Letters to the Minister of Environment on Inadequate Monitoring and Baseline Studies

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There will be inadequate monitoring of emissions:  many of the most toxic pollutants will only be monitored one day a year through a pre-arranged stack test (Table 4-1, HHERA, Dec. 10, 2009); furthermore, the operator Covanta would do the monitoring;

There is NO monitoring of soil, water, agricultural produce and NO human biomonitoring which appears inconsistent with EA commitments (section 3.3, Host Community Agreement)

Consultants excluded Human Health Impacts when evaluating Alternatives - though exclusion of health impacts was raised as a concern by the public, consultants did not amend evaluation criteria nor add health impacts. 

The Environmental Assessment carried out for this facility is inadequate as there is not sufficient knowledge of the toxicity levels for several of the organic chemicals, toxic metals and fine particulate matter that will be released into the air of our community.  Nor can it possibly take into account chemicals that are being developed today and in the near future, that will be burned in this facility.

Epidemiological studies in Europe and Japan (several examples are available through the  British Society of Ecological Medicine http://www.ecomed.org.uk/content/IncineratorReport.pdf) have determined that these facilities increase the prevalence of cancer, heart disease and asthma in the populations located near garbage incinerator smoke stacks.  This of course will put the population of Durham and downwind at risk. 

Unlike “risk assessment”, which uses conjecture and many assumptions and can be carried out in a matter of months, epidemiological studies use actual numbers of illness and death which have occurred over much longer periods of time.  It was this type of research that exposed the danger of tobacco smoke, and led to successful legal actions against tobacco companies.  Do you really want to place your government and Ontario tax dollars in a similar position?

I write today to express my grave concerns regarding your recent comments about the burning of garbage. You touted the City of Amsterdam’s incinerator as an innovative process and stated that surely it is better to get some energy from garbage than have it landfilled. My comments below are limited to these two points.

Burning waste is not a new process. If we listen to the industry proponents, they will tell us that new incinerators are far better than those we used previously. I wonder, did you only listen to the City of Amsterdam’s Waste and Energy Company executives to make your conclusion about such facilities or did you actually also look at the literature available on the downside of incineration? The incinerator proposed by the Region of Durham will actually generate more pollution than the one that was built in Brampton approximately 20 years ago. Please see the attached reports and tables to judge for yourself the validity of this statement. How is such disregard for the environment and its inhabitants either an innovation or an improvement?

Incinerators are not innovative problem-solvers as you have portrayed them. They are an unsustainable solution to a garbage crisis that could be solved through creativity and increased producer responsibility. It is my hope that you and your Ministry have the political will to take the road to a healthier future for Ontario by saying no to incineration.

Two years ago, in May 2008, citizens expressed very serious concerns with the emissions criteria set by Durham and York Regions. Citizens repeatedly requested that the decision makers and the public be provided with emissions criteria, not just the EU standards, but criteria from individual countries within Europe and beyond that have own more stringent criteria so that the public could compare against what Durham was adopting, but that data was not provided.  Citizens also requested to be provided with emissions data which would define a "state-of-the-art" facility, but again that was not provided. In January 2008, council had promised Durham residents "the best of best".

There are lots of claims that this will be a "state-of-the-art" facility, but where is the proof? Instead, we have information that points to the contrary. In a November 2008 memo sent to Durham's Medical Officer of Health, Dr. Robert Kyle, the Regions' consultants gave the annual emissions from the 20-year old Algonquin incinerator in Brampton. When the Durham facility emissions provided in the environmental assessment are compared against the older Brampton facility emissions provided in that memo, the Durham emissions are higher (greater) for many of the pollutants of concern.

Region staff has been unwilling to state that a new incinerator in Durham will operate any better or worse than the 20-year old facility in Peel.

In addition, emission data from the Peel incinerator indicates that it is operating at or near the limit of the A-7 guidelines.