Ministry review of the Town of Blind River municipal waste management plan environmental assessment

Summary of our review

Who

Town of Blind River

What

The proponent, the Town of Blind River (Town), is proposing to increase the capacity of the current landfill by 201,203 cubic metres (m³) for non-hazardous residential, industrial, commercial, institutional, construction, demolition, biosolid and iron sludge wastes generated in the Town. The preferred alternative is to expand the existing waste disposal site. The current service area for the site is geographically defined as the area within the Town’s municipal limits. There is no change proposed to the service area.

When

The environmental assessment (EA) was submitted on August 30, 2024. The comment period for the EA ended on October 18, 2024.

Where

The landfill is located approximately 2 km east of the Town of Blind River on the north side of Highway 17 in the District of Algoma, Ontario.

Why

The Town’s landfill is approaching its approved capacity of 117,848 m³. The proposed additional capacity would extend the life of the landfill for 25 years.

Conclusions

The EA was prepared in accordance with the approved terms of reference (ToR) and contains the information necessary to assess the potential environmental effects of the proposed undertaking. The EA demonstrates that the Town would be able to meet its primary objective of providing a long-term solution for residual waste disposal set out in its terms of reference.

The ministry is proposing conditions be imposed if approved to ensure that the undertaking is carried out in accordance with the EA.

1. Environmental assessment process

The Environmental Assessment Act (EAA) sets out a proponent-driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of a proposed project on the environment.

In Ontario, the EAA sets out the general requirements for the preparation of an environmental assessment (EA), as well as the Ministry of the Environment, Conservation and Parks’ (MECP/ministry) evaluation process. For those proponents and projects subject to the EAA, the requirement of the EAA must be met before the project can proceed.

Proponents are required to address the potential effects of the preferred project on the natural, social, cultural and economic environments for the protection, conservation and wise management of the environment. The EA helps decision-makers to determine, based on the environmental effects, if a project should proceed, and if so, how the potential environmental effects can be managed.

EAs may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred project 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 Indigenous communities, government agencies, and the public to evaluate the alternatives and determine the preferred project. If the project is approved, the proponent is required to monitor the implementation of the project to demonstrate compliance with standards, regulations and conditions of the EAA approval.

On February 22, 2024, amendments to the EAA came into force and revoked Part II of the EAA. Pursuant to the transition provisions for these amendments, if a proponent has given a ToR to the ministry under subsection 6(1) of the EAA in respect of a project and no decision has been made under Section 9 or 9.1 of the EAA, the project is now deemed to be a Part II.3 project. As this is the case for this project, pursuant to these transition provisions the proposed project is deemed to be a Part II.3 project.

1.1 Terms of reference

Completing the EA process involves 2 separate steps—the ToR and the EA. The first step requires the proponent to prepare and submit a ToR to the ministry for review and decision by the Minister of the Environment, Conservation and Parks (minister).

The ToR is the work plan or framework for how the EA will be prepared. The ToR was prepared pursuant to section 17.6(2), of the EAA, which requires the proponent to follow a standard set of requirements for an EA. The ToR established the framework for the preparation of the EA, including a description of the purpose and rationale for the project, which was to provide additional waste disposal capacity, identifying and evaluating potential environmental effects (both positive and negative) and proposing mitigation measures and a consultation plan for obtaining input from Indigenous communities, government agencies and the public.

On July 11, 2008, the former Minister of the Environment approved the Town’s ToR. A lapse of time between ToR approval and EA submission is not uncommon for small municipal landfills. This can be due to municipal funding constraints or other priority projects, which may put landfill development on hold.

1.2 Environmental assessment

After receiving the minister’s approval on the ToR, the Town proceeded to carry out the EA. After completing the EA, including consultation, the EA was sent to the ministry for review and a decision by the minister which is subject to the approval of the Lieutenant Governor in Council.

A draft EA was made available to the public, Indigenous communities and agency review between February 21, 2024, and April 5, 2024.

On August 30, 2024, the Town submitted its Blind River Municipal Waste Management Plan Environmental Assessment to the ministry for review and a decision on the proposed undertaking. The EA was available for review and comment to the public, government review team (GRT) and Indigenous communities until October 18, 2024. Indigenous communities, the public, agencies and interested stakeholders had an opportunity to review the EA and submit comments to the ministry during the comment period. The GRT, comprised of provincial and local agencies, reviewed the EA to verify that the information and conclusions in the EA were accurate based on the mandates of each respective agency.

All comments sent to the ministry are considered by the minister before a decision is made on an application.

1.3 Ministry review

The EAA requires the ministry to prepare a review of the EA, known as the ministry review. The ministry review sets out the ministry’s evaluation of the EA, including whether the EA has been prepared in accordance with the approved ToR, meets the requirements of the EAA, and whether the evaluation in the EA is sufficient to allow the minister to decide whether to approve the proposed project.

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

The minister considers the ministry review when deciding on the application. The minister’s decision whether to approve the project described in the EA would be made after the end of the final 5-week ministry review comment period.

The ministry review provides an opportunity for Indigenous communities, the GRT and the public to see how their concerns with the EA and the proposed project have been considered. During the ministry review comment period, anyone can submit comments on the EA, the project and the ministry review. In addition, anyone can request that the minister refer the EA, or any matter relating to the EA, to the Ontario Land Tribunal for a hearing. Requests for a hearing must be made during this comment period. The minister would consider any requests for a hearing and determine in their sole discretion taking into account subsection 17.18(2) if a hearing is necessary.

A notice of completion of the ministry review was issued and is available for a 5-week comment period through the government of Ontario’s website, Ontario.ca. Copies of the ministry review have also been distributed electronically to potentially affected or interested Indigenous communities, the GRT and those who made comments on the EA submission.

2. The proposed project

2.1 Background

The landfill is located approximately 1 km north of Lake Huron and 2 km east of the Town of Blind River on the north side of Highway 17 in the District of Algoma, Ontario (see Figure 1). The landfill is situated on 2 hectares (ha) of Town owned land with a 4 ha fill area and a current approved waste disposal capacity of 117,848 m³. The landfill currently accepts non-hazardous residential, industrial, commercial and institutional, construction and demolition, biosolid and iron sludge wastes generated in the Town.

The landfill has been operating since the early 1970s and has been accepting waste generated within the Town since that time. The landfill operates under Environmental Compliance Approval (ECA) A713870 issued on November 26, 1980.

The existing landfill has reached its capacity and on October 26, 2023, the Town submitted an interim capacity expansion ECA application for an additional 2 years of waste disposal capacity to the ministry for review. Currently, the landfill is operating at the existing site until the ministry has made a decision on the interim ECA application. The Town submitted responses to ministry comments on the ECA application in January 2025, which are currently under review by the ministry. If approved, the proponent will be able to dispose of the Town’s additional waste in accordance with the amended ECA.

The Town would still require other provincial permits and approvals to construct and operate the project. Refer to section 6.1 of this review for more details.

2.2 Purpose

The purpose of the project is to address the waste management needs within the Town’s existing service area for an additional 25 years of capacity (from 2026 to 2050). The project would also include opportunities for waste diversion and disposal.

2.3 Study areas

The Waste Management Plan Service Area is confined to the municipal boundaries of the Town of Blind River. This area represents the geographical region directly served by the Waste Management Plan, meaning the plan’s recommendations and strategies are designed specifically for managing waste generated within the Town’s limits.

The EA Study Area covers a much broader region than the Service Area, encompassing several geographical townships that make up the incorporated Town of Blind River and covers approximately 82,400 ha. The EA Study Area includes the Townships of Cobden, Scarfe and Juillette, the north limits include Kamichisitit and Jogues Townships and the east limits include Timmermans, Mack and Striker Townships. The North Channel of Lake Huron bounds the south limits of the Study Area.

2.4 Local Environment

The existing landfill site is located within the municipal boundary of the Town to the east of the urban settlement area. The Town is primarily a residential community with a small industrial component and commercial and institutional components that provide basic services to the permanent residents and visitors to the community. The principle future development areas are lands to the north and east of the existing urban service and settlement area.

Residential development consists mainly of single or semi-detached housing and a small number of residential apartment buildings are found in the community. Many of the area lakes also support residential and cottage developments.

The landfill site is accessible from an existing entrance road via a gated entrance off Highway 17 and has an attendant’s shelter. Entry to the landfill is from the south and fill activities have recently taken place in the raised section of the landfill and various diversion areas around the perimeter of the raised section.

The site is situated in an area of relatively flat topography sloping gradually to the south toward Lake Huron. The terrain to the east and northeast of the landfill site is of higher elevations and groundwater has been interpreted to flow south-westerly, eventually discharging into Lake Huron approximately 1.2 km south of the landfill site.

The landfill operates as a natural attenuation site, relying on naturally occurring physical, chemical and biological processes to reduce concentrations of contaminants below ministry limits prior to reaching the property boundary. The Town has gradually increased the height of the site throughout its operating life.

2.5 Description of the proposed project

The current approved fill area at the landfill is 2 ha. The design for the proposed landfill expansion would provide an additional 201,203 m³ of capacity, which considers existing and anticipated diversion activities associated with the site, which are described in Section 4 of this review. This EA has been designed to meet the anticipated waste disposal needs for the existing service area of the Town over a 25-year planning period. There is no change proposed to the service area.

Landfill site design

The horizontal expansion would be limited to the area shown on the conceptual design drawing (Figure 3). The final contours of the expanded site would resemble a pyramid shape incorporating 4:1 side slopes leading up to the 223 m elevation, followed by gentler 20:1 slopes to the top. This design promotes proper drainage and minimizing water infiltration into the waste to control leachate generation and to prevent environmental contamination. A final cover comprising 0.6 m of granular material with low permeability and 0.15 m of topsoil would be placed above the final waste contours and then seeded to establish vegetation to aid in erosion control.

A buffer zone would be maintained around the perimeter of the landfill site serving to separate the landfill from surrounding land uses and providing a visual barrier and a safety margin. The presence of a buffer is important given the site’s proximity to Highway 17. The design also includes a contaminant attenuation zone to manage potential leachate contamination and allow for natural attenuation processes to occur. Natural attenuation involves physical, chemical and biological processes that naturally reduce contaminant concentrations in the leachate before it reaches the surrounding environment. The contaminant attenuation zone’s size and effectiveness would be monitored through a network of groundwater monitoring wells to ensure compliance with ministry regulations.

Site features

The existing gated access road off Highway 17 would be improved by alignment of the road to provide a dedicated lane for waste drop-off. Upon arrival landfill users would be required to report to the site attendant for screening and to receive direction identifying where to deposit waste material. The attendant shelter would be located near the public drop off area to provide the attendant with a clear view of site activity. The shelter would be equipped with a methane gas monitoring and ventilation system to ensure safety. A designated public drop off area would be incorporated into the site design having waste sorting bins along with a recycling area constructed nearby for metals, brush, recyclables and tires. If suspect waste is identified at the site entrance or drop off areas, the hauler would be required to show that the waste is acceptable for receipt at the site prior to disposal.

During landfilling operations, measures would be implemented to minimize the potential for leachate development, which include:

• directing surface water flow away from fill areas by maintaining appropriate grading
• compacting waste
• applying daily and interim cover
• progressively capping the fill area

The final cover would be monitored to ensure its stability and to monitor for the development of leachate springs. Local repair of cover materials may be necessary should cover integrity be degraded or if leachate springs form.

The operation and maintenance of the landfill expansion site would require that attention be paid to the surface drainage patterns. The surface water ponding on the fill area be eliminated wherever possible, and minimized, so that leachate generation through surface water percolation is minimized. Drainage of surface water is to be maintained through the areas of positive slope directing runoff to the proposed perimeter drainage ditch. Slopes would be required to be constructed in a manner that both erosion and sedimentation are minimized. A surface water management plan has been developed for and is currently being implemented at the site.

Designated areas would be allocated for storing soil that would be used for various purposes during landfill operations. This includes soil needed for daily cover, intermediate cover, and final cover. Having dedicated soil stockpiles confirms efficient operations and minimizes disturbance to other areas of the site. Permanent perimeter berms are not present at the site and not anticipated to be required with the proposed expansion as a result of visual and acoustical barrier effects afforded by the remote location and treed buffer at the edge of the landfill. If wind-blown debris is encountered the proponent may construct and use litter control fencing.

3. Results of the ministry review

The review provides an analysis of the EA. This review is not intended to summarize the EA, nor present the information found in the EA. For information on the evaluation process used to assess the alternatives, please refer to the EA. The EA and supporting documentation outline the EA planning process and demonstrates how the proponent selected the preferred project.

The purpose of the ministry review is to determine whether:

• the EA has met the requirements of the ToR and the EAA
• there are any outstanding issues with the EA
• the proposed undertaking has technical merit

The EA must:

• be prepared in accordance with the approved ToR
• include all the basic EAA information requirements
• demonstrate where all the additional commitments in the ToR were met, including studies and the consultation process

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry coordinated an analysis of the EA with the GRT that, in part, looked at whether the EA was prepared in accordance with the ToR. The ministry has concluded that the EA followed the framework in the approved ToR and meets the requirements of the EAA and commitments made in the ToR.

Appendix A summarizes this analysis.

3.1.2 Consultation

Section 17.3 of the EAA states:

One of the key requirements of the EAA is consultation with Indigenous communities, agencies and the public during the preparation of the EA. The proponent is responsible for meeting its consultation requirements prior to submitting the EA to the ministry and the consultation must be carried out in accordance with the consultation plan in the approved ToR.

The Town’s consultation program included:

• establishing a project website with EA documentation
• distribution of notices (notice of commencement, notice of public open house)
• hosting public open houses (allowing for discussion)
• consultation with agencies and organizations
• discussion groups and presentations
• engagement with Indigenous communities and groups
• circulating notices via local newspapers and mail outs
• newsletter updates
• publishing the draft EA for review and a comment period from February 21, 2024 to April 5, 2024

The Town documented its consultation activities adequately in the EA. Section 12.0 of the EA provides an overview of the consultation activities, with the complete consultation record documented in the EA’s Consultation Report.

Following submission of the EA to the ministry, the ministry undertook consultation in accordance with the EAA, beginning on August 30, 2024, and ending on October 18, 2024. Indigenous communities, the GRT, and members of the public had an opportunity to review the EA and submit comments to the ministry regarding the fulfillment of ToR requirements, the EA, and the proposed project. Comments received by the ministry during the comment period were forwarded to the Town for a response. A summary of the comments received along with the Town’s responses is included in Table 1 of Appendix B to this Review.

Government review team

Consultation with the GRT occurred throughout the EA process. This included:

• pre-submission discussions
• technical meetings with ministry staff and key members of the GRT
• an opportunity to review the draft EA

The Town received comments from the GRT, including the ministry, and the Ministry of Citizenship and Multiculturalism (MCM). Themes within comments received through engagement with the GRT on the draft EA include:

The EA should include a summary of how the EA has been prepared in accordance with the approved ToR, summary of alternatives and rationale for preferred landfilling alternative, inclusion of a description of the environment, list of the criteria, indicators and data sources used, and the alternative rankings should be clarified.

The EA should contain a list of Indigenous communities that were considered for consultation and a consultation summary for each community.

The EA should be updated to include a list of technical studies to be completed, study area rationale, additional information on the preferred alternative’s conceptual design, greater mitigation and monitoring detail, the site’s remaining waste capacity, consideration of the Food and Organic Waste Policy Statement and a summary of consultation.

The EA should extend the contaminate attenuation zone, additional parameters should be added to groundwater sampling, expansion of the project’s monitoring wells.

The project should include more detail of climate change impacts, greenhouse gas emissions, surface drainage, the identification of surface water sampling locations and an evaluation of the site’s leachate surface water impacts. Additional detail should include a surface water monitoring program and contingency plan, a discussion of the impact of the preferred alternative on surface water, groundwater flow direction should be added, and the groundwater monitoring data should include road salt impacts.

The EA’s alternative methods should include air quality impacts, odour and dust mitigation measures, and species at risk should be correctly classified.

The EA should reclassify certain species (such as the Bald Eagle, Smith’s Bulrush, Milksnake, among others) as they are no longer considered SAR (Species At Risk).

Updates to the EA should reflect the Town’s cultural heritage resources which include built heritage resources, cultural heritage landscapes and archaeological resources.

The ministry is satisfied with the responses the proponent provided in the EA’s documentation to the GRT’s concerns. A summary of consultation with the GRT during the preparation of the EA is included in Section 12.0 of the EA and its Consultation Report.

Following the formal submission of the EA to the ministry, GRT members were provided with a copy of the final EA for review. Comments from the MECP and MCM were received during the submission comment period and forwarded to the Town for a response. Refer to Section 3.3. of this review or Appendix B regarding these comments.

Public consultation

The Town used a variety of consultation methods to consult with the public including public notices, establishing a project website, 5 public open houses, discussion groups, newsletter updates and direct community engagement via mail-outs and newspapers. The Notice of Commencement of EA was issued in February 2009. The public open houses were held on April 22, 2009, September 13, 2011, February 22, 2016, November 4, 2019, and November 12, 2024. The open house meetings in 2009 and 2011 were to collection information post ToR approval (For example, presenting background information, the existing waste management system, waste diversion strategies, among others). The open house meetings in 2016, 2019 and 2024 were to discuss the draft and final EA (For example presenting updates the on EA and preferred alternative, next steps, discussions with stakeholders, among others).

Themes within comments received through engagement with the public during the open houses included:

• investigation of other alternatives besides a waste disposal site
• recovery of recyclable materials deposited in the old landfill site
• hazardous materials should not be deposited in the landfill
• the landfill should utilize leaf composting
• fencing should be included in the site design
• better control of the separation of recyclable materials
• no surface or groundwater leachate should drain into Lake Huron

The ministry is satisfied with the responses the proponent provided in the EA documentation to the concerns raised during public consultation. A summary of consultation with public stakeholders during the preparation of the EA is included in Section 12.0 of the EA and its Consultation Report.

The Town made the draft EA and its supporting documents available on the project website for members of the public for comment from February 21, 2024 to April 5, 2024.

The notice of submission of the final EA was issued on August 30, 2024 and was circulated to the project contact list as well as posted on the project website.

Indigenous community consultation

In addition to the requirement in the EAA that the proponent consult with interested persons, the ministry delegated to the proponent the procedural elements of the Crown’s duty to consult with Indigenous communities whose existing constitutionally protected rights may be impacted by the proposed project.

At the start of the EA process the following Indigenous communities were identified for consultation purposes:

• North Channel Métis Council
• Historic Sault Ste. Marie Metis Council
• Garden River First Nation
• Batchewana First Nation
• Wikwemikong Unceded First Nation
• ZhIIbaahaasing First Nation
• Sagamok Anishnawbek First Nation
• Mississauga First Nation
• Serpent River First Nation
• Whitefish River First Nation
• Bar River Métis Community
• Thessalon First Nation
• Métis Nation of Ontario

When the proponent began work again in 2017, the ministry updated the list of communities for communities, consistent with Ontario’s consultation policy and approach and delegated the procedural aspects of the Crown’s duty to consult. The following communities were identified for consultation:

• Mississauga First Nation
• Serpent River First Nation
• Thessalon First Nation
• Sagamok Anishnawbek First Nation
• Whitefish River First Nation
• Bar River Métis Community
• Métis Nation of Ontario

Formal study notices were circulated to Indigenous communities. Correspondence from the Town invited the communities to participate during each round of EA consultation. In addition to the formal study notices and open houses, Indigenous communities were given draft studies to review and comment on. Additional engagement activities were undertaken during the preparation of the EA to obtain input from the identified Indigenous communities, including meetings, follow-up calls and emails to verify receipt of materials including the draft EA.

Due to the time elapsed between when the 2009 Notice of Commencement for the EA was sent to Indigenous communities, the proponent followed up with reengagement letters to continue consultation activities on April 6, 2017. In response to these reengagement letters, only the Métis Nation of Ontario (MNO) and Mississauga First Nation (MFN) responded to the proponent requesting meetings to discuss the project in further detail. Meetings with MNO were held on July 28, 2017 and September 26, 2017, and with MFN on August 31, 2017. Major themes within the comments received during these Indigenous community reengagement meetings included:

• MNO had the following concerns relating to landfill design:
  • if the water treatment plant ‘s industrial iron sludge would be allowed at the landfill
  • if soil permeability verified prior to use in the landfill’s progressive capping
  • if the side slopes of the landfill monitored for stability
• MFN requested that they be kept informed during the EA process and indicated they will contact the Town if they have any questions

The ministry is satisfied with the responses the proponent provided in Section 8.16 of the EA documentation to the Indigenous community concerns during the re-engagement meetings. The draft and final EAs were also provided to the Indigenous communities in February 2024 and August 2024, respectively. To date, no comments were received from Indigenous communities on the draft or final EA.

The consultation carried out by the Town with Indigenous communities is summarized in the EA in Section 12.13.1 and documented in Volume V, Appendix I.02 of the Record of Consultation.

Ministry conclusions on the consultation program

The EAA requires that the proponent consult with all interested persons during the

preparation of the EA, provide a description of consultation activities undertaken by the proponent, and document consultation results. Overall, the ministry believes that the Town provided sufficient opportunities for Indigenous, government agency and public consultation during the preparation and finalization of the EA.

The ministry is satisfied that the EA consultation that was undertaken is consistent with the Codes of Practice for Consultation in Ontario’s EA process and best practices, meets the requirements of the EAA, and followed the consultation plan outlined in the approved ToR.

3.2 EA process

An 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 environmental effects of alternatives against criteria, and select a preferred alternative based on the results of the evaluation.

The Town followed a logical and transparent decision-making process to select the preferred method for expanding the landfill to be able to continue providing waste disposal services. Below is a summary of the EA process followed, including the study areas used, and the methodology for assessing alternatives and environmental effects.

Please refer to Appendix A of this review for the ministry’s analysis of how the EA has met the requirements of the EAA and has been prepared in accordance with the approved ToR.

3.2.1 Description of the environment in the study areas

A preliminary description of the existing environment was provided in Section 5.0 of the ToR. The ToR contained the commitment that a more detailed description of the existing environmental conditions would be prepared as part of the EA to assess the potential effects of the alternatives on the environment.

Section 4.0 of the EA describes a general inventory of the existing conditions within the project’s study area which is comprised of the municipal limits of the Town of Blind River. Detailed information describing the existing environment within the study areas has been included in the EA’s technical reports.

A description of the existing environment is completed in section 4.0 of the EA for each environmental criterion to provide the baseline for determining the potential effects resulting from the project.

The ministry is satisfied that a broad definition of the environment was considered and a description of existing environmental conditions in the study areas was provided.

3.2.2 Alternatives to the undertaking

The Town prepared its EA in accordance with the requirements under sections 17.6(2) of the EAA. As part of those requirements the EA was “unfocused” resulting in the Town developing and assessing “alternatives to” long term waste management and ‘alternative methods’ of increasing waste disposal capacity over the landfill’s planning period. The EA prepared by the Town developed and assessed ‘alternatives to’ long term waste management.

As part of the EA process set out in the approved ToR, the Town is required to develop a reasonable range of ”alternatives to” long term waste management in the Town. The ToR discussed “alternatives to’” at a conceptual level by looking at ways to provide additional waste disposal capacity for the Town. This was carried forward into the EA and discussed and reviewed in more detail.

The Town identified 4 key components of municipal waste management plans which consists of reduction and diversion, handling and collection, and processing and disposal. Within each component, various programs were considered, drawing from past similar projects and the ToR. This resulted in a list of 19 potential waste management programs, which were then screened against 4 criteria (program proven, locally manageable, area appropriate and compliance with regulations and policies) to develop a shortlist of “alternatives to” the project.

The Town evaluated the shortlisted programs by using a set of environmental, technical and economic criteria. The environmental criteria examined:

• the program’s effects on the natural environment (air, water, land)
• social environment (transportation, community well-being, aesthetics)
• cultural environment (built heritage, archaeological sites, cultural landscapes)
• economic environment (financial costs, property values, local businesses)

Technical criteria assessed:

• the program’s efficiency in addressing the waste management problem
• its adaptability to changing conditions
• its proven track record, successful implementation and operation in comparable contexts like Northern Ontario

Economic criteria evaluated the relative cost of implementation, operation, and maintenance, considering the Town’s financial capacity and resources.

Each waste management program was assigned a relative impact score of low, medium, or high for each criterion based on available data from existing reports, studies, public, agency and expert input. In addition, the evaluation also considered each program’s advantages and disadvantages for an understanding of potential program benefits and drawbacks. The waste management program evaluation concluded that landfilling was the only alternative to that warranted further consideration.

3.2.3 Assessment of alternative methods

The EA describes that the alternative methods for the project were evaluated in 2 phases to identify the best option for providing additional waste disposal capacity: expanding the existing landfill or establishing a new site, which meets the project’s ToR requirements.

Section 8.0 of the EA reports that the main goal of Phase 1 was to narrow down the options for providing additional waste disposal capacity. The 2 basic choices were to expand the existing landfill site or establish a new "greenfield" site at one of several potential locations.

Six candidate locations within the study area (Figure 2) were assessed during Phase 1 against criteria grouped into 5 categories:

• natural environment
• social environment
• economic environment
• cultural environment
• technical considerations

This assessment considered factors such as potential impacts on:

• the surrounding environment
• residents, businesses
• transportation
• heritage resources
• cost-effectiveness

Each location was assigned a relative impact score of low, medium, or high based on indicators and data sources, including:

• aerial photography
• field assessments
• the Town’s Official Plan
• ministry mapping
• historical operating costs
• community consultations

One of the locations (Location 2) was removed from consideration bECAuse it was being developed for other uses, though it was still included in the Phase 1 evaluation.

Section 9.0 of the EA describes that Phase 2 focused on a detailed assessment of expanding the existing landfill site was the preferred option from Phase 1. This phase used the same criteria groups as Phase 1 but expanded them to include impacts along potential transportation routes, such as those on the surrounding environment, residents, businesses, and Indigenous communities. Throughout this process, the Town consulted with government agencies, Indigenous communities, and the public, using methods like open houses, meetings, and task reports to gather input and ensure transparency. The evaluation results indicated that the preferred alternative (Figure 3) was to expand the existing landfill site due to several factors including leveraging existing infrastructure, minimizing environmental impacts, and being the most cost-effective option.

The “do-nothing” alternative was also considered as a benchmark comparison associated with the analysis in the EA of the advantages and disadvantages of proceeding with the preferred alternative. As a result, the ministry gained an understanding of proceeding with the project versus a do-nothing scenario in this regard.

3.2.4 Assessment of environmental effects

The Town describes the potential effects of the project in section 8.1.3 (Criteria Ranking: Net Environmental Effects) and section 11.9 (Consideration of Cumulative Effects) of the EA. The EA includes a summary of the net effects assessment for each of the environmental criterion (natural environment, social environment, economic environment, cultural environment, and technical considerations), an assessment of cumulative effects and advantages and disadvantages of each alternative. The EA assesses both positive and negative effects of the alternatives. The evaluation method included identifying proposed mitigation measures to minimize or avoid any potential negative environmental effects of the preferred project being considered as part of the EA process. The EA identifies the net effects of the project during both construction and operation.

The EA’s natural environment net effects assessment included potential changes to:

• terrestrial features
• wildlife
• aquatic features
• agriculture resources
• groundwater resources
• surface water resources
• air quality

The social environment net effects assessment included:

• potential displacement or disruption to residents,
• displacement or disruption to institutional, community and recreational features
• impacts to Indigenous communities
• effects on future planned land uses
• noise
• transportation related considerations

The economic environment net effects assessment included:

• potential displacement or disruptions to existing businesses and employees
• displacement or disruptions to forestry and aggregate industries
• the cost of implementing the alternative
• transportation related considerations

The cultural environment net effects assessment included:

• potential changes to built heritage and cultural heritage resources
• the disturbance or destruction of archaeological resources
• the impacts to cemeteries

The technical consideration net effects assessment included potential for each candidate location to address the Town’s waste disposal needs while minimizing environmental impacts to the adjacent areas.

Proceeding with the project is predicted to cause net effects to the environment. However, when considering the implementation of the mitigation measures described in Section 8.0 of the EA, the net effects associated with the project can be mitigated by standard and site-specific environmental protection measures.

Source Water Projection

The existing site and proposed landfill expansion are not located within a wellhead protection area. The proposed landfill has a contaminant attenuation zone of 27.5 ha and is capable of meeting ministry groundwater protection requirements. The area of the landfill expansion has a high-water table containing sandy and gravelly deposits over bedrock with the occurrences of cobbles and slit. This coarse-grained (sand and gravel) overburden enables the downward flow of water and contaminants and provides protection to aquifers from surface sources of contamination. The landfill is not a source of contamination to the municipal drinking water supply as the Town’s groundwater supply is obtained from wells approximately 5 km west of the current waste disposal site.

Monitoring requirements and a monitoring plan would be formalized during the project’s detail design phase and submitted to ministry for review in support of an ECA, to establish and operate the expanded landfill site. For the landfill expansion, approval is required under the EAA and Environmental Protection Act. Obtaining approval under these legislations would require demonstration that the expansion does not pose a threat to the aquifer and drinking water.

Climate change impacts

The effect of the landfill expansion on climate change and the effect of climate change on the landfill expansion are discussed in Section 11.10 of the EA. The landfill expansion would contribute to climate change through the generation and emission of landfill gases. The modeling suggests that the expanded landfill’s peak annual greenhouse gas emissions would be approximately 45 % higher than the peak emissions from the existing site. The effects of the project on climate change are mitigated given the small quantities of waste expected to be received, subsoil and cover characteristics, and its relative size.

The effects of climate change on the landfill expansion are expected to impact the management of surface water that collects on site due to increasingly severe weather events, as well as higher annual mean temperatures. Additional effort may be required to maintain the site access and interior roads, in addition to erosion and sediment control as part of the site’s surface water management works due to potentially more severe rainfall events.

Climate change was considered during the design of the site’s surface water management where the approach used is consistent with the approaches described in ministry landfill standards. According to the proponent’s EA, the design allows the system to accommodate a potential increase of up to 10 % in the volume of surface water runoff generated. The EA anticipates the design of the site’s surface water management system will be sufficient in managing potential increased flows volumes due to climate change.

Cumulative effects

The Code of Practice for Preparing and Reviewing Environmental Assessments in Ontario (2014) encourages proponents to include information about the potential cumulative effects of the preferred alternative in combination with past, present and reasonably foreseeable future activities. The EA outlined steps for determining cumulative effects and determined that the effects from the landfill expansion would not lead to combined impacts from other projects or activities in terms of biology, hydrogeology, surface water, atmospheric, archaeological, social, planned land use, visual, noise, odour, business, and transportation. There are currently no known development applications within 1 km of the proposed project.

3.2.5 Monitoring

Sections 11.7 and 11.8 of the EA describe environmental effects monitoring activities used to ascertain the effectiveness of mitigation measures, in addition to contingency measures to address unexpected occurrences.

3.2.6 Ministry conclusions on the EA process

Overall, the ministry is satisfied with the proponent’s decision-making process and that the process is consistent with the requirements of the EAA and the approved ToR. The EA confirms the need for the project, provides a description of the environment that would be potentially affected, it uses the EAA ’s broad definition of the environment, and considers alternative methods for the landfill’s site development. The EA identifies the potential effects of the alternatives along with mitigation measures and assesses them based on their relative advantages and disadvantages. Net effects of the preferred alternative are identified in the EA and monitoring measures are proposed to manage environmental effects.

3.3 Comments on the project

3.3.1 Key issues

Issues and concerns from the GRT regarding the proposed project were received by the ministry during the review and comment period that followed the submission of the final EA. All comments received, along with the responses provided by the Town, are included in Tables 1 in Appendix B of this review. This section of the review summarizes only the key issues that were raised during the EA process.

Government review team comments

MCM

The MCM reviewed the final EA and were satisfied that the comments they provided on the draft EA were addressed except for a minor omission to a table in the final EA. The proponent updated the table to address MCM’s suggestion of making the language used more consistent with the terminology of the legislative framework, specifically the term “built heritage resources”.

MECP

Groundwater

The MECP groundwater reviewer was satisfied that the proponent updated the final EA to provide responses to draft EA comments. The reviewer recommends that MECP consider imposing a condition of approval related to the groundwater monitoring program, including:

• installation of additional groundwater monitoring wells at the site
• completing 1 year of spring and fall groundwater elevation and quality monitoring/sampling at all monitoring wells
• reassessing the sizing of the contaminant attenuation zone

In addition, the reviewer recommends the condition of approval for the groundwater monitoring program include requirements to monitor total cyanide, bromide, fluoride, organic nitrogen, and hardness in addition to those under Column 1 of Schedule 5 of the Ontario Landfill Standards guideline.

Surface Water

The MECP surface water reviewer was satisfied that the proponent updated the final EA to provide responses to draft EA comments. The reviewer recommends that turbidity, bromide, and sodium should be added to the list of parameters for surface water samples. Additional surface water sampling locations may be required if the groundwater direction changes or if leachate is found to extend beyond current sampling locations. Investigations should be performed for single groundwater or surface water sampling exceedances.

Indigenous Advisor

The ministry’s Indigenous advisor was satisfied that the proponent updated the final EA to provide responses to draft EA comments. The Indigenous advisor recommends that the results of consultation with Indigenous communities including supporting emails, correspondence for each interaction be included in the final EA.

Species at Risk

The ministry’s Species at Risk (SAR) Branch reviewer recommends the removal of Mountain Lion (or Cougar as referred to on the SAR List) as it is unlikely that they would occur in the study area or to correct its status to a species of Special Concern. The reviewer also suggests that the EA includes an explanation of the implications of the SAR status for identified species, the potential for on site SAR, and the resources available to workers to identify them. The SAR Branch reviewer was satisfied that the proponent updated the final EA to address their comments.

Indigenous Community Comments

During the 7-week comment period on the EA, the ministry followed up with the identified Indigenous communities by email on September 18, 2024 and October 10, 2024, and phone on September 20, 2024 and October 10, 2024 to confirm whether they would be providing comments on the final EA.

Only Whitefish River First Nation provided an email response on September 19, 2024, stating that their review of the final EA was being completed and any comments the community had would be submitted. To date, no comments on the project from the Whitefish River First Nation were received by the MECP.

3.3.1 Conclusion

The Town responded to, and addressed, all comments received during the EA submission comment period on the final EA study report. The ministry is of the opinion that the proposed landfill expansion would be designed and operated to comply with the ministry’s standards and that the environmental effects of the proposed project would be managed through the commitments made in the EA, through conditions of approval, or through additional work that must be carried out by the Town in support of future approval applications, if the EA is approved.

4. Waste Diversion

The Town maintains a weekly curb side recyclables program in addition to its curb side waste collection program. The Town’s annual monitoring reports lists its annual recyclables diversion rate in the range of 10% of the total waste and recyclables volume, which is a rate typical for remote communities.

The landfill accepts tires, wood waste, scrap metals and "white" goods for diversion at the site and are stockpiled in designated areas for shipment for recycling or disposal by other means (e.g., burning clean wood waste). Household hazardous wastes including corrosive, toxic, reactive and flammable wastes are collected and disposed of by a qualified contractor on household special waste days scheduled by the Town. During household special waste days (typically once every 2 years), wastes from the industrial, commercial and institutional sectors is not accepted. It is the responsibility of businesses to dispose of their own hazardous waste in accordance with ministry requirements.

To prolong the life of the current and proposed landfill disposal sites, the Town would continue to implement diversion programs, keeping unnecessary wastes from landfill.

5. Summary of the ministry review

The review has explained the ministry’s analysis of the Blind River Municipal Waste Management Plan EA.

This review documents the ministry’s conclusion’s including:

• That the EA complies with the requirements of the approved ToR and has been prepared in accordance with the EAA. The EA provides sufficient information about the project and its potential impacts to enable a decision to be made about the application to proceed with the project.

• That the EA includes: an assessment and evaluation of alternative methods to arrive at the preferred project, an assessment of the potential environmental effects of the alternative methods and the preferred alternative, an assessment of the advantages and disadvantages of the preferred alternative and provides a description of mitigation and monitoring measures to address the potential negative environmental effects of the proposed project.
• That appropriate opportunities were provided for the Indigenous communities, GRT and the public to participate and comment during the development of the EA. Concerns raised by Indigenous communities, the GRT, and the public have been considered and addressed by the proponent either in the EA, or through a commitment to consider the concerns through future discussions, commitments and permitting and approval processes.

• If approval of the project is obtained under the EAA, standard conditions of approval are recommended for the implementation of the project (see Section 5.1.1 below).

5.1.1 Proposed conditions of approval

The ministry proposes to include several standard conditions of approval should the project be approved to proceed:

• general requirements to comply with the EA and commitments made
• documentation requirements for the public record
• compliance monitoring provisions for the proponent to conduct and report on
• preparation of a complaints protocol to respond to all complaints received during construction and operation

Below is an outline of potential conditions that may be recommended to the minister for inclusion in any approval of the undertaking:

• additional requirements for the groundwater monitoring program, including the need to reassess the size of the contaminant attenuation zone

This list is not exhaustive and additional conditions may be proposed subject to further review and consultation. During the 5-week review comment period and prior to the ministry making a recommendation to the minister regarding approval of the project, additional conditions may be proposed to ensure that the environment remains protected.

6. What happens now

The ministry review would be made available for a 5-week comment period. During this time, all interested parties, including Indigenous communities, the GRT, and members of the public can submit comments to the ministry about the proposed project, 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 Ontario Land Tribunal for a hearing if they feel their environmental concerns have not been considered.

At the end of the review comment period, ministry staff would make a recommendation to the minister regarding approval of the project. When making a decision, the minister would consider the requirements set out in the EAA, including the purpose of the EAA, the EA itself, the review of the EA, comments received during the formal comment periods, in addition to other matters the minister may consider relevant.

The minister will make one of the following decisions:

• give approval to proceed with the project
• give approval to proceed with the project subject to conditions
• refuse to give approval to proceed with the project

Prior to making that decision, the minister may also refer either part of or the entire EA to mediation or to the Ontario Land Tribunal for a decision.

The minister’s decision on the application is subject to the approval of the Lieutenant Governor in Council.

6.1 Additional approvals required

If EAA approval is granted, the Town would still need to obtain other permits and approvals to design, construct and operate this project. Section 14.0 (Other Approvals) of the EA outlines all additional approvals that may be required, such as:

• amendments to the existing ECA under the Environmental Protection Act
• Surface Water Management Plan and System design for approval under Ontario Water Resources Act (OWRA)

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

6.2 Modifying or amending the proposed project

Any changes to the undertaking outside the scope of this EA may be considered a new project pursuant to the EAA and may require the completion of a new comprehensive EA or the Environmental Screening Process for Waste Management Projects in accordance with Ontario Regulation 50/24 made under the EAA.

Making a submission

A 5-week public review period would follow the publication of this ministry review. During this time, any interested parties can make submissions about the proposed project, the EA, or this Review. Should you wish to make a submission, please email devon.wills@ontario.ca and address it to:

Kathleen O’Neill, Director
Environmental Assessment Branch
Ministry of the Environment, Conservation and Parks
Re: Blind River Municipal Waste Management Plan Environmental Assessment

Attention: Devon Wills, Project Officer

Your privacy

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 EAA or is collected and maintained for the purpose of creating a record that is available to the general public as described in s.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.

Public record locations

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

Ministry of the Environment, Conservation and Parks
Environmental Assessment Branch
135 St. Clair Avenue West, 1^st Floor 
Toronto, Ontario 
416-314-8001
1-800-461-6290
Fax: 416-314-8452

Appendix A: Environmental Assessment Act requirements

Requirements in O. Reg. 53/24: General and Transitional Matters

Summary of the EA

O. Reg. 53/24: s. 4(1)

EA must contain a brief summary of the EA organized in accordance with the matters set out in subsection 17.6 (2) of the Act.

Analysis of the EA

The EA includes an executive summary organized in accordance with the matters set out in subsection 17.6(2) of the Act.

List of proponent-led studies

O. Reg. 53/24: s. 4(1)

EA must contain a list of studies and reports which are under the control of the proponent, and which were done in connection with the project or matters related to the project.

Analysis of the EA

The list of studies and reports which are under control of the proponent and were undertaken in connection with the EA are listed in Section 8.1.1. This section contains a table outlining the background studies and reports (data sources) conducted for the EA.

List of additional studies

O. Reg. 53/24: s. 4(1)

EA must contain a list of studies and reports done in connection with the project or matters related to the project of which the proponent is aware and that are not under the control of the proponent.

Analysis of the EA

The list of studies and reports which are not under control of the proponent and were undertaken in connection with the EA are listed in Section 8.1.1.

Maps

O. Reg. 53/24: s. 4(1)

Where the EA is for a project with a fixed location, at least 2, well-marked, legible and reproducible maps showing the location of the project and the area to be affected by it.

Analysis of the EA

Figure 2.1 (Key Plan) in Section 2.1 of the EA shows the Study Area of the Blind River Landfill site.

Figure 2.3 (Site Plan) in Section 2.3.1 of the EA shows the current layout of the Blind River site.

Figures 7.1 in section 7.1 of the EA show the potential candidate locations for the proposed landfill sites.

Figures 10.1 (Conceptual Design) in section 10.6 of the EA show the site layout for preferred alternative.

Problem/opportunities

1. Identify an existing problem or opportunity and purpose of the project:

Environmental Assessment Act Sections 17.4(2)(c), 17.6(2)(a) and 17.6(2)(b)(i) and (II).

The EA must contain a description of the purpose of the project. This should include an explanation of the problem or opportunity that prompted the proposed activity.

The EA must include a description of a statement of the rational for the project and its alternative methods.

If a specific project has been identified provide a brief description.

Analysis of the EA

The EA is required to follow Section 3 of the ToR which outlines the project description. Section 1.0 of the EA indicates that the purpose of the ToR is to set the scope and describe the process that will be undertaken to address the problem of diminishing disposal capacity at the existing site. The ToR was prepared documenting the planning process to obtain EA approval for the disposal component of the Municipal Waste Management Plan. The ToR was approved by the ministry in 2009.

The purpose of the project is to address the waste management needs within the Town’s existing service area for an additional 25 years of capacity (from 2026 to 2050). The project will also include opportunities for waste diversion and disposal.

The landfill is located approximately 1 km north of Lake Huron and 2 km east of the Town of Blind River on the north side of Highway 17 in the District of Algoma, Ontario. The proponent is proposing to add 201,203 million m³ of non-hazardous residential, industrial, commercial and institutional, construction and demolition, biosolid and iron sludge wastes generated in the Town. The preferred alternative is to expand the existing waste disposal site. The current service area for the site is geographically defined as the area within the town’s municipal limits covering approximately 82,400 ha. There is no change proposed to the service area.

Alternatives

1. Description and statement of the rationale for the alternatives methods

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2)(b)(II).

“Alternative methods” include a description of different ways of implementing the project (locations and designs).

A reasonable range of “alternative methods” should be identified and outlined.

Analysis of the EA

Section 8.0 of the EA describes that the alternative methods for the project were evaluated in 2 phases to identify the best option for providing additional waste disposal capacity: expanding the existing landfill or establishing a new site, which conforms with the project’s ToR requirements.

The evaluation results indicated that the preferred alternative was to expand the existing landfill site due to several factors including leveraging existing infrastructure, minimizing environmental impacts, and being the most cost-effective option.

The ministry is satisfied that a reasonable range of alternative methods were described in the EA and evaluated using a broad range of environmental criteria and measures.

Evaluation 

1. Description of the environment for the project and alternatives

Environmental Assessment Act Sections 17.6(2)(c)(i) and 17.4(2)(c).

Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions.

The EA must provide a description of the existing environmental conditions in the study area.

The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed project and or the alternatives.

Analysis of the EA

Section 4.0 of the EA describes a general inventory of the existing conditions within the project’s study area which is comprised of the municipal limits of the Town of Blind River. Detailed information addressing the existing environment of the study areas has been included in the EA’s technical reports.

A description of the existing environment is completed for each environmental criterion to provide the baseline for determining the potential effects resulting from the project. The data which was collected from available secondary source information and the sources used have been included in Section 9 of the EA.

The environmental components described in the EA are:

• climate
• geology and hydrogeology
• Surface Water Resources
• vegetation, terrestrial biology
• aquatic animal life and fisheries
• species at risk
• provincial parks and preserve areas
• social and cultural environment
• land use
• Indigenous communities
• utilities
• cultural heritage resources
• recreation
• official plans and policy documents
• economic environment
• municipal services
• transportation environment

The ministry is satisfied that a broad definition of the environment was considered and a description of existing environmental conditions in the study area was provided.

2. Description of the potential environmental effects for alternatives

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2)(c)(II).

The EA must include a description of the effects that will be caused or might reasonably be expected to be caused to the environment. Both positive and negative environmental effects should be included.

The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project.

Impact assessment methods and criteria used during the evaluation should be identified.

The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA.

Analysis of the EA

The Town describes the potential effects considerations of the project in Section 7.0 (Potential Net Effects) and section 7.5 (Consideration of Cumulative Effects) of the EA. The EA includes a summary of the net effects assessment for each of the environmental criterion (natural environment, socio-cultural environment, atmospheric air quality, and economic environment), an assessment of cumulative effects and advantages and disadvantages of each alternative. The EA assesses both positive and negative effects of the alternatives. The evaluation method included identifying proposed mitigation measures to minimize or avoid any potential negative environmental effects of the preferred project being considered as part of the EA process. The EA identifies the net effects of the project during both construction and operation.

The EA’s Natural environment net effects assessment included potential changes to:

• terrestrial features
• wildlife
• aquatic features
• agriculture resources
• groundwater resources
• surface water resources
• air quality

The Social environment net effects assessment included:

• potential displacement or disruption to residents
• displacement or disruption to institutional, community and recreational features
• impacts to Indigenous communities
• effects on future planned land uses
• noise
• transportation related considerations

The Economic environment net effects assessment included:

• potential displacement or disruptions to existing businesses and employees
• displacement or disruptions to forestry and aggregate industries
• the cost of implementing the alternative
• and transportation related considerations

The Cultural environment net effects assessment included:

• potential changes to built heritage and cultural heritage resources
• the disturbance or destruction of archaeological resources
• impacts to cemeteries

The Technical consideration net effects assessment included potential for each candidate location to address the Town’s waste disposal needs while minimizing environmental impacts to the adjacent areas.

Proceeding with the project is predicted to cause net effects to the environment. However, when taking into account the implementation of the mitigation measures described in Sections 7.0 and 7.5 of the EA, the net effects associated with the project can be mitigated by standard and site-specific environmental protection measures.

3. Description of the actions necessary to prevent, change, mitigate or remedy the environmental effects for the alternatives

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2)(c)(iii).

A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

Analysis of the EA

Section 11.9 of the EA describes that based on the evaluation of alternative methods carried out for the landfill expansion, negative net environmental effects on the natural, social, economic, cultural or technical environments are anticipated to be mitigated to acceptable levels with implementation of the proposed mitigation measures. There is no other known past, present or foreseeable future activities in the vicinity within a similar timeframe as the proposed landfill expansion. No negative cumulative effects are anticipated.

Section 11.8.3 of the EA describes and presents a list of potential effects and possible mitigation measures in Table 11.4 which can be implemented when the project’s potential environmental effects exceed or differ from the expected net environmental effects.

4. Evaluation of advantages and disadvantages to the environment for the project and alternatives

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2)(d).

The preferred alternative should be identified through this evaluation.

Analysis of the EA

Section 6.0 (Evaluation of Waste Management Programs) identified the list of waste management programs summarized in Table 6.1. The evaluation of “alternatives to” (as in alternative waste management programs) considered the characteristics of the specific programs, their applicability and suitability, as well as their environmental effects and impact management measures.

The EA presents a summary of the differences between each alternative method and summarizes the advantages and disadvantages of the preferred alternative based on the net effects of the preferred alternative.

The EA adequately describes the advantages and disadvantages of the proposed project to the environment based on potential environmental effects.

5. Description of consultation with interested stakeholders

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2)(e).

A description of any consultation for the project and the results of that consultation must be documented. The description should include:

• consultation methods used
• frequency of consultation
• dates that events occurred
• target audience
• descriptions of key milestones for which stakeholders are providing input
• comments received

The EA must identify any Indigenous community consultation efforts that have been made including:

• methods for identifying potentially interested Indigenous communities
• who was consulted
• when and how consultation occurred
• any comments received from Indigenous communities

The EA should outline conflict resolution techniques used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

Analysis of the EA

A description of stakeholder consultation is included in Section 12.0 (Public and Agency Consultation) of the EA, which includes the methods used to identify and gain input from stakeholders, the frequency of consultation, and a description of key engagement milestones was provided.

Key consultation methods included:

• distribution of public notices
• public open houses
• mailings
• discussion groups
• project website

Section 12.13 (Indigenous Community Consultation) of the EA describes the consultation undertaken with Indigenous communities. Letters and emails were sent to each of the communities advising of notices, open houses, and draft reports which took place throughout the planning process.

The EA demonstrates how Indigenous community, public and government agency input received throughout the EA process informed the results of the EA.

The EAA requires that proponents consult with all interested persons during the preparation of the EA and report on the results of that consultation. The ministry is satisfied that the proponent appropriately carried out the consultation plan in accordance with the Code of Practice: Consultation in Ontario’s Environmental Assessment Process (2014) that was committed to in the approved ToR.

Overall, the ministry is satisfied that the public, agencies and Indigenous communities had opportunities to comment and provide input on the EA throughout the process.

Selection process

1. Proposed project

Description and statement of the rationale for the project:

Environmental Assessment Act Sections 17.4(2)(c), and 17.6(2) (b) (i) and (c).

The description of the project should specify what the proponent is seeking approval for under the EAA.

The description should include information on the location, attributes, dimensions, emissions etc.

The evaluation process should identify which is the preferred project.

Analysis of the EA

The evaluation process in Sections 5.0, 6.0, and 7.0 of the EA explain why alternatives were chosen and why the preferred undertaking was selected. A net effects assessment was undertaken for the alternatives and the preferred alternative was selected only after determining it would cause the least impacts on the surrounding environment.

Section 7.0 of the EA provides a description of the preferred undertaking. A summary of the proposed undertaking is provided in Section 2.5 of this review.

The EA documents how the preferred undertaking addresses the problem and opportunity statement, which is to provide additional capacity at the landfill site as the current site is reaching capacity.

Other approvals

1. Additional Approvals

Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

Analysis of the EA

If EA approval is granted, the proponent will still require other legislative approvals to construct and operate the project.

Section 14.0 (Other Approvals) of the EA outlines additional approvals that may be required, such as environmental compliance approvals, and surface water management plan and system design approval under Ontario Water Resources Act.

Appendix B: Submissions received during the initial comment period

Table 1: Agency comment summary table

Ministry of Citizenship and Multiculturalism (MCM)

Comment #1

Table 9.1, row D, under the “Indicators” column (p.113). “Potential presence of built heritage resources and cultural heritage landscapes at existing site.” We recommend revising Table 9.1 to be consistent with the terminology of the legislative framework, specifically the term “built heritage resources.”

Proponent’s response

Table 9.1 has been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to be consistent with the terminology of the legislative framework.

Status

The ministry is satisfied this comment has been addressed.

Ministry of the Environment Conservation and Parks (ministry) — Environmental Assessment Branch

Comment #1

Following a review of the 2020 groundwater monitoring data for Location 1 it was noted that road salt from Highway 17 may be impacting groundwater quality in several monitoring wells along the south property line, and additional impacts were noted in the background monitoring well (MW1-02). The current groundwater monitoring program includes sodium and chloride as analytical parameters but does not include bromide. Chloride/bromide ratios can be used to differentiate between landfill leachate and road salt sources, as discussed in the following publication: Panno, S.V., Hackley, K.C., Hwang, H.H., Greenberg, S.E., Krapac, I.G. Landsberger, S., and O’Kelly, D.J. (2006). Characterization and identification of Na-Cl sources in ground water. Ground Water, Vol. 44 (2), p. 176-187.

It is recommended that bromide is included in the analytical parameter list for the groundwater monitoring program.

It is recommended that the EA includes the following condition:

The groundwater quality monitoring program shall include the following parameters in addition to those listed under Column 1 of Schedule 5 of the Ontario Landfill Standards guideline: total cyanide, bromide, fluoride, organic nitrogen and hardness.

Proponent’s response

Bromide has been added to the list of parameters in Section 11.7.1 of the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry is considering a Condition of Approval that would require additional requirements for the Town’s groundwater monitoring program, including the need to reassess the size of the contaminant attenuation zone.

Comment #2

Five additional groundwater monitoring wells are proposed. Two wells are located at the southern extent of the proposed contaminant attenuation zone (CAZ). One well is located at the northwestern extent of the CAZ, and 2 wells are located southwest of the proposed expanded fill area. I agree with the proposed monitoring well locations. It is recommended that these monitoring wells are installed, and at least one year of seasonal groundwater elevation and quality monitoring data should be collected prior to application to the ministry for an Environmental Compliance Approval (ECA) amendment for landfill expansion. Following receipt of these results, the ministry may recommend additional groundwater monitoring well installations and further expansion of the CAZ.

It is recommended that the EA includes the following condition:

Prior to application for the ECA amendment for the Undertaking (landfill expansion), the proponent shall: install the 5 proposed groundwater monitoring wells (as shown in the Environmental Assessment, Figure 10.2 Rev 2, CAZ – Proposed Expanded Area), complete one (1) year of spring and fall groundwater elevation and quality monitoring/sampling at all monitoring wells, and reassess the sizing of the contaminant attenuation zone (CAZ). Groundwater quality monitoring shall include the parameters listed under Column 1 of Schedule 5 of the Ontario Landfill Standards guideline, with the addition of the following parameters: total cyanide, bromide, fluoride, organic nitrogen and hardness.

Proponent’s response

The noted parameters have been added:

We respectfully request that the ministry accept an ECA application for landfill expansion concurrent with the installation and monitoring of the 5 proposed groundwater monitoring wells (starting in spring of 2025) considering on the following:

• The current landfill site has exceeded its approved disposal capacity. Following pre-application consultation with the ministry, an ECA application has been submitted for an emergency interim volume expansion (equivalent to 2 years of disposal volume) to bridge the period of time until environmental approvals are obtained and the landfill expansion is constructed. This ECA application is currently being reviewed by the ministry.

• As the majority of downgradient lands are owned by the Town or Crown, modifying the currently proposed CAZ and amending a final ECA, if required, will not be impeded.

• Increasing the CAZ is an identified potential contingency measure in order to ensure that adequate attenuation is available downgradient of the site. The current monitoring program allows for early detection of adverse quality variations resulting from site operation with the Town implementing appropriate mitigation measures (e.g. repair/properly maintain surface water management works, grading and application of cover) prior to unacceptable conditions occurring at the downgradient CAZ boundary.

Status

The ministry is considering a Condition of Approval that would require additional requirements for the Town’s groundwater monitoring program, including the need to reassess the size of the contaminant attenuation zone.

Comment #3

Page 75, 8.1.3 Criteria Ranking: Net Environmental Effects, Table 8.2, Criteria #3

Location 1, states that there are no SW features within 200 m, however imagery shows the pond (SW1 sample location) is closer than 200 m to the fill area. The 2 seeps monitored at SW2 and SW3 (if these are considered natural wetland areas), would also be considered SW features. There may also be a wetland southwest of the Site.

Verify and update the distances in this table.

Proponent’s response

Table 8.2 has been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to include distances to the noted SW1 sample location, 2 seeps and potential wetland.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #4

Page 160, 11.7.2 Surface Water Monitoring

To have enough information to determine compliance with Landfilling Site O. Reg. 232/98, s. 13 (2). surface water samples should also be analyzed for turbidity. This is for EA and for permitting.

Recommend that turbidity be added to the surface water quality parameters list.

Proponent response

Section 11.7.2 has been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to include turbidity.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #5

Page 160, 11.7.2 Surface Water Monitoring

Similar to comments in GW review, if chloride concentrations are elevated in surface water samples chloride and bromide may be able to help differential between impacts form landfill leachate and those from the application of road salts. Link to paper provided in the groundwater review comments.

Recommend that the following parameters be added in addition to those listed: bromide and sodium.

Proponent response

Section 11.7.2 has been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to include bromide and sodium.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #6

Page 160, 11.7.2 Surface Water Monitoring

For clarity, in the sentence “Samples collected will be analysed for parameters identified in Schedule 5, Column 3 of the ministry Landfill Standards.” the name of the column heading should be added. This is for EA and for permitting.

Recommend adding the column name.

Proponent response

The column name has been added to Schedule 5, Column 3 in the revised “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #7

Page 161, 11.7.2 Surface Water Monitoring

Additional surface water sites may be required if groundwater direction changes or if leachate plume is found to extend beyond current sampling locations. This is for EA and for permitting.

Additional surface water sampling locations may be required. For example, if it is determined that groundwater flow direction has changed or if leachate plume is found to extend beyond current sampling locations.

Proponent response

Section 11.7.2 has been revised as per the ministry’s proposed text in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #8

Page 163, 11.8.1 Surface Water

Trigger concentrations are equivalent to the provincial water quality objectives and Canadian water quality guidelines values, whichever is more recently published. The ‘Federal Environmental Quality Guideline (FEQG)’ should also be listed. This is for EA and for permitting.

The ‘Federal Environmental Quality Guideline (FEQG)’ are also recommended to be used.

Proponent response

Sections 11.7.2 and 11.8.1 have been revised to include the FEQG in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #9

Page 163, 11.8.2 Tier 1 — Annual Routine (Alert) Monitoring Program

The EA proposes investigation of cause is proposed after 3 consecutive exceedances. However, O. Reg. 232/98, s.27(1) specifies that investigation of cause should be carried out if trigger is exceeded for any single monitoring event. This is for EA and for permitting.

Updated to after a single exceedance for groundwater or surface water sampled in accordance with O. Reg. 232/98 s.27(1).

Page 163, 11.8.2 Tier 1 — Annual Routine (Alert) Monitoring Program

For clarity, the actual column named should be included. Schedule 5, Column 3 of the ministry’s Landfill Standards. This is for EA and for permitting.

Recommend adding the column name.

Proponent response

Section 11.8.2 has been revised so that Tier 2 level monitoring will be initiated following a single exceedance in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

The column name has been added to Schedule 5, Column 3 in the revised “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #10

Page 165, 11.8.3 Mitigating Measures Table 11.4

There are situations where it may be reasonable for an exceedance of trigger concentration in surface water to require the use of a leachate collection system. This is for EA and permitting.

Though exclusion of this mitigating measure from the table does not preclude it from being a possible mitigation measure it would be consistent to include “Leachate/groundwater collection system, if required” as item in row 2.

Proponent response

Table 11.4 has been revised to include “Leachate/groundwater collection system, if feasible” in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #11

Consultation report in the EA and Consultation Report

In section 12.16 it states that a link to the Draft EA was provided to the Indigenous communities in February 2024 however this is not reflected in the consultation table or in the supporting information. The supporting information to communities does not include the reach out correspondence of both 2019 and 2024.

Regardless of the outcome of the consultation, i.e. no comments, it should be clearly indicated all touch points to Indigenous communities and the supporting emails, correspondence, etc. for these touchpoints.

Proponent response

Section 12.13 and Table 12.11 have been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to include the 2024 consultation.

Section 8.1 and Table 11 have been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Consultation Report, October 2024” to include the 2024 consultation.

The 2024 correspondence with Indigenous Communities has been added to Appendix H.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Ministry of the Environment Conservation and Parks (ministry) — Species at Risk Branch (SARB)

Comment #1

Mountain Lion is referred to as Cougar on the Ontario Species at Risk (SAR) List. The status of this species was re-assessed and it is now listed as Special Concern, not endangered. It is also very unlikely that Cougars occur or will occur in the study area. There is limited information on Cougars in Ontario but in the few cases where wild individuals have been confirmed, it has been in Northwestern Ontario. DNA analysis has suggested that these individuals originate in South Dakota and are most likely transient. Similarly, neighbouring jurisdictions such as Minnesota do not have a resident Cougar population but transient individuals from the Dakotas have been observed on rare occasions (page 18 of the final EA).

• SARB suggests removing consideration of Cougar as possibly occurring in the study area or at least correcting its status (Special Concern in Ontario).

• Special Concern species do not receive protections under Section 9 (protection against kill, harm, harass etc.) or Section 10 (damage or destruction of habitat) of the Endangered Species Act, 2007 but Endangered and Threatened species do.

Proponent’s response

Section 4.1.7 has been revised in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024” to remove the mountain lion.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #2

Suggest including an explanation of the implications of SARO status for these species (page 18 of the final EA).

e.g., Species listed as Endangered and Threatened under the Endangered Species Act, 2007 receive protections under Section 9 and 10 of the Act that Special Concern species do not. Section 9 prohibits killing, harming, harassing individuals, among other things. Section 10 prohibits the damage or destruction of habitat. An authorization is required under the Act to contravene the prohibitions set out in Section 9 and 10.

Proponent response

The proposed text from the ministry has been added to Section 4.1.7 in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.

Comment #3

Agree with proposed best practice to halt work if a SAR does show up on-site (page 19 of the Appendix G: Environmental Impact Study).

Suggest resources to identify SAR are available to workers on-site and that they are aware of potential for SAR to occur on-site.

Proponent response

The proposed suggestion from the ministry has been added to Sections 9.1.2, Criteria Group A: Natural Environment, Criteria 1 and 2 in the “Town of Blind River Municipal Waste Management Plan Environmental Assessment Report, October 2024”.

Status

The ministry has indicated that it is satisfied with the proponent’s response and has no further comment.

The ministry is satisfied this comment has been addressed.