Waterkeeper Comments Re: FarmTech Report, dated August 5, 2008
Concerned about FarmTech's proposal to build an ethanol plant on the Oshawa waterfront, Lake Ontario Waterkeeper wrote to the Government of Canada to express our concerns. Because the government is providing land, funding, and permits for the project, it required an official environmental assessment.
Our full submission is here. Here's a summary:
Lake Ontario Waterkeeper ("Waterkeeper") is concerned that the proposed FarmTech facility cannot satisfy the purposes of the Canadian Environmental Assessment Act ("CEAA"). There is evidence to suggest that the facility is not an example of sustainable development, that it will not conserve or enhance environmental quality around the Oshawa Harbour, that this kind of economic development is not appropriate for the Oshawa Harbour, that approving such a a facility demonstrates leadership on the part of government, and that the proponent has demonstrated a genuine respect for public consultation.
We offer the following commentary to assist Public Works and Government Services Canada in the preparation of the Screening Report. In particular, we recommend the following recommendations:
1. Consider the changes to local air quality and to the local waterways where air-borne contaminants may settle in the screening report.
2. Study potential impacts of noise thoroughly, and employ the precautionary principle in the decision-making process.
3. Assess the environmental impacts of the water taking for ethanol production
4. Prepare a thorough hydrogeological analysis of the impacts of the groundwater takings
5. Include descriptions of accidents or malfunction scenarios and their potential impacts on the local and regional environment in the screening report.
6. Ensure the environmental assessment consultation process reflects and respects the significant public concern.
7. Consider alternate locations in the environmental assessment process.
8. Consider the Province of Ontario's decision to abandon its 10% ethanol target.
9. Do not issue any approvals that would permit a different industrial operation on the lands, in the event that FarmTech's business fails.
10. Develop new VECs in consultation with the community. 11. Compile and consider the numerous reports on water quality.
Read our original submission to Environment Services Ontario here.