Tell Environment Minister Bradley for a 'Bump Up' on the Duffin Creek Outfall EA

On November 19, Durham & York Regions declared their class EA on the Duffin Creek Sewage Plant Outfall 'competed' in spit of the fact that it has never evn been approved by Durham Regional Council, and, in fact, the Phase II report was specifically rejected back last March. By some quirk of Regional procedure, the EA proceeded regardless and is now 'complete'. 

A 'Bump Up' is an order from the Minister to do the equivalent of an individual EA which is a more rigourous process and provides for a greater public role. In contract a class EA (Schedule C) is self-assessment process. The end result of a class EA is an 'Environmental Study Report' (ESR). In technical terms a 'bump up' is 'Part II order under the Environmental Assessment Act'

We have until 4pm Feb. 18 to make the request. If we, as citizens, make the Part II order request in sufficient numbers and with solid arguments, then the Minister is likely to grant our request.

Requests can be made by email or by snail mail. The following notes assume you will use email but you could easily turn it into a letter.

There is a specific format to your email:

Hon. Jim Bradley
Minister of the Environment
12th floor
135 St. Clair Avenue West
Toronto, Ontario  M4V 1P5

minister.moe@ontario.ca

Re: Request for a Part II Order under the Environmentasl Assessment Act Schedule C Class Environmental Assessment to address Outfall Capacity Limitations at the Duffin Creek Water Pollution Control Plant

I am writing to ask you to order York and Durham Regions to comply with Part II of the Environmental Assessment Act and carry out an individual environmental assessment to address the capacity limitations of the outfall at the Duffins Creek Water Pollution Control Plant.

The Duffin Creek WPCP discharges sewage effluent into the water of lake Ontario near Ajax, through a 1 km long outfall pipe. The plant presently discharges approximatelt 360 million litres per day but has a capacity to discharge up to 630 MLD of effluent.

State that you have read or reviewed the ESR or have attended meetings or have talked to concerned residents or something else to indicate a level of involvement in the issue. State timeframes if reasonably long. If you live in the vicinity of the shoreline in Ajax and have experienced the smell of the rotting algae, then say so and tell how bad it was.

After that, you need to state as many reasons as you like as to why you are not satisfied with the Regions' Class EA process and what additional work should have been done. There are sevel suggestions below. Pick as many as you like but don't take them all. Personalize them if you like and add any other concerns you might have.

You want to finish the letter with something like this:

Minister: For the reasons set out above, I feel that the ESR is deficient and that the Class EA process is entirely inappropriate for a project with such significant adverse environmental effects. I ask you to require the regions to conduct a full individual EA.

Sincerely,

Your name and full address

cc. Regons of York - Mr Wayne Green, info@York.ca
      Region of Durham - Mr. Barry Laverick, info@Durham.ca

Then email it. Make sure you cc the two regions.

Content suggestions:

Dilution of pollutants is the false solution proposed in the Regions' ESR. Lake Ontario may be a large lake but we though Lake Simcoe was too until it died. We thought Lake Erie was a large lake too and its died twice.
Sewage plants need to remove the nutrients before they are discharged into lakes.

Because Lake Simcoe 'died' in the late 70s due to excessive phosphorus, Ontario passed the Lake Simcoe Protection Act in 2008. As a result sewage plants discharging into that Lake are required to remove much greater amounts of phosphorus than is currently required of plants discharging into Lake Ontario. This includes plants in both York and Durham.

York is currently planning an advanced treatment plant that will discharge essentially clean water into the East Holland River. Given that 80% of the sewage at Duffin Creek is coming from York, I believe that what's good enough for 'their' lake (Simcoe) should be good enough for Durham's lake (Ontario).
Algae is a problem of varying degrees in most temperate fresh water lakes and there is an urgent need for leadership. Ontario could be providing some of that leadership by focusing research on the Cladophora problems on the Ajax waterfront. Your Ministry's Great Lakes Protection Act allows for development of strategies to improve water quality.
The regions have simply chosen the cheapest solution at $1.5 million. Duckbill diffusers are the equivalent of putting your finger over the end of a hose to make the spray go farther. Even at that, they will (according to their modelling) only increase the dilution ratio from 1:19 to 1:22.
The Outfall EA has never been 'approved' by Durham Regional Council. Indeed the Phase II report was specifically rejected by Council on Mar. 6, 2013. See DurhamCLEAR.ca/EAnotApproved
I expect my governments to reduce pollution instead of adding to it. The Regions are happy to 'meet standards'. If that is all they are willing to do then tighter standards need to be imposed.
When the regions assessed the 'alternatives', they downgraded tertiary treatment by grouping 5 very different technologies together and chose the most expensive as 'representative'. They then said tertiary treatment was too expensive. This logic skewed the choice in favour of the duckbill diffusers. When asked to provide cost analysis on all of these options, they have ignored the request.
The regions have failed to examine the impact of excessive algae growth on fish, fish spawning and fish habitat in the Ajax nearshore.
The Regions have failed to seriously consider technologies that can cost-effectively remove soluble reactive phosphorus from the plant's effluent. One such techology is Actiflow currently in use at Syracuse New York which removes 99% of the SRP.
The Regions have not acknowledged any role of the plant in the growth of algae and hence has made no effort to consider solutions.
The province has limited the discharge of phosphorus from the plant to 311 Kg per day. However, the plant is currently discharging far less than that and the algae problem is already severe. 311 Kgs is 2 to 3 times the current discharge which will make the algae problem even worse.
The plant is currently discharging about 26 tonnes of SRP per year. The regions must not be allowed to conclude that this simply disappears when it hits Lake Ontario. Instead it is fuelling blooms of Cladophora
The modelling done by the consultants on this EA as presented at the Public Information Forums seemed implausible. They imply that the phosphorus discharged from the plant never comes near the shore, which, given the range of currents seems unlikely. This needs to be more carefully studied.
The regions blame the algae on mussels, climate change, storm water and local tributaries. They cite, for example that the phosphorus loading in Lake Ontario is approximately 20% from local tributaries. However, Dr. Martin Auer in a 2011 peer review (page 21) concluded that 97% of the loading of Soluble Reactive Phosphorus in the near shore area around Ajax is coming from the Duffin Creek Sewage plant. The Regions chose to ignore this information even though they helped fund Auer's work