I attended one of the open houses conducted by the proponent, and I have reviewed the environmental assessment document submitted on December 31, 2022 by GFL (Green for Life) Environmental for their proposed Brant Street Electric Arc Furnace Dust Recycling and Zinc Manufacturing Facility to be located on Brant Street in Hamilton, Ontario.
I have a number of concerns which I believe need to be answered by the proponent prior to any MECP approval of this project.
1. Failure to adequately consult with and consider the interests of Indigenous Nations: The proponent claims to have sent notice and information to Indigenous nations, but there is no evidence that any response was received or any actual contact with Indigenous nations occurred, and no indication that the proponent followed up with effective communication.
Also there is no indication of offering assistance to the Indigenous First Nations to help them review and respond. The Truth and Reconciliation Commission calls to action include a business section (#92) that reads in part: “Commit to meaningful consultation, building respectful relationships, and obtaining the free, prior, and informed consent of Indigenous peoples before proceeding with economic development projects.”
It appears that no free, prior or informed consent has been obtained; and that the proponent failed to engage in a serious and respectful attempt to obtain such consent.
2. Failure to adequately notify local residents: In the consultation, the proponent admitted not circulating notices to the neighbourhood about the project, but instead relying of ads in various newspapers. Only one of those newspapers (the Hamilton Spectator) even circulates in the neighbourhood of the proposed facility and it requires a paid subscription so it is unlikely it actually goes to any local residents especially since they most appear to be low income.
The EA acknowledges nearby residential uses including “a two-storey building at 290 Sherman Avenue North, located immediately east of the Site that has potential residential uses. Other residential dwellings are located approximately 100 m southeast of the Site along the south side of Imperial Street, approximately 490 m south of the Site and approximately 400 m northwest of the Site.” A reasonable attempt to notify these residents would be the simple circulation of a letter to each household before the open houses and public consultation began. This failure needs to be remedied by restarting the consultation.
There is also no text discussion of a proposed HSR “bus barn” on Birch Ave within 300 metres of the facility that should also be deemed a sensitive use. It is mentioned in a table on page 6-12. What will be the impacts on drivers and other users of this facility? Why wasn’t the driver’s union notified and asked to comment?
3. Failure to address the climate emergency: The proponent has prominently claimed that a major justification for the project is to cut greenhouse gas emissions. This objective was highlighted by Sustainable Development Technology Canada (STDC) when it announced $3.8 million in funding to the proponent’s partner Cobric Chemicals, in early 2021. The media release for that federal investment quoted the Honourable François-Philippe Champagne, Minister of Innovation, Science and Industry as saying: “Now is the time for ambitious climate action. Cleantech innovation, entrepreneurship and commercialization are key to the vital shift to a healthier environment and a net-zero carbon economy. Today’s announcement will boost our leadership in climate and waste reduction technologies and help foster a truly Canadian success story.” Curiously and of concern is that this major public funding was not mentioned in the workshop I attended, or in the environmental assessment document.
And it appears that the project as proposed is not climate responsible. The environmental assessment table 6-2 indicates that the project will be powered by natural gas (more appropriately referred to as fossil gas) and is expected to result in new greenhouse gas emissions of 11,266 tonnes per year. These are new emissions, and along with other pollutant emissions, are being added to the Hamilton air-shed which is recognized as already compromised.
This same table states that the project will result in a reduction of an estimated 22,500 tonnes per year at an unidentified United States recycling facility. This claim is problematic in several respects. The facility is not identified; there is no indication of how this estimate was arrived at; no calculations are provided; and there no way an independent reviewer can confirm this claim. Instead the report simply states: “The proposed project uses less energy to process the same quantity of material. It is presently estimated based on the energy inputs that the existing US alternative technology would produce twice as much of CO2 equivalent.” Why is this the case? Does this reflect the size of the referenced US facility – presumably larger and therefore likely more efficient than the pilot project being proposed in Hamilton? Is there any evidence that the US facility will actually reduce its GHG emissions if it doesn’t receive the waste being diverted to the proponent’s proposed facility? If the US facility is using less efficient technology, why could it not adopt the Hamilton technology and thus cut its emissions? The fuel at the US facility is not revealed. If it is fossil gas, the transportation costs (and emissions) of that fuel would be expected to be less than the fracked gas imported a considerable distance from the US that makes up the majority of Ontario supplies.
And further, it is not revealed if the proponent’s calculations of emissions consider the reportedly much higher actual climate impacts of fracked gas versus the usual claims for “natural” gas. I understand that the vast majority of gas used in Ontario comes from fracking operations in Pennsylvania, a state that does not monitor or report on fugitive emissions from those operations. Independent research suggests that the climate impact of fracked gas is similar to burning coal. The proponent’s climate claims need to be accurate and transparent.
The same table 6-2 shows the expected greenhouse gas reductions claimed by the proponent as a result of reduced transportation are 709 tonnes/year, less than 7 percent of the new GHG emissions expected to occur in Hamilton.
4. Failure to act in a climate responsible way: The decision to rely on fossil gas as the main energy source flies in the face of the overwhelming evidence of a climate emergency largely caused by fossil fuels. Everyone from the Secretary-General of the United Nations, to the International Energy Agency agrees that we have to get off fossil fuels as quickly as possible, and that doing the opposite in a new industrial investment is irresponsible. Note the SDTC commitment to “net zero”. How will this be advanced by opening a new facility that relies on fossil gas? This will inevitably require retrofitting to electrical energy and the company will no doubt seek public dollars for such a retrofitting. Instead it should be done right in the first place.
5. The economic impact was not examined: The economic costs to Ontario of relying on an imported energy source (fracked gas) are considerably greater than the utilization of Ontario-produced energy provided through the grid. This is not assessed or even considered.
