to the landfill. Bio-diesel or other low or no carbon fuels may be able to help. Climate change action plans that include education towards waste reduction (including packaging reduction and reusable packaging) may help.

Proponent’s response

Thank you for your interest in the project and your comment.

This EA focused specifically on expansion of the existing landfill footprint rather than the design and layout of the existing solid waste management site. The existing property where the solid waste management site is located is quite large and could potentially accommodate organic waste collection. If the City decided to process its own organics, then it would be required to complete some additional investigation to confirm a suitable location on the property, follow any applicable regulations and guidelines related to siting such a facility, and amend the site’s Environmental Compliance Approval.

Also, we appreciate the comments regarding climate change mitigation, and your suggestions are worthwhile considering.

Status

The ministry recommends that the City of Elliot Lake investigate the feasibility of organic waste diversion options, and explore ways to reduce greenhouse gas emissions during waste collection and disposal operations.

Table 3: Indigenous communities comment summary table

Comment #1

Acknowledgement of receipt form indicated intention to submit comments. No comments were received.

Indigenous community

Mississauga #8 First Nation

Proponent’s response

N/A

Status

The ministry will follow-up with this community during the Ministry Review comment period.

Comment #2

No comments.

Indigenous community

Sagamok Anishnawbek First Nation

Proponent’s response

N/A

Status

N/A

Comment #3

No comments.

Indigenous community

Métis Nation of Ontario (MNO) North Channel Métis Council

Proponent’s response

N/A

Status

N/A

Comment #4

Acknowledgement of receipt form indicated no comments.

Indigenous community

Bar River Métis Community

Proponent’s response

N/A

Status

N/A

Comment #5

Serpent River First Nation expressed the intention to submit comments. No comments were received.

Indigenous community

Serpent River First Nation

Proponent’s response

N/A

Status

The ministry will follow-up with this community during the Ministry Review comment period.

Comment #6

No response/comments.

Indigenous community

MNO Historic Sault Ste. Marie Métis Council

Proponent’s response

N/A

Status

N/A

Appendix C: Amended Environmental Assessment report

Contents are available in hard copy at the public record locations listed in this ministry review.