46 Ackroyd Lane

Denbigh, Ontario

K0H 1L0

October 30, 2014

Open letter to:

Mr. Peter Taylor,

Manager, Technical Support Section

Section 34, Ministry of the Environment

1259 Gardiner's Road

P.O. Box 22032

Kingston, Ontario

K7P 3J6

Dear Mr. Taylor,

I am writing to you pursuant to motions M2014-13 and M2014-14 ( attached ) which were passed with the required 2/3 majority at the Denbigh Townhall meeting of September 17, 2014.

Ms Dagg-Foster has stated that the ministry makes its decisions based on “the science”. However, in her response of July 11, 2014 ( attached ) to the Denbigh Townhall's letter of May 14, 2014 ( attached ) Ms. Dagg-Foster did not provide any of the requested scientific data. Would you please provide the Denbigh Townhall with the data that the ministry used to amend the Environmental Compliance Approvals for the Addington Highlands Vennachar and Macavoy waste sites.

Furthermore, in her response Ms. Dagg-Foster states:

“Regulation 232/98 of the EPA requires that a surface water and groundwater monitoring program is carried out a landfill site.”

However, Regulation 232/98 states:

“2. (1) This Regulation applies to the following landfilling sites:

Every landfilling site that comes into existence on or after August 1, 1998 and that is intended at the time it comes into existence to have a total waste disposal volume of more than 40,000 cubic metres and to accept only municipal waste for disposal.

Every landfilling site for which an alteration, enlargement or extension is proposed on or after August 1, 1998 that involves an increase in the site’s total waste disposal volume, if the site is intended after the alteration, enlargement or extension to have a total waste disposal volume of more than 40,000 cubic metres and to accept only municipal waste for disposal. O. Reg. 232/98, s. 2 (1).

(2) Subsection (1) does not apply with respect to a landfilling site in respect of which an application for a certificate of approval has been received by the Director under Part V of the Act before August 1,

1998, unless the operator or owner of the landfilling site gives written notice to the Director that the operator or owner wants this Regulation to apply. O. Reg. 232/98, s. 2 (2).”

The bolded portions of the regulation clearly state that the regulation applies only after August 1,1998 and only to waste sites whose capacity is, or will become, greater than 40,000 cubic metres unless the operator gives written notice requesting that the regulation apply. All of Addington Highlands Certificates of Approval pre-date 1998 by many years.

Therefore, Ms. Dagg-Foster's statement appears to be factually incorrect. In the absence of written requestes from Addington Highlands, for the regulation to apply the waste sites would need to have total disposal volumes of greater than 40,000 cubic metres. The waste sites in question have total disposal volumes of less than 40,000 cubic metres.

If Addington Highlands made written request for Regulation 232/98 to apply, please provide the Denbigh Townhall with copies of the correspondence. Otherwise, please indicate either why Regulation 232/98 applies or what other regulation, if any, applies with regard to water sampling.

Yours truly,

Paul Isaacs as per

Denbigh Townhall motion M2014-14