- The MOECC’s reply letter contains environmentally-significant factual errors – for example that the proponent’s current non-compliant water treatment system is equivalent to what was approved and that it has adequate capacity. Given this non-compliant water treatment system overflowed for days, it clearly is not equivalent and it does not have adequate capacity.
- The MOECC’s reply letter is very troubling as it claims that if the proponent’s work releases polychlorinated biphenyls (PCBs), the proponent could and would clean it up. It is not possible to “clean up” PCBs released to a river.
- But the biggest concern is that the proponent’s work should be treated as a brownfields redevelopment, as it is the site of an abandoned waterfront industrial facility. The MOECC has procedures for brownfields redevelopment here, yet they are not requiring the proponent to follow these requirements.
That is, instead of fulfulling their mandate of protecting the environment, the MOECC is catering to an irresponsible developer that is months behind schedule.
We have therefore sent this letter to the Minister of the MOECC, and we await their reply.