December 31, 2010
The Honourable John Wilkinson
Minister of the Environment
11th Floor, Ferguson Block
77 Wellesley Street West
Toronto, ON., M7A 2T5
By e-mail to: minister.moe@ontario.ca
Re: Redevelopment of Lansdowne Park
Dear Minister Wilkinson,
As president of the Glebe Community Association (GCA), I am writing to express the concerns of the GCA board and of the many residents near Lansdowne Park about the next stages of the proposed development of Lansdowne Park.
One reason advanced for major redevelopment of Lansdowne Park was the opportunity it would present to address brownfields which earlier environmental site assessments identified. The City commissioned AMEC Earth and Environmental to conduct two site assessments: Phase I1 and Phase II2 Environmental Site Assessments for Lansdowne Park and Sylvia Holden Park, 945-1015 Bank Street, Ottawa, Ontario. These reports confirmed the existence of significant contamination. More recently, the Friends of Lansdowne Park, Inc. commissioned a Peer Review3 of both reports by XCG Consultants Ltd. XCG’s review found at least nine areas of actual or potential environmental concern on the Lansdowne property that warrant further investigation.
The GCA wishes to advise the Minister of the Environment that due process may not be followed in the following respects:
- The process may be rushed to meet a December 31, 2010 deadline regarding “transition rules” so as to benefit from less stringent 2004 standards and avoid the more stringent 2009 standards. The 2009 standards are based on newer science and as a result are more protective of human health and the environment. Therefore, it is in the public’s best interest for the newer standards to be used at this site given that it is in a densely populated urban setting close to bodies of water and park areas that are extensively used for recreation and as habitat for urban wildlife including birds, small mammals and fish.
- Citizen concern about major landfills and waste deposits on the site has been raised by the fact that, to date the city has not released its own Phase II Environmental Site Assessment to the public. Furthermore, the city has not carried out the public consultation that is appropriate for this project given that the Lansdowne property is public land located in a densely populated area of Ottawa, and is used extensively by the public for community events. The development of an appropriate plan for managing site contamination should be done in a way that allows the public to be informed and to provide input. The GCA expects that a full and open public information dissemination and consultation process be followed as part of the overall plan for the development of the site. This has not yet occurred.
- Our best information suggests that the city has not changed its plans for remediation. A minimum of the site may be classed as Residential / Parkland / Institutional, and conversely, a maximum as Industrial / Commercial / Community, including the heretofore public park adjacent to the Rideau Canal, so as to artificially avoid stricter regulations associated with the Residential / Parkland / Institutional classification. The city is planning to dump tens of thousands of tonnes of waste construction material and soil contaminated with metals and polycyclic aromatic hydrocarbons in an on-site berm. This berm will be close to a settling pond and near the Rideau Canal, a World Heritage site just over 30 meters away, which draws into the Ottawa River a fishery and municipal water source which itself would be adversely impacted by drainage of contaminants from the Lansdowne dumps. This approach avoids more strict regulations associated with moving it off site. The berm disposal method proposed by the City has not been tested under Lansdowne circumstances.
Essentially, the city proposes to establish a waste disposal site at Lansdowne Park. A risk assessment and risk management plan are to be prepared by the City in support of the above soil management approach, a costly, time-consuming and uncertain endeavour if properly done. Given the information in the reports cited above and the failure of the city to address the cost implications of a proper cleanup (estimated at $20 million by XCG) we have strong environmental and, indeed, health concerns about the city’s plan. The GCA is firmly opposed to the establishment a waste disposal site on the subject property in the form of a berm constructed of contaminated soil.
Because of the level of expert criticism by the XCG, the GCA requests that the Peer Review be included in the documents used by the Ministry of the Environment for its review under the Environmental Protection Act (EPA).
In summary, City of Ottawa Council approved major redevelopment of this site located in a high density residential area and adjacent to the World Heritage Rideau Canal. Significant contamination has been identified on the site. The Glebe Community Association is concerned about both the potential short term impact on residents of the area, including a long term care facility directly across from the site, during the excavation and redevelopment of the site, and the prolonged environmental and health consequences of disposing of the contaminated material either by burying it on the site or placing it in a berm.
Sincerely,
original signed by
Caroline Vanneste
GCA President
cc: The Honourable Dalton McGuinty
Premier of Ontario
Legislative Building, Queen's Park
Toronto, ON M7A 1A1
Dalton.McGuinty@premier.
The Honourable Deb Matthews, PhD
Minister of Health and Long Term Care
10th Floor, Hepburn Block
80 Grosvenor Street
Toronto, ON M7A 2C4
Director, Ottawa District Office of the Ministry of the Environment
2430 Don Reid Drive
Ottawa, ON
K1H 1E1
Gord Miller
Environmental Commissioner of Ontario
075 Bay Street, Suite 605
Toronto, ON M5S 2B1
City of Ottawa Mayor Jim Watson
110 Laurier Avenue West
Ottawa, ON K1P 1J1
City of Ottawa Councillor David Chernushenko
110 Laurier Avenue West
Ottawa, ON K1P 1J1
Yasir Naqvi, MPP
411 Roosevelt Avenue
Ottawa, ON K2A 3X9
Paul Dewar, MP
1306 Wellington Street
Ottawa, ON K1Y 3B2
Marie Lemay, Chief Executive Officer
National Capital Commission
202-40 Elgin Street
Ottawa, ON K1P 1C7
Alan Latourelle, Chief Executive Officer
Parks Canada
25-7-N Eddy Street
Gatineau, Quebec K1A 0M5
1. http://www.letsgetitright.ca/news-and-media/docs
2. http://letsgetitright.ca/images/docs/lansdowne-park-phase2-esa-report-final.pdf
3. http://www.letsgetitright.ca/images/peer%20review%20lansdowne%20summary%20nov%2018.pdf