On Monday, June 5, you announced your approval of the Boundary Road landfill site. In the memo accompanying your decision, the MOECC declared, “In making a decision, the Minister carefully considered issues raised by the public, stakeholder groups, municipalities, and government reviewers, along with a detailed technical review by ministry staff.” Carefully Considered? You did? Has that phrase been redefined?
You gave eight reasons to support your decision. Five of them, reasons 3-5, 7 and 8, are repeated verbatim to set the stage and are succeeded by arguments contesting their significance.
“(3) On the basis of the proponent’s Environmental Assessment and the Ministry Review, the proponent’s conclusion that, on balance, the advantages of this undertaking outweigh its disadvantages appears to be valid.
(4) No other beneficial alternative method of implementing the undertaking was identified.
(5) The proponent has demonstrated that the environmental effects of the undertaking can be appropriately prevented, changed, mitigated, or remedied.
(7) All comments from government agencies, the public and Indigenous communities have been appropriately addressed.
(8) I am not aware of any outstanding issues with respect to this undertaking which suggest that a hearing should be required.”
Additional landfills are not needed, therefore reasons (3) and (4) are meaningless. Fundamental to the safety of any landfill is the stability of the land on which it is to be built. If the land is, or can easily become, unstable, containment of the waste will most likely be breached.
All reasonable attempts to prevent, or avoid, instability must be implemented, but they were not, thereby making reason (5) largely untrue. You and your Ministry ignored geological information, pertinent to the occurrence of a possible nearby, damaging earthquake, yet you claimed in reason (7) that all comments were addressed appropriately. If ignoring information germane to a possible nearby earthquake is appropriate, then expectations of environmental protection in Ontario are unrealistic. Despite your claim in reason (8) there is still at least that one major outstanding issue that must be addressed. Keep reading!
The region encompassing the Ottawa Valley is within the third most seismically active area in Canada, an area in which damaging earthquakes are known to have occurred. You, or at least those who advised you, should know that earthquakes occur because of rock movement along faults in response to stress. If there is evidence, or reasoned suspicion, of geologically recent movement along faults at, or near, a proposed landfill site, those faults must be investigated. Denial, such as that advanced by Golder Associates, is not an option.
I conducted a study in which I interpreted that geologically young faulting had occurred within 6km of the Boundary Road site. The fault interpretation was published in the peer-reviewed Canadian Journal of Earth Sciences. Golder was aware of it because they included the published paper in the reference list of their assessment report, but did not discuss the findings. Listing a paper, but not discussing it is unusual. It is, however, understandable when one realizes that doing so would not be beneficial to their client. I caught that deliberate omission, which Golder acknowledged. After professing that I had many mistakes they doggedly claimed those nearby faults do not even exist. That is favourable to their client because if there are no faults they cannot constitute an earthquake risk there.
The fault interpretation should be taken seriously enough to be verified. Each fault was inferred from the presence of scarps separating relatively level ground at a higher elevation from its adjacent counterpart at a lower elevation.
During the review process, I wrote to you and MOECC staff that the fault verification there is feasible. Data from Golder’s own report, photographs, explanatory figures and text were all sent in support of my exhortation that MOECC require that the consultant’s assertion of no faulting be proved. Why did you not do so?
Proving that the scarp is or is not the result of faulting would entail drilling into bedrock at each of two or three locations on each side of the escarpment (illustrated by the white arrows in the figure, along the escarpment). The objective would be to drill across the gradual change from red rock to grey rock with depth and determine the elevation of that transition zone at each location. If the transition zone on the higher side of the escarpment were higher than the transition zone on the lower side, the fault’s existence would be confirmed!
MOECC did not require the investigation of those faults therefore, besides being irresponsible, it is absolutely an outstanding issue.
Joe Wallach, Ph.D.