To the Hon. Jeff Yurek, Minister of Environment, Conservation and Parks

Dear Minister Yurek;

We are writing to you to express our concern with regards to the building of a cement plant in L’Orignal, Ontario. More specifically on Lot 217, Plan M100 on the north side of County Road 17.

While the Ministry of Environment, Conservation & Parks (MECP) has already issued an Environmental Compliance Approval (ECA), it was based on erroneous data provided by the proponent of the project.

Colacem consistently underestimated its kiln pollutants emissions. In their calculation, Colacem used U.S short tons instead of metric tonnes. This was acknowledged during the Local Planning Appeal Tribunal (LPAT) hearings held in November and December 2020. Mr. Robinson, Member of the LPAT acknowledged a “ failure to convert imperial units to metric units.” We would be more forgiving towards this mistake if it had been made during the mid-70’s when the metric conversion system was being implemented. More than forty years later, it’s hard to believe a mistake like this could be made when an entire team of professionals was at the disposal of the proponent of the project. We
hope this was not done intentionally to show a lower concentration of kiln pollutants emitting from Colacem.

Furthermore, the Cumulative Effects Study (CES) lacked complete data to truly reflect the overall air emissions of the project. Colacem owns the quarry beside the lot where the proposed cement plant will be built. It is our understanding that the quarry has a license to extract up to 3,000,000 t/ year of aggregate. Mr. Capstick, Colacem’s air quality expert hired to perform the CES, acknowledged at the LPAT hearing that he did not factor in the increased amount of output from the quarry to accurately calculate the air emissions. In fact, he used the National Pollutant Release Inventory (NPRI) of 2016. This approach clearly fails to take into account the increased amount of production from the quarry to supply the cement plant. The pollutants emitted from the quarry are estimated to be at least three times greater than the 2016 values.

In addition, when Colacem submitted its CES report to the MECP, they wrote that the quarry emissions were modelled conservatively, assuming it would be operating 24 hours a day, 365 days per year. Mr. Capstick acknowledged under oath at the LPAT hearing that in reality, they only used a 10 hours a day, 365 days per year basis. Even when modelled with extremely underestimated quarry emissions, one of the CES scenarios predicts that the Ontario’s Ambient Air Quality Criteria will be exceeded at least every two weeks outside Colacem’s property limit. This breach would likely be much more frequent if they use realistic quarry emissions values in the models.

Minister, Premier Legault acknowledged publicly in March 2021 that it was a catastrophe to have built a cement plant in Port-Daniel-Gascons. The promises made by the company have yet to materialize. This has had a major negative impact on the community of Port-Daniel-Gascons. We want to avoid this situation in our community before it’s too late.

We are asking you to revoke the ECA, as too many significant errors were committed by the proponents of the project. An ECA should be issued based on facts and supporting evidence. While the LPAT may not be the appropriate body to deal with issues surrounding the approval process for the ECA, it did highlight the miscalculations used by Colacem to obtain its ECA. We, as elected representatives, have a responsibility to ensure the decision-making process is based on factual statements.

Statements made in this letter are supported by evidence provided during the LPAT hearing and expert testimony. Minister, we would be happy to share further information at your request.

Sincerely,

Amanda Simard, MPP, Glengarry-Prescott-Russell

Francis Drouin, MP, Glengarry-Prescott-Russell