It's not a rhetorical question: Waterfront Toronto is applying to the Ontario government for permission to create a waste site on Unwin Avenue, across the street from Lake Ontario Park, the outer harbour sailing and paddling clubs, Cherry Beach, and the Waterfront Trail.
The waste site would stockpile contaminated soil pulled from the ground as part of the waterfront redevelopment and revitalization process. Cleanup, clearly, is a good thing. It is less clear, though, that creating a waste site on the waterfront is the best way to go about cleaning up the ... er ... waterfront.
The soil would be contaminated with chemicals and metals that vastly exceed every benchmark for soil use in the country. Benzene, for example, exceeds industrial site standards by nearly 800 times. These contaminated soils would be hauled in and piled up as often as necessary - including on Saturdays - for the next twenty years.
The idea is that a treatment facility will also be built at the waste site, and that the soils will be cleaned up and reused. The trouble is, no treatment facility plan has been submitted to the government. It's not certain that a company will be able to do what Waterfront Toronto needs it to do at a price the public agency can afford. If no processor can be found, we are left with piles of heavily contaminated soil piled up at the edge of Lake Ontario.
Normally, when a waste site is proposed in Ontario, one (or more) of a few things happens. Sometimes there is an Environmental Assessment. Sometimes there is a technical hearing. Sometimes there is a citizen liaison committee process. In this case, none of that is happening.
The Ministry of the Environment is considering a licence for air emissions from the waste site separately from a licence for water emissions, and both of those separately from the licences for the treatment facility. The Ministry of the Environment refused Lake Ontario Waterkeeper's repeated requests for an extension to the public consultation process regarding the waste site application. So far, we are being told that there will be no hearings.
In the short amount of time we had, we reviewed the project documents. It took more than 7,000 words just to summarize our general concerns about the project. We have asked for the appropriate hearing process to kick in, so that we have an opportunity to review and improve the technical aspects of the project.
The goals of the project are laudable - to clean up Toronto's waterfront. But the potential flaws with the project could also be devastating. Just imagine: hundreds of thousands of tonnes of soil laced with benzene, toluene, arsenic, chromium, lead, mercury and more contaminants, all stockpiled on waterfront land that is surrounded on three sides by water and within metres of the city's popular recreational areas.
We have submitted the first of a series of comments on the application to the Ontario Ministry of the Environment. Hopefully, the Ministry responds with an appropriate level of regulatory oversight and respect for Lake Ontario so that we can truly move forward with cleaning up Toronto's waterfront.
Lake Ontario Waterkeeper's first submission on the waste site is available here.
Find additional information here.