October 24, 2006
Mr. Gord Miller
Environmental Commissioner of Ontario
1075 Bay Street, Suite 605
Toronto, ON M5S 2B1
Canada
Dear Commissioner Miller:
We are a Coalition of Citizen Groups opposed to the proposed expansion of the Carp Rd. Landfill. Our members, all of whom are volunteers, constitute residents affected by this landfill and/or concerned about the environment in this province.
In January 2006, Waste Management (WM), the operator of the Carp Rd. Landfill in the City of Ottawa, shocked the community by announcing plans to seek approval from the Ministry of the Environment (MoE) to create a mega dump that would see an additional 18.75 million cubic metres of new garbage dumped on top of, or beside, some 8 million cubic metres of existing garbage. In May 2006, the Coalition submitted an extensive and detailed response to the Draft Terms of Reference submitted by Waste Management that included 165 recommendations to the Ministry of the Environment, recommending that the Terms of Reference submitted by WM be rejected. Indeed, the City of Ottawa also submitted extensive comment on WM’s Draft Terms of Reference describing it as generally “deficient” and requiring extensive revision. A copy of the Community Response to the Terms of Reference is available at http://www.nodump.ca
The impact of the landfill on air and water quality is of profound concern to local residents. The communities of Stittsville, Kanata and West Carleton are growing rapidly as a result of the inevitable urbanization of the west end of Ottawa. There are already some 100,000 people living within 10 kilometeres of the landfill with more subdivisions planned and underway, all within the shadow of the Landfill.
Of great concern is that many of the residents living in the area rely on the local aquifer as the source of their drinking water. Built on sand and fractured bedrock, the worst imaginable foundation for a dump, there is growing evidence that the Carp Rd. Landfill has polluted the groundwater of the surrounding area. The Carp Rd. Landfill stands out as a sad relic of a past, when public concern for the environment was minimal at best.
Earlier this year, the Coalition obtained, under the Freedom of Information and Protection of Privacy Act (FIPPA), a copy of WM’s February 2005 annual groundwater monitoring report, prepared by Water and Earth Sciences Associates Ltd. (WESA) and supplied to the Ministry of the Environment (MoE). Over the summer, we reviewed WM’s data and prepared our own analysis, conclusions and recommendations. We provided these to the Minister of the Environment on September 28, 2006. We are pleased to provide you with a copy of our letter and the report we prepared for the Minister.
The concerns we raise regarding the state of the Carp Rd. Landfill parallel the issues that you raise in your Annual Report, released on October 3, 2006. In that report, you highlight the growing problems with Ontario’s aging landfills, such as the one on Carp Rd., and point out that the last inventory of landfills in Ontario was completed in 1991. You also raise questions regarding the “significant shortcomings” identified in the MoE’s approach to the management of landfills and raises questions regarding the adequacy of frameworks for monitoring and regulating Ontario’s landfills and the ability to provide the public with information on these sites. This is completely consistent with our experience in trying to obtain information on the present condition of the Landfill as well as our understanding of the ability for the MoE to adequately monitor and enforce regulatory requirements.
On October 13, 2006 we received a response to our report from the MoE. They will be reviewing our information and a response from the Ministry is forthcoming. In their letter, the Ministry acknowledged that the Carp Rd. Landfill is presently not in compliance with provincial groundwater policies and that leachate from the landfill had migrated off-site to an adjacent property that at the time was not owned by the landfill operator. A Provincial Officer Order was issued in 2002, however it is our feeling that the groundwater monitoring plan agreed to under that Order is unsatisfactory for a number of reason including:
- some of the test wells used to establish background levels appear to be contaminated and therefore are not representative of what would constitute “clean” groundwater in the area
- the plan does not account for the migration of Volatile Organic Compounds into the vadose zone and subsequent contamination of the underlying groundwater
- there are not enough test points to adequately characterize the extent of the leachate plume
- there are insufficient test points to the north and west of the landfill (an area that includes dozen’s of homeowners, all on wells) to adequately monitor for contamination. This is crucial given the changes to the groundwater that now partially flows in that direction.
Per your Annual Report, we are very concerned that the extent and direction of the existing off-site contamination (the leachate plume) is not fully understood nor has it been adequately addressed. Part of the Provincial Officer Order included allowing WM to purchase additional lands to expand the contamination abatement zone to conform to regulations. In our humble opinion, this is not an acceptable solution to the problem and does nothing to eliminate the possibility of further contamination.
We listened with interest to the Minister’s recent announcements regarding the Ontario Clean Water Act (Bill 43). If indeed Ontarians are to have some of the best protected drinking water in the world, then old landfills, such as the Carp Rd. Landfill that are built on porous, fractured limestone, and that have ongoing problems with leachate containment and contamination of local groundwater, should be closed.
Meanwhile, we trust that you will find our information of interest and supportive of the findings and recommendations included in your Annual Report. Should you or your staff wish to meet with us regarding our analysis of the WM’s groundwater monitoring reports, or our ongoing opposition to the proposed expansion of the Carp Rd. Landfill, we would be happy to do so at your convenience. In the meantime, do not hesitate to contact us should you have any questions or concerns with the information that we have provided.
Sincerely,
Vincent Lavoie, President Richardson Corridor Community Association
On behalf of the Coalition of Citizens’ Groups opposing the expansion of the Carp Rd. Landfill.
113 Wilbert Cox Drive
Carp, Ontario
K0A 1L0
(613) 831-8933
c.c.: The Honourable Laurel C. Broten – Minister of the Environment
Gordon O’Connor – MP (Carleton – Mississippi Mills)
Norm Sterling – MPP (Lanark – Carleton)
Lisa McLeod – MPP (Nepean – Carleton)
Bob Chiarelli – Mayor, City of Ottawa
Peggy Feltmate – Councillor, Ward 4
Eli El-Chantiry – Councillor, Ward 5
Janet Stavinga – Councillor, Ward 6
No Dump
Ottawa Landfill Watch
Stittsville Village Association
Michael Walters – Waste Management