ministry review of the goderich harbour wharf expansion

Ministry Review of the Goderich Harbour Wharf Expansion Environmental Assessment Review prepared pursuant to subsection 7(1) of the Environmental Assessment Act, R.S.O 1990 Province of Ontario by the Ministry of the Environment, Environmental Approvals Branch

Cette publication n’est disponible qu’en anglais conformément au Règlement 671/92, selon lequel il n’est pas obligatoire de la traduire en vertu de la Loi sur les services en français. Pour obtenir des renseignements en français, veuillez communiquer avec le ministère de l’Environnement au 1-800-461-6290 ou à 416-314-8001.

NEED MORE INFORMATION?

Public Record Locations The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office:

Director Ministry of the Environment

Environmental Approvals Branch 2 St. Clair Avenue West, Floor 12A

Toronto, Ontario Fax: (416) 314-8452

Re: Goderich Port Management Corporation Proposed Harbour Wharf Expansion

Environmental Assessment Report Attention: Andrew Evers, Project Officer

Telephone: 416-314-7213 Email: [email protected]

The Review and Notice of Completion are also available at the following locations: Ministry of the Environment Town of Goderich Municipal Office Owen Sound District Office 57 West Street 101 17th Street East Owen Sound, Ontario M4V 1L5 (519) 371-2901/1-800-265-3783 Huron County Public Library, Goderich Branch 52 Montreal Street Goderich, Ontario N7A 2G4 (519) 524-9261

Goderich, Ontario N7A 2K5 (519) 525-8344

The Notice of Completion and Ministry Review is available on the Ministry’s website at: https://www.ontario.ca/environment-and-energy/goderich-harbour-wharf-expansion This Review is subject to the provisions of Ontario Regulation 616/98 which sets out a deadline for the completion of this document. The deadline for the completion of the Review was May 30, 2014. This paragraph and the giving of the Notice of Completion are the notices required by subsection 7(3) of the Environmental Assessment Act. The five-week public review period of the Ministry Review ends on July 25, 2014. The Review documents the Ministry’s evaluation of the EA and takes the comments of the government agencies, the public and Aboriginal communities into consideration. © Queen’s Printer for Ontario, 2014 PIBS 9701E

Table of Contents Executive Summary ............................................................................................ 1

1. Environmental Assessment Process ..................................................... 2 1.1 Terms of Reference ......................................................................... 2 1.2 Environmental Assessment ............................................................. 3 1.3 Ministry Review ............................................................................... 3

2. The Proposed Undertaking ..................................................................... 4

3. Results of the Ministry Review ............................................................... 7 3.1 Conformance with the Terms of Reference and Environmental

Assessment Act ............................................................................... 7 3.1.1 Ministry Analysis .................................................................. 7 3.1.2 Consultation ......................................................................... 7 3.1.3 Conclusion ......................................................................... 18

3.2 EA Process .................................................................................... 18 3.2.1 Key Issues ......................................................................... 21 3.2.2 Conclusion ......................................................................... 24

3.3 Proposed Undertaking ................................................................... 24 3.3.1 Key Issues ......................................................................... 25 3.3.2 Conclusion ......................................................................... 26

4. Summary of the Ministry Review .......................................................... 27

5. What Happens Now? ............................................................................. 29 5.1 Additional Approvals Required ...................................................... 29 5.2 Modifying or Amending the Proposed Undertaking ....................... 30

List of Appendices Appendix A Environmental Assessment Act Requirements Appendix B Submissions Received During the Initial Comment Period Appendix C Supplemental Information List of Tables Table 1 Government Review Team Comment Summary Table Table 2 Public Comment Summary Table Table 3 Aboriginal Communities Comment Summary Table

Goderich Harbour Wharf Expansion Environmental Assessment Review

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Executive Summary WHO Goderich Port Management Corporation

WHAT Ministry Review of an Environmental Assessment (EA) for

the proposed undertaking which includes: • The construction, operation and maintenance of the

Goderich harbour wharf expansion. • The undertaking will include the construction of a twin-

slip dock in the northern portion of the outer harbour, which will allow for two additional docking spaces, usable storage space of 6.3 hectares and added wave protection.

WHEN EA Submitted: February 21, 2014.

The Ministry Review comment period will commence on June 20, 2014 and conclude on July 25, 2014.

WHERE The proposed undertaking will be located on the east shore of Lake Huron in the Town of Goderich. The expansion of the harbour will be located in the northern portion of the outer harbour.

WHY The purpose of the undertaking is to address the need for additional loading/unloading space, the need for storage space for existing and future shipping operations and to better shelter the harbour from adverse lake conditions.

CONCLUSIONS The Ministry Review concludes that the EA was prepared in accordance with the approved Terms of Reference and contains sufficient information to assess the potential environmental effects of the proposed undertaking.


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1. Environmental Assessment Process Environmental Assessment (EA) is a proponent driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of an undertaking on the environment. In Ontario, the Environmental Assessment Act (EAA) sets out the general contents for the preparation of an EA, as well as the Ministry’s evaluation process. For those proponents and undertakings subject to the EAA, approval under the EAA is required before the undertaking can proceed.

Proponents address a wide range of potential effects on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. An EA determines, on the basis of the environmental effects, if an undertaking should proceed, and if so, how environmental effects can be managed.

EAs may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred undertaking from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with interested stakeholders including a Government Review Team (GRT), the public and affected Aboriginal communities to evaluate the alternatives and determine the preferred undertaking. Once the undertaking is approved, the proponent is required to monitor to demonstrate compliance with standards, regulations and the EAA approval.

1.1 Terms of Reference

Preparing an EA is a two-step application to the Minister of the Environment (Minister). The first step requires the proponent to prepare and submit a Terms of Reference (ToR) to the Ministry of the Environment (Ministry) for review and approval. The ToR is the work plan or framework for how the EA will be prepared.

On February 10, 2011, the Minister approved the Goderich Port Management Corporation’s ToR. The ToR set out how the Goderich Port Management

EA Process

ToR Approval ↓

EA Preparation ↓

EA Submission ↓

EA Comment Period ↓

MMiinniissttrryy RReevviieeww ↓

Review Comment Period ↓

Minister’s Decision


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Corporation would assess alternatives, assess environmental effects and consult with the public during the preparation of the EA.

1.2 Environmental Assessment

Once the ToR is approved by the Minister, the proponent can proceed to the second step of the EA process and carry out the EA. The EA must be prepared in accordance with the approved ToR and the requirements of the EAA. Once the proponent has carried out the EA, including consultation, the EA is submitted to the Ministry for review and decision.

On February 21, 2014, the Goderich Port Management Corporation submitted the Goderich Harbour Wharf Expansion Environmental Assessment to the Ministry for decision for the proposed expansion of the Goderich harbour wharf, which includes the construction of a twin-slip in the northern portion of the outer harbour accommodating two additional docking spaces, usable storage space of 6.3 hectares and added wave protection. The EA comment period ended on April 11, 2014.

1.3 Ministry Review

The EA was circulated for review to a GRT. The GRT, including federal, provincial and local agencies, reviewed the EA to ensure that the information and conclusions of the EA were valid, based on their agencies’ mandates. The public and Aboriginal communities also had an opportunity to review the EA and submit their comments to the Ministry. All comments received by the Ministry are considered by the Minister before a decision is made about the EA undertaking.

The EAA requires the Ministry to prepare a review of the EA, known simply as the Ministry Review (Review). The Review is the Ministry’s evaluation of the EA. The purpose of the Review is to determine if the EA has been prepared in accordance with the approved ToR and therefore meets the requirements of the EAA and whether the evaluation in the EA is sufficient to allow the Minister to make a decision about the proposed undertaking.

The Review outlines whether the information contained in the EA supports the recommendations and conclusions for the selection of the proposed undertaking. Ministry staff evaluated the technical merits of the proposed undertaking, including the anticipated environmental effects and the proposed impact management measures. The Review also provides an overview and analysis of the public, agency and Aboriginal community comments on the EA and the proposed undertaking.


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The Minister considers the conclusion of the Review when making a decision; the Review itself is not the EA decision-making mechanism. The Minister’s decision will be made following the end of the five-week Review comment period. The Minister’s decision is subject to the approval of the Lieutenant Governor in Council.

The Review comment period allows the GRT, the public and Aboriginal communities to see how their concerns with the EA and the proposed undertaking have been considered. During the Review comment period, anyone can submit comments on the EA, the undertaking and the Review. In addition, anyone can request that the Minister refer the EA, or any matter relating to the EA, to the Environmental Review Tribunal for a hearing if they believe that there are significant outstanding environmental effects that the EA has not addressed. Requests for a hearing can only be made during this comment period. The Minister will consider all requests and determine if a hearing is necessary.

A Notice of Completion of the Review was published in the Goderich Signal Star indicating that this Review has been completed and is available for a five-week comment period from June 20, 2014 to July 25, 2014. The Notice was also posted on the Ministry’s website. Copies of the Review have been placed in the same public record locations where the EA was available, and copies have been distributed to the GRT members and potentially affected or interested Aboriginal communities. Those members of the public who submitted comments during the EA comment period have also received copies of the Review.

2. The Proposed Undertaking The proposed undertaking is the construction, operation and maintenance of the expansion of the Goderich Harbour located on the east shore of Lake Huron in the Town of Goderich (Figure 1). Specifically, the Goderich Port Management Corporation is seeking approval for:

• The expansion of the wharf by 7.69 hectares in the northern portion of the outer harbour;

• The twin-slip dock expansion will allow for two additional docking spaces along the expanded wharf and an increase in the usable storage space by 6.3 hectares; and

• Wave protection features (i.e., rock berm) as Goderich harbour is located on the windward side of Lake Huron and the outer harbour requires better protection from wave action.


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Possible improvements to North Harbour Road, including the intersection at Highway 21 were also included as part of the undertaking in the approved ToR. However, during the EA, a traffic assessment was completed and determined that improvements to North Harbour Road were not required to accommodate the Goderich Harbour Wharf Expansion.

Should approval under the EAA be granted, the Goderich Port Management Corporation intends to immediately finalize the detailed design for the proposed expansion. The final detailed design will be completed in discussions with the retained contractor, as well as based on the impact management measures, commitments and results of a future Public Information Centre (PIC) as indicated in the EA.

The proponent anticipates that if the EA is approved, construction will take 26 months once the necessary approvals and permits have been obtained. An Environmental Management Plan (EMP), which will include, but not be limited to environmental best management practices, EA commitments, EA conditions of approval, terms and conditions of authorizations, permits and approvals, compliance with legislative requirements and environmental risks associated with the project will be made available. In addition, a fish habitat management plan will be finalized prior to construction.

The proponent anticipates that the design life of the expanded wharf will be 100 years with routine maintenance. The EA assumes that after 100 years the needs of the port will likely be different from the current needs and at that time decisions will be made on what alterations need to be made to the port. The design features of the expanded wharf are expected to withstand a 100-year storm event, although some minor repairs may be required. Typical maintenance tasks that may be required over the 100-year operation period include re-paving, replacing lights and poles, maintenance dredging, repairing storm sewers and concrete, and restoring armour stone.

If EAA approval is granted, the Goderich Harbour Wharf Expansion will be completed in accordance with the terms and provisions outlined in the EA and any proposed conditions of approval, and it will include the details outlined above. In addition, Goderich Port Management Corporation must still obtain all other legislative approvals it may require for the undertaking.


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Figure 1:

Goderich Harbour Wharf Expansion Project Location


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3. Results of the Ministry Review The Review provides the analysis of the EA. The Review is not intended to summarize the EA, nor present the information found in the EA. For information on the decision making process, refer to the EA itself. The EA and supporting documentation outlines the EA planning process and demonstrates how the proponent has selected the preferred undertaking and made the final decision.

3.1 Conformance with the Terms of Reference and Environmental Assessment Act

3.1.1 Ministry Analysis

The Ministry’s analysis of the EA, in part, looked at whether the requirements of the ToR have been met. The Ministry considered the contents of the approved ToR and proponent’s EA, along with comments from the public, Aboriginal communities and the GRT, and has concluded that the Goderich Port Management Corporation has prepared the EA in accordance with the framework set out in the approved ToR, that the EA has sufficiently addressed the commitments made in the ToR, and that the EA clearly demonstrates how the requirements of the EAA have been met.

Appendix A summarizes this analysis and identifies how the ToR requirements have been addressed in the EA.

3.1.2 Consultation

One of the key requirements of the EAA is pre-submission consultation completed during the preparation of the EA. This consultation is the responsibility of the proponent and must be undertaken prior to the submission of the EA and in accordance with the consultation plan outlined in the ToR. During the preparation of the EA, the Goderich Port Management Corporation carried out a consultation

The purpose of the Ministry Review is to determine whether:

• The EA has met the requirements of the ToR and the EAA.

• There are any outstanding issues with the EA.

• The proposed undertaking has technical merit.

Must Haves in the EA:

• The EA must be prepared in accordance with the approved ToR.

• EA must include all the basic EAA information requirements.

• EA demonstrates where all the additional commitments in the ToR were met, including studies and the consultation process.

Section 5.1 of the EAA states: “When preparing proposed terms of reference and an

environmental assessment, the proponent shall consult with such persons as may be interested.”


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process that allowed for multiple opportunities for the exchange and review of information pertaining to the proposed project by the GRT, public and Aboriginal communities. In accordance with the consultation commitments that were outlined in the approved ToR, the Goderich Port Management Corporation carried out the following consultation methods during the preparation of the EA:

• Establishing and maintaining a stakeholder contact list; • Providing project related information and updates throughout the EA

process by way of a project web site, the publication of newsletters, written correspondence, and holding two Public Information Centres with open house format;

• Advertisements in the local newspaper providing notice of formal project milestones, and consultation events;

• Five meetings with interested Aboriginal communities were organized to present the project and status, identify lands of interest, discussion on traditional activities that may be affected, discuss impact management measures and the fish habitat compensation strategy;

• Other meetings in Aboriginal communities not included in the five meetings mentioned above regarding the status of the EA;

• Establishing the Regulatory Agency Advisory Group (RAAG) to obtain guidance on regulatory requirements and EA documents throughout the EA process;

• Maintaining a Record of Consultation documenting all issues or concerns that were raised during the preparation of the EA, and the responses to them;

• Government Agency meetings to discuss relevant issues and mandates; • The circulation of draft supplemental technical documents to interested

stakeholders, GRT and Aboriginal communities for review and comment; and

• The circulation of a Draft EA to the Ministry of the Environment, Fisheries and Oceans Canada (DFO), Transport Canada, Maitland Valley Conservation Authority (MVCA) and Ministry of Natural Resources for review and comment.

The objective of the Goderich Port Management Corporation’s consultation process was to ensure obligations under the Environmental Assessment Act were met, introduce the design of the undertaking and ensure that all affected agencies, Aboriginal communities, local stakeholders and the public were fully aware of and had the opportunity to be engaged in the consultation process and provide input, as well as ensure that the views and suggestions of all participants were given respectful consideration and due weight in refining plans for the design of the undertaking.


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In accordance with the requirements under Section 6(3) of the EAA, the Goderich Port Management Corporation documented its consultation process in a Record of Consultation, which provides a summary of the issues and concerns raised during the consultation process on the EA. The Record of Consultation was provided as a stand-alone document to accompany the EA Report. Once the EA is submitted to the Ministry, additional Ministry driven consultation occurs during the formal EA comment period. The GRT, the public and potentially affected Aboriginal communities were provided with the opportunity to review the EA and to submit comments to the Ministry on whether the requirements of the ToR had been met, on the EA itself and on the proposed undertaking. All comments received by the Ministry during the EA comment period were forwarded to Goderich Port Management Corporation for a response. Summaries of the all comments received along with the Goderich Port Management Corporation’s responses are included in Tables 1 to 3. Copies of the submissions are also available in Appendix B. Government Review Team Consultation During the preparation of the EA, the Goderich Port Management Corporation engaged in consultation with members of the GRT. The purpose this consultation was to identify those regulatory and GRT that may have a potential interest or mandate in the proposed undertaking and to identify any potential concerns about the proposed undertaking. The Goderich Port Management Corporation sought input from the members of the GRT through a variety of means including telephone calls, written and electronic correspondence, formal meetings and presentations. A summary of the consultation process carried out during the preparation of the EA with members of the GRT, the comments received and the Goderich Port Management Corporation’s responses to them can be found in Section 2.0 of the EA and the Record of Consultation. In addition to the GRT, the proponent established the RAAG as an advisory committee to review EA related documents and provide advice to the proponent during the EA process. The mandate of the RAAG was to:

• Provide an inclusive discussion and forum for agencies to advise the Study Team;

• Serve as a means to share and exchange information, ideas and concerns related to the Goderich harbour wharf expansion;

• Review and provide comments on the following documents: o Environmental technical reports; o Environmental Assessment Report; and o Public consultation materials including PIC displays.


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Four meetings were held with the RAAG; the first meeting being in person to discuss the ToR and provide a tour of Goderich harbour. The three subsequent meetings were held via teleconference and were used to discuss the status of the EA, upcoming PICs and the results of the PICs, agency concerns, consultation with Aboriginal communities and to solicit comments on the technical reports and the Draft EA Report. Once the proponent finalized its EA, members of the GRT were also provided with an opportunity to review and comment on the EA during the seven week inspection period, which commenced with the formal submission of the EA on February 21, 2014. The inspection period was coordinated by the Ministry, and members of the GRT were asked to provide any comments directly to the Ministry for consideration. All comments received by the Ministry were forwarded to the Goderich Port Management Corporation for a response. A summary of the comments received and the Goderich Port management Corporation’s responses can be found in Table 1 of this Review. The Ministry received comments from six government reviewers during the formal inspection period on the EA. Comments were received from the Canadian Environmental Assessment Agency, Aboriginal Affairs and Northern Development (AANDC), the County of Huron, MVCA and the Ministry of Tourism, Culture and Sport (MTCS). The Ministry of the Environment’s technical reviewers also undertook their own analysis of the EA. The Canadian Environmental Assessment Agency (CEA Agency) requested that the proponent review the regulations to determine applicability to the proposed project including those associated with wildlife areas and migratory birds. In addition, The CEA Agency requested that the proponent review Section 24(c) Regulations Designating Physical Activities to determine if the proposed project is subject to a federal EA. The Goderich Port Management Corporation responded and confirmed that Section 24(c) does not apply to the proposed project and included previous correspondence from the CEA Agency indicating that the Canadian Environmental Assessment Act (CEAA) does not apply to the proposed project. The County of Huron and AANDC indicated that they had no comments on the Final EA. The Ministry of Natural Resources (MNR) were provided the technical reports for review. The MNR Lakes Management Supervisor provided comments on the technical Reports. Comments were also received on the draft EA from the District Planner at the Guelph District MNR office, as well as from the MNR Lakes Management Supervisor. The comments and responses are provided in the Record of Consultation. The Ministry did not receive any comments on the Final EA from the MNR during the seven-week comment period.


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The MVCA indicated that a permit pursuant to Ontario Regulation 164/06 will be required prior to commencing the work and that the testing and control of fill will be placed as a condition on the permit. They also noted that the stormwater collection system should be equipped with an oil and grit separator, and that stormwater runoff should be treated to the normal water quality standard. The Goderich Port Management Corporation acknowledged the need for a permit. The Goderich Port Management Corporation also responded that the stormwater collection system will be developed during detailed design and that MVCA will have the opportunity to review the proposed collection system design. In addition, the proponent confirmed that fill used in the construction of the expanded wharf facility will be sampled in accordance with the Guidance on Sampling and Analytical Methods for Use at Contaminated Sites in Ontario (MOE 1996) and the Fill Quality Guide and Good Management Practices for Shore Infilling in Ontario (MOE 2011). The MTCS requested that the proponent confirm that only a marine archaeological assessment was completed since it appeared that there is no land archaeological component to the proposed project. The MTCS also requested that the proponent confirm that an interpretive plaque be installed at the harbour. The Goderich Port Management Corporation confirmed that only a marine archaeological assessment was required. A land archaeological assessment was not completed because no improvements to North Harbour Road were required, and the Goderich Port Management Corporation confirmed that no lands would be disturbed by the proposed project. The proponent also confirmed that an interpretive plaque would be installed at the harbour. The Ministry’s technical reviewers provided a number of comments regarding surface water, noise levels and air quality. The surface water specialist requested that the proponent follow the Canadian Council of Ministers of the Environment (CCME) standards for monitoring turbidity and requested that a more rigorous monitoring program for turbidity be implemented. The Goderich Port Management Corporation revised the monitoring program for turbidity. The noise engineer requested that the vacant lots adjacent to the site be modelled to determine noise levels and that further clarification on the noise source data, sound level calculations and transportation noise assessment be provided. The Goderich Port Management Corporation clarified that the vacant lot is actually a restaurant and is not a sensitive receptor requiring assessment. The EA indicates that best management practices will be implemented to control dust and NOx emissions during construction, operation and maintenance. As such, the EA indicates that there will be no net effects to air quality during construction, operation and maintenance of the proposed undertaking. The air quality specialist has requested the monitoring and modelling data to verify the


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results and conclusions of the air quality assessment. The Ministry’s review of the modelling and monitoring will be completed before a decision is made on the EA. Summaries of the all comments received from members of the GRT, along with the Goderich Port Management Corporation’s responses, can be found in Table 1 of this Review. Public Consultation Members of the public, including harbour users, local residents, local businesses and other stakeholders, were provided with several opportunities to participate and provide input during the preparation of the EA. The Goderich Port Management Corporation carried out consultation during the preparation of the EA with members of the public in a variety of ways, including: holding two Public Information Centres (PICs); written correspondence; newspaper notifications of EA milestones and consultation opportunities; and posting information and materials to a project website. The objective of public consultation was to inform and seek input from interested members of the public on the EA process and the proposed undertaking. A summary of the consultation process carried out during the preparation of the EA with members of the public, the comments received and the Goderich Port Management Corporation responses to them can be found in Section 2.0 of the EA and the Record of Consultation. Both PICs held were advertised in the Goderich Signal Star, which is the local newspaper. The purpose of the first PIC was to present the proposed project and discuss the EA process. A formal presentation and question and answer period was held during this PIC. The purpose of the second PIC was to present the refined project design, the evaluation process for alternative methods and the preferred method that was selected. Anticipated impact management measures and permits and approvals were also presented. A formal presentation and question and answer period was held during this PIC. Summaries of the PICs can be found in the Appendix G and H of the Record of Consultation. The proponent has committed to holding a final PIC during detailed design.

Members of the public were also provided with an opportunity to review and comment on the EA during the seven week inspection period that commenced with the formal submission of the EA on February 21, 2014. The inspection period was coordinated by the Ministry and members of the public were asked to provide any comments directly to the Ministry for consideration.

The Ministry received comments from Maitland Valley Marina Limited, as well as from three members of the public. The comments received included concerns regarding potential noise impacts related to the expansion of the wharf and access to the wharf for recreational activities. Summaries of the all comments


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received from the public, along with the Goderich Port Management Corporation’s responses, can be found in Table 2 of this Review.

The Maitland Valley Marina Limited, as well as two other members of the public provided comments regarding the noise assessment, including noise related to trucks. The Goderich Port Management Corporation responded by directing the commenter to the appropriate section of the report where their comment is addressed as well as referring to the applicable guidelines for the assessment. A member of the public also identified concerns related to recreational use of the harbour. The proponent responded that access to the harbour is maintained by the Town of Goderich. A plan is being developed by the Town of Goderich with interests groups to balance public access and public safety at the harbour. The proponent has committed to providing formal letter responses to the members of the public who provided comments on the Final EA.

Aboriginal Community Consultation During the preparation of the EA, the Goderich Port Management Corporation contacted both the Ministry of Aboriginal Affairs and Aboriginal Affairs and Northern Development Canada. The purpose of which was to seek guidance in identifying those Aboriginal communities that may have an interest or be potentially impacted by the proposed undertaking, and should therefore be involved in the EA process. The following Aboriginal communities and organizations were identified as having a potential interest in the proposed undertaking:

• Association of Iroquois and Allied Indians; • Union of Ontario Indians; • Chippewas of Nawash; • Chippewas of Saugeen; • Saugeen Ojibway Nation; • Walpole Island First Nation; • Chippewas of Kettle and Stony Point; • Aamjiwnaang First Nation; • Oneida Nation of the Thames; • Elected Six Nations of the Grand River Territory; • Six Nations of the Grand River Territory – Haudenosaunee Development

Institute; • Historic Saugeen Métis; • Georgian Bay Métis Council; • Métis Nation of Ontario; and • Office of the Federal Interlocuter for Métis and Non-status Indians.

Aboriginal communities were contacted at key milestones during the preparation of the EA, including the Notice of Commencement, Notification of Public


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Information Centres and the Notice of Completion. Much of the consultation with Aboriginal communities occurred over five meetings centralized meetings with interested Aboriginal communities. The Aboriginal communities that participated in the meetings regularly were Walpole Island First Nation, Aamjiwnaang First Nation and the Saugeen Ojibway Nation (include Chippewas of Nawash and Chippewas of Saugeen). The Chippewas of Kettle and Stony Point were invited to all five meetings and received the meeting notes, but only attended the first meeting. Individual correspondence in the form of emails, telephone calls, meetings and letters were made to the remaining Aboriginal communities listed above. The proponent attended two meetings with the Historic Saugeen Métis. The details of these meetings are described below. The Union of Ontario Indians and Georgian Bay Métis Council indicated that the project was outside of their traditional territory. The Elected Six Nations of the Grand River Territory indicated that they had no objections to the expansion of the harbour. A number of follow-up attempts were made with Association of Iroquois and Allied Indians, Oneida Nation of the Thames, Six Nations of the Grand River Territory – Haudenosaunee Development, Métis Nation of Ontario and Office of the Federal Interlocuter for Métis and Non-status Indians as documented in the Record of Consultation; however, no comments were received. The purpose of the five meetings with Aboriginal communities was to initiate discussions on the proposed undertaking and to provide status updates on the EA. These meetings were also used to discuss potential effects of the project on fish and fish habitat, water quality and introduction of invasive species. A representative from DFO attended the meetings to discuss the fish habitat compensation plan including recommendations for compensation projects. Permits and approvals, the EMP and the request for proposal from contractors were also discussed. The Goderich Port Management Corporation went through the comments on the technical reports from the Aboriginal communities and presented their responses. The proponent also met independently with specific Aboriginal communities as outlined in the sections below. A description of the correspondence with interested Aboriginal communities and the issues raised by each Aboriginal community during the preparation of the EA is described in the subsequent sections. Aamjiwnaang First Nation As stated above, a representative from Aamjiwnaang First Nation attended all five meetings held with the Goderich Port Management Corporation. In addition, a presentation was made to the Chief and Council on November 8, 2012 and to the Environmental Committee on December 4, 2012. No comments were received at these meetings. The technical reports were provided for review and


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a joint review with Saugeen Ojibway Nation was completed. An Open House was held at Aamjiwnaang First Nation on June 13, 2013. No comments were received by the proponent at this Open House. Chippewas of Kettle and Stony Point The Communication Relations Officer for Chippewas of Kettle and Stony Point attended the first meeting. The Communications Relations Officer indicated at this meeting that a presentation by the proponent to the community would likely be required to present the project. However, the proponent followed up and no response was provided by Chippewas of Kettle and Stony Point to hold a presentation. The Chippewas of Kettle and Stony Point were invited to the subsequent centralized meetings with interested Aboriginal communities; however, they did not attend. The proponent provided the meeting minutes of all of the centralized meetings to Chippewas of Kettle and Stony Point for their reference. The technical reports were also provided for review; however, no comments were provided. Historic Saugeen Métis The proponent met with the Historic Saugeen Métis on two occasions. During the initial meeting the Historic Saugeen Métis inquired if any building structures would be constructed and asked about the fill material to be used for the wharf expansion. The Goderich Port Management Corporation responded that the materials being stored on the expanded site did not require indoor storage facilities. With regard to the fill material, the Goderich Port Management Corporation indicated that fill materials would likely be shipped in and armour stone would be trucked to the site. In addition, all fill materials would be clean of any contaminants. The Historic Saugeen Métis also inquired about areas for recreational use. The proponent responded that the harbour is mainly for commercial use, but two marinas are located north of the harbour at the mouth of the Maitland River. A subsequent meeting was held with Historic Saugeen Métis to review the EA technical reports. The Historic Saugeen Métis did not provide formal comments on the draft technical reports. Saugeen Ojibway Nation Prior to the five meetings mentioned above, the Saugeen Ojibway Nation submitted an email to the proponent indicating that the project is in an area that has Aboriginal Title claims and territory for the Chippewas of Nawash First Nation and Chippewas of Saugeen First Nation (collectively referred to as the Saugeen Ojibway Nation). The Territorial Resources Coordinator participated in all five centralize meetings. In the initial meeting, the Territorial Resources Coordinator stated that the proponent would need to demonstrate the Aboriginal communities were consulted in a meaningful way. In addition, a benefit to the local Aboriginal


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communities would also need to be documented. This benefit may be in the form of revenue sharing, employment opportunities or environmental monitoring. The Goderich Port Management Corporation entered into a Memorandum of Understanding (MOU) to provide capacity funding to the Saugeen Ojibway Nation to facilitate the peer review of the technical reports. Further to this, the interested Aboriginal communities agreed to a coordinated review of the technical reports and the Saugeen Ojibway Nation would lead this review. In early 2014, a MOU was signed between Saugeen Ojibway Nation and the Goderich Port Management Corporation for the inclusion of a stable isotope analysis in the fish habitat compensation plan. The purpose of the stable isotope analysis is for determining the structure of the aquatic food web surrounding the wharf expansion. The proponent also attended Community Information Sessions at Saugeen Ojibway Nation on February 20, 2014, and at Chippewas of Nawash First Nation on February 21, 2014 at the Community Centre. Details of these meetings and presentation materials are provided in Appendix C. Walpole Island First Nation The Walpole Island First Nation attended all five centralized meetings between the proponent and the Aboriginal communities. During the initial centralized meeting with Aboriginal communities, the Walpole Island First Nation noted that the Lake Huron lakebed is not covered by any First Nation treaties; however, it is the local Aboriginal communities’ position that they hold title to these lands. The Walpole Island First Nation Project Review Coordinator indicated there were a number of fisheries projects that could be recommended as part of the fish compensation strategy. Walpole Island First Nation agreed to a coordinated peer review of the technical reports with Aamjiwnaang First Nation, Saugeen Ojibway Nation and Chippewas of Kettle and Stony Point. The Chief of Walpole Island First Nation expressed his support for the Swan Lake Marsh Enhancement Project and Fighting Island Reef Enhancement Project as part of the Goderich Wharf Expansion Fish Compensation Strategy. Both projects have since been included in the draft fish habitat compensation strategy. A summary of the consultation process carried out during the preparation of the EA with Aboriginal communities, the comments received and the Goderich Port Management Corporation’s responses to them can be found in Section 2.0 of the EA and Record of Consultation. Aboriginal communities were also provided with an opportunity to review and comment on the EA during the seven week inspection period that commenced with the formal submission of the EA on February 21, 2014. The inspection period was coordinated by the Ministry, and Aboriginal communities were asked to provide any comments directly to the Ministry for consideration. All comments received by the Ministry were forwarded to the Goderich Port Management Corporation for a response. A summary of the comments received and the


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Goderich Port Management Corporation’s responses can be found in Table 3 of this Review. The Ministry received one comment from the Historic Saugeen Métis during the formal inspection period. Comments indicated that they had no issues with the EA Report and Sediment Transport Impact Analysis. The Historic Saugeen Métis requested that they be kept informed during project detailed design and while acquiring the necessary approvals and permits, as well as requested that they are able to review the Stormwater Management Report, drawings and are consulted on the proposed construction methods. At the conclusion of the the seven-week inspection period on the EA, the Ministry contacted each of the Aboriginal communities that indicated they had potential interest in the proposed undertaking one final time. The purpose of which was to confirm that each community received the project information that was circulated as part of the Goderich Port Management Corporation’s consultation process, and to verify that those communities had any outstanding issues or concerns. A letter of support of the project from Chief Burton Kewayosh from Walpole Island First Nation was provided along with a covering letter acknowledging that they were pleased with the consultation process on the project to date. The Ministry received a phone call from Aamjiwnaang First Nation on April 30, 2014 indicating that they had no comments or concerns with the EA and that a formal letter would be provided following their committee meeting on May 14, 2014. The Saugeen Ojibway Nation provided a letter on May 22, 2014. The letter indicates the Saugeen Ojibway Nation’s concern with potential effects to Aboriginal rights and land claims, specifically to commercial fishing in the area. The letter noted the agreement that was entered into between Saugeen Ojibway Nation and the proponent in May 2013 that guaranteed that the Saugeen Ojibway Nation’s technical advisors would have the opportunity to review the technical reports. Subsequently, another agreement was made for the inclusion of the stable isotope analysis in the fish habitat compensation plan. The Saugeen Ojibway Nation’s technical advisors noted that restoration efforts indicated in the EA are suitable mitigation measures for the project. In addition, the letter states that there are small details requiring resolution; however, these can be addressed during the monitoring process for the project. The Goderich Port Management Corporation acknowledged the letter and committed to on-going consultation with Saugeen Ojibway Nation.

A summary of the comments received from Aboriginal communities, along with the Goderich Port Management Corporation’s responses, can be found in Table 3 of this Review.


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Ministry Conclusions on the Consultation Program

Overall, the Ministry is satisfied that the Goderich Port Management Corporation has provided sufficient opportunities for interested members of the public, GRT and Aboriginal communities to be consulted during the preparation of the EA. The EA clearly documents the consultation methods utilized by the Goderich Port Management Corporation to engage these groups during the EA process, and clearly sets out the issues and concerns raised and how they have been addressed. The Goderich Port Management Corporation has provided additional responses to comments made on the Final EA to clarify how outstanding issues have been or will be addressed, with the exception of additional information pertaining to the air quality assessment, which is forthcoming. Should the EA be approved, the Goderich Port Management Corporation has committed to continue its consultation efforts with interested members of the public, GRT and Aboriginal communities during the detail design, monitoring and implementation of the proposed undertaking.

3.1.3 Conclusion

The Ministry is satisfied that consultation on the EA has been undertaken in accordance with the requirements of the ToR and demonstrates how the required components of the EAA for consultation have been met.

3.2 EA Process

EA is a planning process that requires a proponent to identify an existing problem or opportunity; consider alternative ways of addressing the problem or opportunity; evaluate the environmental effects of a reasonable range of alternatives; and, select a preferred alternative that will become the undertaking for which approval under the EAA will be sought.

The ToR was approved on February 10, 2011. The EA process was initiated by the Goderich Port Management Corporation on November 9, 2011, with the publication of a Notice of Commencement of an EA. The purpose of undertaking the EA process was to complete an evaluation of the alternative wharf sites and subsequently an evaluation of the alternative wharf designs for the expansion of the wharf. Following the selection of the preferred wharf site and design, the potential effects of the preferred undertaking and impact management measures intended to minimize or avoid any potential negative effects of the preferred undertaking were identified and described.

The proposed undertaking is a continuation of efforts by the Goderich Port Management Corporation to identify problems encountered in the harbour regarding sediment deposition and exposure to wind and wave action. The Goderich Port Management Corporation – Harbour Rehabilitation Master Plan


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published in 2006, identifies several projects that are required to alleviate wave action in the harbour and reduce sedimentation. In addition to these issues, Sifto Canada Corporation, a major salt producer located in Goderich harbour, completed an expansion to its operations in 2012. Sifto’s increase in production was not contingent on the expansion of the wharf facilities; however, the Goderich Port Management Corporation would like to increase the use of the port by providing additional loading/unloading space for ships and storage for salt and other commodities. Therefore, the Goderich Port Management Corporation is proposing the expansion of the wharf to provide for additional stable off-loading and on-shore storage, as well as increase protection from wave action.

In accordance with the approved ToR, the Goderich Port Management Corporation prepared an EA pursuant to subsection 6.1(3) of the EAA, which states that an EA may consist of information other than the generic requirements as outlined in subsection 6.1(2). This approach was designed for proponents who are more advanced in their decision making; such as proponents who have already identified a specific undertaking for which the consideration of “Alternatives To” is not appropriate or who have completed a separate planning process that resulted in the identification of a preferred “Alternative To”. Proponents preparing an EA in accordance with subsection 6.1(3) of the EAA may focus the EA process on the assessment of “Alternative Methods”. The EA provides a justification for focusing the EA based on the assessment of “Alternatives To” carried out by the Goderich Port Management Corporation in the approved ToR.

The preparation of the EA was focused on the selection and evaluation of a reasonable range of “Alternative Methods” or potential wharf sites and subsequently wharf designs for the expansion of the Goderich harbour wharf within a defined Study Area. In accordance with the approved ToR, the Study Area for the EA process was divided into primary and secondary study areas. The primary study area was restricted to the inner and outer harbour identified for the expanded wharf facilities. The secondary study area includes the mouth of the Maitland River and lower Maitland River valley areas adjacent to the harbour (Figure 1 in this Review). The Goderich harbour is located at the mouth of the Maitland River, in the northwest quadrant of the Town of Goderich municipal limits, on the east shore of Lake Huron.

In accordance with the approved ToR, the Goderich Port Management Corporation carried out studies and research to compile an inventory of the existing natural, socio-economic and cultural environments of the Study Area. The inventory was used to establish the baseline conditions for which the potential effects of the proposed undertaking would be assessed during the preparation of the EA. A description of the existing environment and the components of the environment that could be potentially affected by each of the alternatives being considered can be found in Section 3.0 of the EA.


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The preliminary screening of “Alternatives To” was completed in the approved ToR; therefore, no evaluation of “Alternatives To” was required for the EA. The EA identified and evaluated a reasonable number of wharf sites and designs within the EA Study Area (“Alternative Methods”). A summary of the evaluation method used to identify and evaluate potential locations and designs for the Goderich harbour wharf expansion is provided in Section 4.0 of the EA.

A total of four (4) alternative wharf sites were identified as viable locations for the proposed undertaking and screened against the following criteria:

• Provide sufficient number of docks and dock area for loading/unloading; • Provide sufficient wharf area for materials storage; • Provide protection from wind and wave action; • Provide sufficient seaway depth; • Optimize efficiency/effectiveness of harbour operations; • Minimize adverse effects on the natural environment; • Minimize adverse effects on the socio-economic environment; and • Maximize cost effectiveness.

As a result of the screening process, two (2) of the potential sites were eliminated as nonviable alternatives and two (2) sites where presented at PIC#2 as possible sites for the expansion of the wharf.

Following the qualitative evaluation of the alternative wharf sites to select a preferred wharf site, an evaluation of three (3) alternative wharf designs was completed; no slip, single slip and twin-slip options. The alternative wharf designs were evaluated against a range of criteria and indicators related to the natural, socio‐economic, cultural and physical environments, and a range of technical engineering considerations. The criteria and indicators were weighted based on the relative importance to each component of the Study Area environment, and were then given a quantitative result. The wharf design with the highest score was forwarded on as the preferred alternative for the assessment of potential effects. The evaluation was built upon baseline data and the existing conditions in the Study Area. A summary of the evaluation of alternative wharf can be found in Section 4.0 of the EA. The advantages and disadvantages for the alternative wharf designs were not evaluated in the EA, but this information was provided by the proponent following the EA comment period, and is provided in Appendix C of this Review.

Based on the results of the evaluation of alternative wharf designs, the Goderich Port Management Corporation identified the preferred site and twin-slip design for the expansion of the wharf as a 7.69 hectare area allowing 6.3 hectares of usable storage space located in the northern portion of the outer harbour (Figure 1). A detailed description of the preferred alternative can be found in Section 5.0 of the EA.


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In accordance with the approved ToR, the Goderich Port Management Corporation completed an assessment of the proposed undertaking, including the identification of potential effects, and impact management measures to address the potential effects of the proposed preferred undertaking on the natural, social, cultural and built environments. A summary of the potential effects, proposed impact management measures and resulting net effects of the preferred undertaking can be found in Section 6.0 and in Tables 6-5 and 6-6 of the EA.

As part of the description of the preferred undertaking, the Goderich Port Management Corporation also developed a draft monitoring and contingency plan, which will be finalized during project detailed design if the EA is approved. The objectives of the monitoring and contingency plan are to:

• Augment existing information and databases, where required; • Determine the accuracy of impact predictions and the effectiveness of

environmental protection measures; • Ensure compliance with federal, provincial and local legislation and

regulations; and • Ensure the EA commitments are carried out as planned.

The plan applies to all phases of the undertaking including: pre-construction, construction and operations and maintenance. In some cases, monitoring reports will be provided to the appropriate agency for review. A summary of the draft monitoring and contingency plan can be found in Table 6-7 of the EA.

The Goderich Port Management Corporation followed a logical and transparent decision making process that was clearly outlined in the EA. The EA provides an evaluation of a reasonable range of alternative wharf sites and wharf designs that would be a viable option with respect to the purpose of the undertaking. The analysis and evaluation of alternatives assessed the potential environmental effects for the alternative sites and designs. An assessment of the potential effects, net effects, advantages and disadvantages of the preferred undertaking was completed and impact management measures were developed to address the potential negative environmental effects.

3.2.1 Key Issues

A detailed summary of the comments received during the preparation of the EA, and how the issues raised were addressed, can be found in Section 2.0 of the EA. The comments received, and the Goderich Port Management Corporation’s responses to them, are also documented in a Record of Consultation provided with the EA.


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Key issues regarding the EA process completed by the Goderich Port Management Corporation for the Goderich Harbour Wharf Expansion were gathered during the pre-submission consultation and the EA review comment period. A number of issues requiring clarification by the proponent were brought up by the Ministry. These submissions can be found in Appendix B of this Review. Key issues are discussed below, and all comments, including Goderich Port Management Corporation’s responses and MOE’s level of satisfaction can be found in Tables 1 to 3 of this Review. The Ministry identified that the proponent’s approved ToR indicated that a marine archaeological assessment and a Stage 1 archaeological assessment would be completed, and subsequently a Stage 2 archaeological assessment, if required. However, only a marine archaeological assessment was submitted with the Final EA. The proponent was requested to provide justification to explain why a Stage 1 archaeological assessment was not warranted. The Ministry requested this justification from the proponent following the review of the Final EA. The proponent responded that a Stage 1 archaeological assessment was not completed as it was determined through a traffic assessment that no improvements to North Harbour Road are required as a result of the expansion and no laydown or storage areas were to be constructed; therefore, no new land disturbance as a result of the proposed project is expected. The Ministry requested clarity regarding the method used to evaluate “Alternative Methods” for the undertaking. The Final EA presents the criteria and indicators used to evaluate the alternative methods, but it was not clear how the scoring was assigned to determine the preferred method. In addition, the proponent did not provide the relative advantages and disadvantages of the alternative methods. The proponent provided the process for inputting the data into the software (VISA software) used to complete the evaluation of alternative methods and sensitivity analysis. In addition, the proponent provided a supplemental table outlining the relative advantages and disadvantages of the alternative methods, which is provided in Appendix C of this Review. The approved ToR indicated that an evaluation of construction methods would be included in the EA. The Final EA did not include an evaluation of the construction methods, but indicated that the preferred construction method would be determined during the detailed design phase of the project. The proponent was requested to provide appropriate justification to explain why an evaluation of the construction methods was not warranted. The proponent responded indicating that the construction method described in the EA is typical for the expansion of the harbour; however, contractors may propose alternative construction methods in their bid for the project. The proponent committed to accepting proposals from contractors that are in line with environmental requirements including legislation, permits/approvals, EA commitments and EA conditions of approval if the proposed undertaking is approved. In addition, the


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proponent will hold a PIC during detailed design to present the preferred construction method, which will allow the GRT, the public and Aboriginal communities to provide comments on the proposed construction method. A number of commitments were made throughout the EA that would be implemented during detailed design. The Ministry requested that a list of these commitments be provided so that they were consolidated into one list. The proponent provided a consolidated list of the commitments to be implemented during the detailed design phase. These are provided in Appendix C of this Review. The Ministry identified a number of inconsistencies in the monitoring plan described in Section 6.0 and in Table 6-7 of the EA Report. The surface water evaluator also requested that the proponent increase the frequency of turbidity monitoring during construction. The Goderich Port Management Corporation acknowledged and corrected the inconsistencies, as well as revised the monitoring plan for turbidity. The proponent also indicated that a final monitoring plan would be included in the Environmental Management Plan, which will be completed during detailed design. The Ministry, as well as a member of the public brought up concerns regarding the methods used for the assessment of noise. The proponent originally stated in the EA that there are no vacant lots capable of development as some of these vacant lots are owned by Compass Minerals. The noise engineer noted that some of the vacant lots are also owned by the Town of Goderich. The noise engineer requested letters from Compass Minerals and the Town of Goderich committing to no development of sensitive noise receptors on the vacant lots. If this could not be completed, a zoning examination should be completed to determine if sensitive noise receptors are permitted on these vacant lots. The Goderich Port Management Corporation responded that the aerials used in the EA Report are outdated (2010) and that a restaurant is now located on these lots; therefore, no assessment of these lots is required. As stated in Section 3.1.2, the EA indicates that best management practices will be implemented to control dust and NOx emissions during construction, operation and maintenance. As such, the EA indicates that there will be no net effects to air quality during construction, operation and maintenance of the proposed undertaking. The Ministry’s air quality analyst requested further clarification on some of the calculations and concluding statements in the air quality assessment report. The Goderich Port Management Corporation has provided responses to the Ministry’s request for clarification; however, the Ministry has also requested the modeling and monitoring data to verify the conclusions in the air quality assessment. This information is pending from the proponent and will be reviewed prior to making a decision on the EA.


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3.2.2 Conclusion

Overall, the Ministry, in consultation with the GRT, public and Aboriginal communities, is satisfied that the proponent’s decision making process meets the requirements of the approved ToR and EAA. The Ministry is satisfied with the responses provided by the proponent to comments raised by the GRT, the public and Aboriginal communities, pending receiving information to clarify the air quality assessment from the proponent.

The EA contains a brief explanation of the opportunity that prompted the EA process, and presented an evaluation of a reasonable range of “alternative methods” of addressing the opportunity for the Goderich harbour wharf expansion in the Study Area. A qualitative evaluation of alternative wharf sites was completed, and subsequently the evaluation of alternative wharf designs using criteria and indicators that considered the broad definition of the environment was completed.

The EA includes a thorough description of the potentially affected environment in the EA Study Area, and identifies the elements of the environment that may be affected by the alternatives being evaluated as part of the EA planning process. The advantages and disadvantages for the alternative wharf designs were not provided in the EA and were requested from the proponent during the seven-week review period. Supplemental information provided by the proponent describing the advantages and disadvantages of the alternative wharf designs is provided in Appendix C.

The Ministry is therefore satisfied that the EA demonstrates, through a logical and transparent process, why the preferred alternative was selected; and that the EA was completed in accordance with the approved ToR and the requirements of the EAA. The Ministry is also satisfied that the Goderich Port Management Corporation has provided adequate responses and supplemental information to address the EA process concerns raised by the members of the public, GRT and Aboriginal communities during the preparation of the EA and the EA comment period.

3.3 Proposed Undertaking

As summarized in Section 2 of this Review, the proposed undertaking is the construction, operation and maintenance of the Goderich harbour wharf expansion in the Town of Goderich (Figure 1 of this Review). A detailed description of the proposed undertaking can be found in Section 5.0 of the EA.

The twin-slip alternative selected in the assessment of alternative methods will create an expanded wharf that will increase available storage space and provide additional loading/unloading spaces for ships. Located in the northern portion of


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the outer harbour, the twin-slip option allows for two additional docking spaces along the expanded wharf and a usable storage space of 6.3 hectares. The total lakebed footprint of the preferred design alternative is 7.69 hectares.

The proposed undertaking is clearly described in the Goderich Port Management Corporation’s EA documentation, and the undertaking was selected based on an evaluation of alternative wharf sites and designs, including a comparison of advantages and disadvantages (provided in Appendix C of this Review), and subsequently an assessment of potential effects on the environment due to the preferred undertaking. A broad definition of the environment was used in order to evaluate all potential effects.

3.3.1 Key Issues

A detailed summary of the comments received during the preparation of the EA, and how the issues raised were addressed, can be found in Section 2.0 of the EA. The comments received, and the Goderich Port Management Corporation’s responses to them, are also documented in a Record of Consultation provided with the EA. Key issues regarding the EA process completed by Goderich Port Management Corporation for the Goderich Harbour Wharf Expansion were gathered during the pre-submission consultation and the EA review comment period. A summary of the key issues raised during the seven-week comment period are described below, as well as the responses provided by the proponent. Comment submissions can be found in Appendix B. All comments, including Goderich Port Management Corporation’s responses and MOE’s level of satisfaction can be found in Tables 1 -3. During the preparation of the EA, DFO determined that the Goderich harbour wharf expansion will result in harm to fish habitat, and an authorization under Section 35(2) of the Fisheries Act will be required. As a result, the proponent has prepared a fish habitat compensation plan in consultation with the DFO, MVCA and interested Aboriginal communities as described in Section 3.1.2 of this Review. One of the main discussion points in the five meetings held with interested Aboriginal communities described in Section 3.1.2 of this Review was the fish habitat compensation plan. The interested Aboriginal communities were able to recommend projects for the creation and/or restoration of fish habitat. The fish habitat compensation plan contains the following projects:

• Wetland restoration on the Walpole Island First Nation; • Creation of a spawning reef near Fighting Island in the Detroit River; • Restoration of the Garvey/Glenn watershed; and • A stable isotope analysis to determine the structure of the aquatic food

web surrounding the new wharf.


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During detailed design, the proponent has committed to finalizing the fish habitat compensation plan in consultation with the DFO, MVCA, Walpole Island First Nation, Aamjiwnaang First Nation and Saugeen Ojibway Nation. No outstanding concerns were identified during the seven-week comment period on the Final EA. During the seven-week public comment period of the Final EA, a member of the public identified concerns related to public access at the harbour and potential impacts to recreational use of the harbour. The proponent responded that public access to the harbour is managed by the Town of Goderich. A plan is being developed by the Town of Goderich that allows public access to this industrial area, while maintaining public safety. The Goderich Port Management Corporation is preparing a formal response letter to the commenter based on the response provide in Table 2 of this Review.

3.3.2 Conclusion

The Ministry is satisfied that the information contained in the Goderich Port Management Corporation’s EA, as well as the responses to comments on the final EA supports the recommendations and conclusions for the selection of the proposed undertaking. The Ministry is also satisfied that environmental effects of the proposed undertaking have been clearly identified, and that these effects can be managed through the commitments made in the EA, through conditions of EA approval, or through additional work that must be carried out by the Goderich Port Management Corporation in support of future approval or permitting applications.


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4. Summary of the Ministry Review The purpose of this Ministry Review is to determine if the Goderich Port Management Corporation has prepared its EA for the Proposed Goderich Harbour Wharf Expansion in accordance with the approved ToR and the requirements under the EAA. This Review also concludes whether the evaluation in the EA is sufficient to allow the Minister to make a decision about the proposed undertaking. On the basis of this Review, the Ministry has concluded that:

• The EA has been prepared in accordance with the Goderich Port Management Corporation’s approved ToR and the requirements under subsection 6.1(3) of the EAA;

• The EA has identified and evaluated a reasonable range of alternatives to arrive at a preferred undertaking;

• The EA and supplemental information requested has identified and evaluated the potential environmental effects for the alternative methods to the undertaking and completed an assessment of the potential environmental effects of the proposed undertaking;

• The EA and supplemental information has provided a description of the proposed impact management measures and monitoring and contingency plan to address the potential negative environmental effects of the preferred undertaking;

• The EA contains sufficient impact management measures and monitoring and contingency measures to ensure that the potential negative environmental effects of the undertaking will be minimized;

• The Goderich Port Management Corporation has provided sufficient time and opportunities for interested members of the public, GRT and Aboriginal communities to participate and comment on the preparation of the EA and the undertaking for which approval is being sought;

• The EA clearly documents the consultation methods utilized to engage for interested members of the public, GRT and Aboriginal communities throughout the EA process;

• The consultation methods used during the EA process were carried out in accordance with commitments in the approved ToR and the requirements of the EAA;

• The EA identifies and clearly explains the issues and concerns that were raised during the preparation of the EA, and how they have been addressed; and

• The EA contains sufficient information to enable a decision to be made about the application to proceed with the undertaking.


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The Ministry is satisfied that the proposed undertaking, as described in the Goderich Port Management Corporation’s EA, will address the need for additional loading and unloading, an increase in storage capacity and will provide protection from wave action.

The Ministry is also satisfied, that should approval under the EAA be granted, the implementation and operation of the proposed undertaking will be completed in accordance with the terms and provisions outlined in the EA; any proposed conditions of approval; and, through additional work that must be carried out by the Goderich Port management Corporation in support of future approval and permitting applications.

During the final review period and prior to forwarding a recommendation to the Minister about this EA, conditions specific to consultation, commitments during project design, completion of the environmental management plan, finalization of the monitoring and contingency plan and finalization of the fish habitat compensation plan for the proposed undertaking may be proposed to ensure the environment remains protected.


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5. What Happens Now? The Review will be made available for a five-week comment period. During this time, all interested parties, including the public, the GRT and Aboriginal communities can submit comments to the Ministry about the proposed undertaking, the EA or the Ministry Review. At this time, anyone can request that the Minister refer either all or part of the EA to the Environmental Review Tribunal for a hearing if they believe that their concerns have not been addressed.

At the end of the Review comment period, Ministry staff will make a recommendation to the Minister concerning whether the EA has been prepared in accordance with the ToR and the requirements of the EAA and whether the proposed undertaking should be approved. When making a decision, the Minister will consider the purpose of the EAA, the ToR, the EA, the Review, the comments submitted during the EA and the Review comment periods and any other matters the Minister may consider relevant.

The Minister will make one of the following decisions:

• Give approval to proceed with the undertaking; • Give approval to proceed with the undertaking subject to conditions; or • Refuse to give approval to proceed with the undertaking.

Prior to making that decision, the Minister may also refer either part of or the entire EA to mediation or refer either part of or the entire EA to the Environmental Review Tribunal for a decision.

If the Minister approves, approves with conditions or refuses to give approval to the undertaking, the Lieutenant Governor in Council must concur with the decision.

5.1 Additional Approvals Required

If EAA approval is granted, the Goderich Port Management Corporation will still require other legislative approvals to design, construct and operate this undertaking. Section 7.0 of the EA outlines additional

If EAA approval is granted, the

proponent must still obtain any other

permits or approvals required to construct

and operate this undertaking.

Next Step in the EA Process

ToR Approval ↓

EA Preparation ↓

EA Submission ↓

EA Comment Period ↓

Ministry Review ↓

RReevviieeww CCoommmmeenntt PPeerriioodd

↓ Minister’s Decision


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approvals that may be required. These approvals may include:

• Goderich, Central Huron and Ashfield-Colborne-Wawanosh Official Plan amendments;

• Zoning by-law amendments; • Noise by-law exemption; • Fisheries Act; • Development, Interference with Wetlands, and Alterations to Shorelines

and Watercourses Regulation (Ontario Regulation 164/06); • Environmental Compliance Approval; • Section 53 of the Ontario Water Resources Act; • Navigable Waters Protection Act; • Scientific License Collection Permit; and • Site Plan Approval.

These approvals cannot be issued until approval under the EAA is granted.

5.2 Modifying or Amending the Proposed Undertaking

If the proponent needs to address changes to the undertaking if approval is granted, it should be noted that any major changes are themselves deemed to be undertakings for which EA approval will be required.

APPENDIX A

ENVIRONMENTAL ASSESSMENT ACT REQUIREMENTS

- 1 -

Appendix A: Environmental Assessment Act and Terms of Reference Requirements of the Environmental Assessment EA Decision Making

Process EAA and ToR Requirements

Description and Characteristics of the Requirements Analysis of the EA

Problem/Opportunities Identify an existing problem or opportunity

The Environmental Assessment (EA) should contain a brief explanation of the problem or opportunity that prompted the proposed activity.

• The EA indicates that the Port of Goderich is the only deepwater port on the east shore of Lake Huron. Servicing regional mining, manufacturing and agricultural industries, the Port is an important hub of commercial shipping in southwestern Ontario. On average 250 ships dock within the Port of Goderich annually, loading and delivering salt, grain and calcium chloride. In addition to these activities, the port is also used by fishing boats, and other users.

• The EA indicates that the wharf facilities are currently constrained by loading/unloading space. Storage space is also considered deficient for existing and future shipping operations. Sifto Canada Corporation, a major salt producer located in Goderich Harbour, completed an expansion to its operations that increased annual production capacity in 2012. Salt produced at the Goderich mine is shipped by freighter to approximately 35 ports along the Great Lakes, in both Canada and the U.S., from the Lakehead (Thunder Bay) to Quebec City.

• The EA indicates that Goderich Harbour is also exposed at times to adverse lake conditions as it is located on the windward side of Lake Huron. The opportunity exists as part of this project to provide better shelter within the harbour.

• The EA indicates that the purpose of the

Purpose of the Undertaking: s.6.1(2)(a)

If a specific undertaking has been identified provide a brief description.

- 2 -

EA Decision Making Process

EAA and ToR Requirements


undertaking is to address the need for additional loading/unloading space, the need for storage space for existing and future shipping operations and to better shelter the harbour from adverse lake conditions (Section 1.2.2 of the EA).

• The proponent clearly explained the opportunity that prompted the initiation of the EA process and the purpose of the proposed undertaking (Sections 1.2 and 1.3 of the EA).

Alternatives Description and Statement of the Rationale for the Alternatives to: Alternative to s.6.1(2)(b)(iii)

“Alternatives to” represent functionally different ways of addressing the problem or opportunity. A reasonable range of “alternatives to” should be identified and evaluated. The proponent should be able to justify that it has considered a reasonable range of alternatives. The “do nothing” alternative to should be included in the evaluation and will represent the “bench mark” situation.

• The EA was prepared pursuant to subsection 6.1(3) of the Environmental Assessment Act (EAA), which states that an EA may consist of information other than the generic requirements as outlined in subsection 6.1(2).

• The evaluation of “Alternatives To” was presented in the approved ToR. A summary of this evaluation is provided in Sections 4.1 of the EA.

• The EA provides a justification for focusing the EA based on the previous evaluation of “Alternatives To” provided in the approved ToR. Therefore, an evaluation of “Alternatives To” was not required for the EA.

• The ToR did include an evaluation of the “do nothing” alternative, which was assessed as part of the evaluation of “Alternative To”.

Description and Statement of the Rationale for the Alternatives methods: Alternative Methods s.6.1(2)(b)(ii)

“Alternative methods” include a description of different ways of implementing the preferred “alternative to” A reasonable range of “alternative methods” should be identified and outlined.

• The EA was focused on the selection and evaluation of a reasonable range of “Alternative Methods” or potential locations for the harbour wharf expansion, as well as the design of this expansion. The evaluation of “Alternative Methods” was completed in a two-step process. First, the evaluation of

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alternative wharf sites based on four potential locations was completed. Once the wharf site was selected, the evaluation of three wharf designs (no-slip, single slip and twin slip options) was completed (Section 4.0 of the EA).

• Section 4.0 of the EA provides an evaluation of the alternative methods. The EA describes how the criteria and indicators were used in the evaluation for identifying the preferred undertaking.

• The preferred wharf site was selected based on a qualitative evaluation of advantages and disadvantages of each of the four wharf site options.

• A quantitative evaluation of alternative wharf designs was then completed based on a number of natural, social, cultural and built criteria and indicators. Weights were assigned to the criteria and indicators to reflect their level of importance in decision making. The alternative wharf designs were then evaluated using Visual Interactive Sensitivity Analysis (VISA) multi-criteria analysis software. Based on this evaluation, the preferred alternative wharf design was selected; this being the twin-slip option.

• The EA clearly explains how the “Alternative Methods” were evaluated. The effects assessment was completed on the selected alternative method (Section 6.0 of the EA).

Evaluation Description of the Environment s.6.1(2)(c)(i)

Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural

• The EA Study Area remained unchanged from the approved ToR. The focus of the EA was on the primary study area, which was restricted to the inner and outer harbour areas

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conditions. The EA must provide a description of the existing environmental conditions in the study area. The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed undertaking and/or the alternatives.

identified for the expanded wharf facilities and North harbour Road. The secondary study area included the mouth of the Maitland River and the lower Maitland River valley adjacent to the harbour.

• The proponent carried out studies and research to compile an inventory of the existing natural, social-economic and cultural environments of the Study Area. The inventory was used to establish the baseline conditions for which the potential impacts of the alternatives being considered during the EA process were to be assessed (Section 3.0 of the EA).

• The EA identified the elements of the environment that may be reasonably expected to be affected by the proposed undertaking and the alternatives (Section 3.0 of the EA).

Description of Potential Environmental Effects s.6.1(2)(c)(ii)

Both positive and negative environmental effects should be discussed. The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project. Impact assessment methods and criteria used during the evaluation should be identified. The methods chosen must be clear, traceable and replicable so that interested parties can understand the

• The EA clearly identified the potential interactions between the project activities for the preferred undertaking and the environment. These interactions were further assessed by describing the potential effects. Only negative effects were assessed; however, benefits/advantages were identified in Section 6.5 of the EA. The EA identified the impact assessment methods, criteria and studies used to analyze potential environmental effects in Sections 3.0, 4.0 and 6.0. However, the EA was unclear as to how net effects were identified (Table 6-5 and 6-6 of the EA). The method for determining net effects was requested during the initial inspection of the EA. The proponent provided the method in a response received by the

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analysis and logic used throughout the EA.

Ministry. • The method included identifying proposed

impact management measures to minimize or avoid any potential negative environmental effects of the preferred undertaking being considered as part of the EA process (Section 6 and Tables 6-5 and 6-6of the EA).

• The EA identified the elements of the environment that may be reasonably expected to be affected by the proposed undertaking.

Description of the Actions Necessary to Prevent, Change, Mitigate or Remedy the Environmental Effects s.6.1(2)(c)(iii)

A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

• The potential environmental effects and impact management measures for the preferred undertaking have been described in the EA (Section 6.0 and Tables 6-5 and 6-6 of the EA).

• Commitments for future work (Section 7.0 of the EA) include additional studies, consultation, acquiring additional approvals, completion of the Environmental Management Plan and Consultation. A list of commitments during project design was requested during the initial inspection of the EA and provided by the proponent. Overall, the EA provides a description of the commitments to prevent, change, mitigate or remedy potential environmental effects.

Evaluation of Advantages and Disadvantages to the Environment s.6.1(2)(d)

The preferred alternative should be identified through this evaluation.

• The EA did not include, but upon the Ministry’s request during the initial inspection period of the EA, the proponent provided a summary of the relative advantages and disadvantages of the alternative wharf designs. Based on this, it was clear why the wharf site location and twin-slip design was selected.

• The proponent’s decision making is clear,

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traceable, and reproducible. The EA clearly demonstrated why the preferred alternative was selected over the others.

Description of Consultation with Interested Stakeholders s.6.1(2)(e)

A description of stakeholder consultation that occurred during the preparation of the EA needs be documented and should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received. The EA must identify any Aboriginal consultation efforts that have been made including methods for identifying potentially interested First Nations, who was consulted, when and how consultation occurred and any comments received from First Nations. The EA should include outline conflict resolution techniques to resolve issues used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

• The proponent carried out a comprehensive consultation program to ensure that interested members of the public, government agencies and Aboriginal communities had an opportunity to provide comment and input during the preparation of the EA (Section 2.0 of the EA).

• In accordance with the approved ToR, the proponent carried out the following consultation methods: • Establishing and maintaining a

stakeholder contact list; • Providing project related information and

updates throughout the EA process by way of a project web site, the publication of newsletters, written correspondence, and holding two Public Information Centres with open house format;

• Advertisements in the local newspaper providing notice of formal project milestones, and consultation events;

• Five meetings with interested Aboriginal communities were organized to present the project and status, identify lands of interest, discussion on traditional activities that may be affected, discuss impact management measures and the fish habitat compensation strategy;

• Other meetings in Aboriginal communities not included in the five meetings mentioned above regarding the status of

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the EA; • Establishing the Regulatory Agency

Advisory Group (RAAG) to obtain guidance on regulatory requirements and EA documents throughout the EA process;

• Maintaining a Record of Consultation documenting all issues or concerns that were raised during the preparation of the EA, and the responses to them;

• Government Agency meetings to discuss relevant issues and mandates;

• The circulation of draft supplemental technical documents to interested stakeholders, agencies and Aboriginal communities for review and comment; and

• The circulation of a draft EA to the Ministry of the Environment, Fisheries and Oceans Canada, Transport Canada, Maitland Valley Conservation Authority and Ministry of Natural Resources for review and comment.

• The EA identified Aboriginal consultation efforts including methods for identifying potentially interested Aboriginal communities, describing how consultation occurred, and included comments received from Aboriginal communities as part of the EA amendment (Sections 2.2.3.1 through 2.2.2.3.16 and Tables 2-4 and 2-5 of the EA).

• The proponent identified a reasonable range of Aboriginal communities based on input from both the Ministry of Aboriginal Affairs and Aboriginal Affairs and Northern Development Canada.

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• The EA clearly details how potential effects on Aboriginal communities were identified and how these effects were considered and/or addressed during the EA process.

Selection Process Proposed Undertaking

The description of the undertaking should specify what the proponent is seeking approval for under the EAA. The description should include information on the location, attributes, dimensions, emissions etc. The evaluation process should identify which is the preferred undertaking.

• The EA identifies the proposed undertaking as the construction, and operation and maintenance of the Port of Goderich harbour wharf expansion located on the east shore of Lake Huron in the Town of Goderich.

• Section 5.0 of the EA describes in detail the undertaking for which approval under the EAA is being sought.

• The proposed undertaking addresses the need for additional loading/unloading space, the need for storage space for existing and future shipping operations and to better shelter the harbour from adverse lake conditions (Section 1.2.2 of the EA).

• The evaluation to determine the preferred undertaking was completed in a two-step process. First, the evaluation of alternative wharf sites based on four potential locations was completed. Once the wharf site was selected, the evaluation of three wharf designs (no-slip, single slip and twin slip options) was completed (Section 4.0 of the EA).

• Section 4.0 of the EA provides an evaluation of the alternative methods. The EA describes how the criteria and indicators were used in the evaluation for identifying the preferred undertaking.

Description and Statement of the Rationale for the undertaking s.6.1(2)(b)(i)

Next Steps and Additional Commitments

Additional ToR Commitments

Outline any further commitments made by the proponent in the ToR or in the EA.

• Table 6-5 and 6-6 summarize the commitments for impact management measures.

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• Table 6-7 provides the draft monitoring and contingency plan with a commitment to include the final monitoring plan in the Environmental Management Plan to be completed at the project design phase.

• A list of commitments to be completed during project design were requested and provided to the Ministry during the initial inspection of the EA Report.

Additional Approvals Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

• Section 7.0 of the EA outlines the additional approvals that may be required. These approvals may include:

• Goderich, Central Huron and Ashfield-Colborne-Wawanosh Official Plan amendments;

• Zoning by-law amendments; • Noise by-law exemption; • Fisheries Act; • Development, Interference with Wetlands, and

Alterations to Shorelines and Watercourses Regulation (Ontario Regulation 164/06);

• Environmental Compliance Approval; • Section 53 of the Ontario Water Resources

Act; • Navigable Waters Protection Act; • Scientific License Collection Permit; and • Site Plan Approval. (The above list is not all inclusive and other approvals may be required as the project proceeds)

APPENDIX B

SUBMISSIONS RECEIVED DURING INITIAL COMMENT PERIOD

Ministry of the Environment

Environmental Approvals Branch

2 SL Clair Avenue West Floor 12A Toronto ON M4V 1 L5 Tel.: 416 314-8001 Fax: 416 314-8452

Aprll14,2014

MEMOBANDUM

Mlnlattra de I'Envlronnament

Dlrectlon des autortsatlons envtronnemenlales

2. avenue Sl. Clair Ouest etage 12A Toronto ON M4V 1L5 Tel : 416 314-8001 T~h~c. : 416 314-8452

TO: Ms. Connie Agnew Assistant Manager LGL Ltd.

FROM: Andrew Evers

r')h t ~ 1/r- Ontario

Project Officer, Environmental Approvals Branch Ministry of the Environment

RE: Provincial Review of the Environmental Assessment Report for the Proposed Goderlch Harbour Wharf Expansion

The Ministry of the Environmenrs (Ministry) Environmental Approvals Branch has completed its review of the Environmental Assessment Report for the Goderich Port Management Corporation's Proposed Goderich Harbour Wharf Expansion. The purpose of this review was to determine If the comments on the Draft Environmental Assessment (EA) outlined In the memorandum dated December 10, 2013 were addressed. In addition, this review was carried out to determine If the EA meets the requirements of the Ontario Environmental Assessment Act (EAA), the approved Terms of Reference (dated August 2010) and the expectations set out In the Ministry of the Environment's Code of Practice: Preparing and Reviewing Environmental Assessments in Ontario. The review also assessed the clarity and detail of the EA documentation in order to ensure that the Minister of the Environment has sufficient Information when making a decision to approve or not approve the proposed undertaking.

Comments According to Section of the EA

Section 1 .0: Introduction and Background

Under Section 1 .3.1.2 of the EA, it states that the EA contains information In accordance with s. 6.1 (2) of the Environmental Assessment Act (EAA). Section 2.0 of the approved ToR states that the EA will be completed In accordance with s. 6.1 (3) of the EAA. Please confirm in accordance with which section of the EAA the EA is being completed, and if it Is different from what is stated in the approved ToR, please provide justification for this change.

Section 2.0: Consultation and Engagement

In Section 8.2.5 of the approved ToR and Table 2-1 of the EA mention that the Study Team may elect to hold a fourth Public Information Centre (PIC). In Table 2-1 ofthe EA, it is mentioned

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that the Study Team elected not to hold the fourth PIC. Please provide justification for not holding the fourth PIC.

In Table 2-4 It is noted that Saugeen Ojibway Nation (SON) stated in a meeting held on September 6, 2012 that the proponent would need to demonstrate benefits to the local Aboriginal community. The Study Team's response only notes funding and review of the technical documents, as well as a Memorandum of Understanding for the completion of an isotope analysis as part of the fish habitat compensation plan. Please explain what the benefits are to Aboriginal communities and where this explanation or assessment can be found In the EA Report.

In Sadlon 2.2.3.1 It mentions that the Study Team attended two Community Information Sessions on February 20 and 21, 2014 with Saugeen First Nation and Nawash First Nation, respectively. Please provide details of this meeting Including the materials distributed, comments/concerns from these Aboriginal communities and how they were addressed and if there are any outstanding concerns.

Section 2.3 of the EA notes that a workshop was held on August 29, 2012 with Flsheries and Oceans Canada (DFO), Ministry of Natural Resources (MNR}, Maitland Valley Conservation Authority and Town of Goderich staff to discuss strategies for the loss of fish habitat due to the wharf expansion. Please confirm if Aboriginal communities were Invited to this workshop or Informed of the content presented at this workshop, and If not, please justify. In addition, please note where In the Record of Consultation (RoC), meeting minutes, materials and correspondence can be found regarding the workshop.

In the memorandum dated December 10, 2013 from the Ministry providing comments on the Draft EA, it was requested that 2.3.1 provide a summary of next steps in consultation, Including consultation with Aboriginal communities. Currently It Is still unclear what the next steps will be In consulting with Aboriginal communities during projed design and In finalizing the fish habitat compensation plan, as well as any other outstanding concerns. Please provide the plan of next steps for consultation (i.e., PIC during project design as mentioned in Sadlon 7.0).

Please confirm that representatives from the Ministry's Drinking Water Inspection Program were added to the stakeholder list as mentioned In Section 5.3.1 of the approved ToR.

Section 3.0: Summarv of the Existing Environment

Section 5.1 of the approved ToR provides a brief explanation of the primary and secondary study areas. The overall study area Is not described in Section 3.0 of the EA so It Is unclear if the study areas changed in the EA from those described in the approved ToR. Some of the environmental component study areas are described for each discipline in Section 3.0; however, In some cases no study area is presented (i.e., bedrock geology, noise). According to Section 4.2.3 of the Code of Practice: Preparing and Reviewing Environmental Assessments in Ontario (CoP), the boundaries of the overall study area, study area for the alternatives and study areas for the environmental components must be clearly described. Please provide descriptions of the overall study area, the evaluation of alternatives and the study areas for those environmental components not provided in Section 3.0 of the EA. If the overall study area is different from the one described In the approved ToR, please note these differences. Currently,

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it Is unclear if the description of the existing environment and the effects assessment have been completed within the boundaries of all of the defmed environmental component study areas. In addition, please provide a figure of the overall study area.

Please Indicate which sources were used to complete the secondary source Investigation on Physiography In Section 3.1.1 .

Section 4.0: Identification of Alternatives and Evaluation Process

Consultation on the alternative designs, method for evaluation and preferred design was completed during PIC #3, as Indicated In Appendix H of the RoC. Please note if any comments were received specifically on the alternative designs and evaluation method, and If any modifications to the methods evaluation were Implemented based on these comments (I.e., welghtlngs}.

Section 4.2.1 Identifies that the uorange" and •red" sites were carried forward as the preferred locations for the wharf expansion. These designs were then presented at PIC #2 for discussion. Section 4 does not Indicate how the decision was made to select the red site over the orange site for the wharf expansion. Was it based solely on the results of PIC #2?

In Section 6.1.2 of the approved ToR, It mentions that criteria and Indicators will be developed to compare alternative methods with respect to:

• Potential environmental effects; • Impact management measures; • Net effects; and • Advantages and disadvantages of the alternative method.

In Section 4.2.2 of the EA, Step 2, It notes that the original criteria were selected entirely based on environmental considerations, not on technical and cost considerations. Please explain how Impact management measures, net effects and advantages and disadvantages were considered In selecting the criteria and Indicators and subsequently used to compare the alternative methods for wharf sites and designs. If the alternative method evaluation was altered from what Is provided In Section 6.1 .2 of the approved ToR, please provide rationale for the change.

Section 6.1.2 of the approved ToR mentions that a sensitiVIty analysis would be completed on the results of the evaluation methods. The results of this sensitivity analysis do not seem to be presented In Section 4.0 of the EA. Please comment on how the criteria weights Influenced overall decision making and the selection of the preferred wharf design.

Table 4-4 In the EA provides the information used to complete the evaluation of alternatiVe methods for wharf designs. Table 4·5 provides the weights and rationale for the criteria and indicators used to evaluate the alternative wharf designs. From here It is unclear how the results were determined In Figure 4-5. Please provide a table that shows what each wharf design scored according to each Indicator that summed to the results provided in Figure 4-5 (i.e., what was the score for each indicator to sum to 67 for the twin slip option}.

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Section 4.2.4: Assessment and Evaluation in the CoP Indicates that the proponent must determine and clearly articulate the rationale for choosing the preferred alternative, taking Into account relative advantages and disadvantages. In Section 4.2.2 a list of advantages for the twin slip option Is provided and advantages and disadvantages of the preferred undertaking are provided In Section 6.5.5. Although advantages and disadvantages of the undertaking are provided for the preferred undertaking, these are not explained relative to the other alternative methods {i.e., no slip and single slip alternatives). Please provide a summary of the advantages and disadvantages for each of the alternative methods of wharf sites and wharf designs evaluated In Section 4.0.

In Section 4.2 of the approved ToR, It mentions that alternative methods also consider construction methods. Although no formal alternative methods evaluation was completed on construction methods, an Informal evaluation was described In Section 5.1.3 of the EA. Please confirm that when considering the construction methods to be used for the wharf expansion, environmental effects, impact management measures, net effects and advantages and disadvantages will be considered in choosing the preferred construction method, and described the evaluation method that will be used for selecting the preferred construction methods. In addition, please confirm that the construction methods being' considered, and subsequently the preferred construction method Is consulted on during a PIC at the project design phase, as Indicated in Section 7.3 of the EA.

Section 5.0: Proiect Descdotlon

Please provide a sequential schedule of construction activities to be completed within the construction schedule of 26 months provided in Section 5.1.4. Will any of these construction activities be weather/seasonally dependent? If so, please explain.

Section 5.1.5: Operation and Maintenance provides a description of operation activities to be completed. However, maintenance activities are not described until Section 5.1.7: Decommissioning. Please clarify why maintenance activities were described under the decommissioning phase, and also provide a description of the activities that would be required to decommission the wharf since only maintenance activities are listed. A list of maintenance activities are provided in Table 5-2. Please provide a brief explanation as to what these maintenance activities would Involve. Also, please confirm that all maintenance activities provided In Table 5-2 have been assessed according to the activities listed under operation and maintenance in Table 6-1.

Section 6.0: Impact Management. Mitigation and Monitoring

In Section 8.2.3 of the approved ToR, it mentions that the following issues will be discussed with Aboriginal and Metis communities during the EA phase:

• Identification of lands with First Nations and Metis interest In the study area; • Identification of land use/activities by First Nations and Metis communities within the

study area; • Potential Impacts of the study on land used for traditional activities within the study area:

and

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• Proposed mitigation/compensation of Impacts to land used for traditional activities within the study area.

Although extensive consultation with Aboriginal communities is presented In Section 2.0 of the EA, please confirm if Aboriginal interests, traditional activities or concerns raised In the meetings with Aboriginal communities were considered In Section 6.0, specifically In Sections 6.3.10, 6.3.11, 6.3.12 and 6.3.13 of the EA for the assessment of effects on the Socio-economic environment. If not, please provide justification for the omission.

In Section 6.3.3.2 it mentions that transportation of fill material by truck represents a "worse case" scenario over transportation by ships. How was this determined and please justify this statement. Also, transportation by ship Is the only Impact management measure mentioned for import of fill material in Section 6.3.3.2. If trucks need to be used, what Impact management measures would be Implemented?

Please clarify for consistency that Table 6-7 should include monitoring at homes if blasting Is Implemented as mentioned In Section 6.3.4.1.

Were traffic collisions with wildlife considered for the Import of fill material in Section 6.3. 7? Please justify why collisions with wildlife were not considered an impact.

In Section 6.3.9.1 it mentions that the fish habitat compensation strategy will Identify 62 ha of new and/or restored fish habital Only 6.0 ha of new and/or restored fish habitat Is mentioned In the Executive Summary and In Section 6.6.2. Please confirm the amount of new and/or restored fish habitat mentioned In the strategy.

Throughout the EA it Is mentioned that a fish habitat compensation strategy has been drafted and submitted to the DFO for review. What Is the status of this review and when Is it expected that the strategy will be finalized?

In Section 6.4.6.1 It Is mentioned that stormwater management wm be monitored on a regular basis for the life of the facility. In Table 6-7ft mentions that the stomwater management system will be monitored twice per year or after a spill for five years post construction. Please clarify, for consistency, the monitoring program for the stormwater management system.

In Section 6.4.11.1 it mentions that no permanent lighting will be erected at the facility. However, new down directional lighting focused on the pier deck will be Installed. If this lighting is not permanent, how long will it be in place for?

Section 6.4.16.1 mentions that traffic monitoring will be Implemented annually to determine If advanced warning systems are required. Table 6-7 indicates that traffic monitoring will be completed as required. Please clarify, for consistency, how often the traffic systems will be monitored, and If it is needed on an as required basis, please clarify what will determine when traffic monitoring Is required.

Table 6-5 provides a summary of the environmental components, the potential impacts, mitigation measures and the net effects. It is unclear how the net effect was determined based on the assessment completed in Section 6.0 because net effects are not mentioned until Tables

0

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6-5 and 6-6 of the EA. Please clarify how net effects were determined (I.e., effect following the implementation of Impact management measures).

Table 6-7 outlines monitoring to be Implemented during the pre-construction phase. The preconstruction phase Is not mentioned throughout the rest of the report. Please provide an explanation of the activities to be completed during pre-construction.

Please confirm who will receive each monitoring report for review. Will it be the agencies that are listed to be consulted for each monitoring component?

Please confirm that the draft monitoring plan provided in Table 6-7 for fish and fish habitat will be updated based on the finalization of the fish habitat compensation strategy. In addition, Is It anticipated that the restored areas (Section 7.2.3.1) will be monitored for the success of establishment?

In the memorandum dated December 10, 2013 from the Ministry providing comments on the Draft EA It was requested that more detail be provided regarding timing and season of sampling for each component Although more detail has been provided regarding frequency of monitoring, are any of the sampling programs seasonally, time of day, peak level dependent?

Monitoring for snow removal is mentioned In Section 6.4.6.2; however, there is no mention of snow removal monitoring In Table 6-7. Please confirm for consistency that snow removal monitoring will be Included In the final monitoring plan and provide a summary of what the monitoring plan for snow removal will include.

Section 7.0: Commitments to Future Work

In Section 7.3 of the EA it Is mentioned that a PIC will be offered during the project detail design phase. Please summarize who wtll be Invited to attend and what will be presented at this PIC, Including but not limited to the conditions on EA approval, final project design, procurement of the contractor, construction methods and evaluation of construction methods, and the final Environmental Management Plan. Please confirm that a PIC summary will be provided to the Ministry similar to those provided In the RoC Appendices. Also confirm the sections that will be Included In the PIC Summary.

Section 4.3.5 of the CoP explains that the EA must provide a plan that sets out how and when all commitments, Including impact management measures, will be fulfilled and how the proponent will report to the Ministry. Although Table 6-7 in the EA presents a comprehensive monitoring plan, and Section 7.0 provides a summary of additional approvals required following approval of the EA, a number of commitments to be Implemented during project design were mentioned throughout the EA. Please provide a comprehensive list of commitments to be implemented during project design.

Conclusion

In addition to the comments provided above, please find attached to this memorandum comments from the Ministry's technical reviewers. Please provide your responses to comments on the EA back to the undersigned In a comment disposition table indicating how each comment

..

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' Is addressed. The Environmental Approvals Branch will review the comment disposition tables to determine If they are satisfied with the responses. It would be appreciated if responses to comments could be provided by April 23, 2014 In order to facilitate the completion of the Ministry Review.

In closing, I would like to extend an Invitation within a few days of receiving the Ministry's comments to the Goderlch Port Management Corporation and LGL Consulting Limited to have a teleconference with Ministry of the Environment staff to discuss the Ministry's comments with the EA and the next steps In the EA process.

Should you have any further questions or concerns, please feel free to contact the undersigned, at (416) 314-7213 or by e-mail at [email protected].

Yours sincerely,

Andrew Evers Project Officer Environmental Approvals Branch Ministry of the Environment

Attachments:

Noise Comments - Goderich Harbour Wharf Expansion EA Wastewater Comments - God erich Harbour Wharf Expansion EA Surface Water Comments - Goderich Harbour Wharf Expansion EA

,,

Ministry af the EnvlroMiant

Enviranmental Approvals Branch

2 SL Cia r Avenue West Floor 12A Toronto ON M4V 1l5 Tel.: 418 314-6001 Fu: 418 ::114-8452

April 8, 2014

TO: Andrew Evers Project Officer

Mlnllltllra da I'Envlronnement

Olrectlan des autarlaallons tmVJromemenlales

2. llver'IUB St. Clair Ouest Ela1Je12A Taranto ON M4V 1L5 r61.: 418 :J14-BD01 T~6c.: 418 314-8452

Environmcnud Approvals Branch

FROM: Pierre J.R. Godbout Senior Noise Engineer Environmental Approvuts Branch

RE: Noise Review Comments Goderich Wharf E.'Cponsion EA FILE No.: 03·10 Noise EA Filu No.: E-00 13·13

f' ,.

t?ontario

This office W11S requested to review the revised report entitled "Noise Impact Assessment. Proposed Goderich WhorfE.,pnnslon, Town ofGoderich" prepared by J.E. Coulter Associates Limited, dated February 13,2014 ond signed by Snm Kulendrun, us well us the "Record of Consultation'' prepared on beholfofthe Goderich Port Monugement Corpomtlon. doted February 2014 and signed by Constnncc J. A~:~ncw and Mntthew J. Pcurson, which nddrcsses the MOE's "Noise Review Comments'' .dated September 13.2013 and signed by Pierre J.R. Godbout.

The above noted Noise Impact A!asessment and Record of Consultation support 11 proposed whurf expansion in the Town ofGoderich. Ontario. Currently, the wharf is shored by a salt mine (Sifto Cnnodo) and 11 grain stomge ond shipping facility (Goderich Elevators).

The report includes noise predictions due to the operation of the wharf expansion, which include new noise sources such as: 11) idling ships; b) frontend loaders; c) ship unlouding/londing; d) mil activity; e) conveyor systems; t) diesel generators; g) snit loaders; und h) on~site truck tmffic. Daytime and nighttime sound levels were predicted for the wharf expansion into two opcmtionnl scenarios: I) Salt Stomge; ond 2) Aggregate Storage. The noise predictions were conducted at 11

totnl of four representative receptors selected near the God erich Wharf. The stationary source noise predictions for dny and night opemtions were identical and in the runge of 45 to 54 dBA, thus exceeding the noise limits at most n:ceptors. The rcpon nlsu includes o noise impact unulysis ofthe expanded trucking activities on Nonh Unrbour Rood, indicating sound level increnses of up to 14 dBA at the most impacted receptor, and presents seveml options of conceptuul sound barrier configurntions as 11 rnenns of noise control.

rhe following ore our noise review comments on the nbove noted rev bed Noise lmpnct Assessment and Record of Consultation: (pll111gruph numbering as pet the Record of Consultation)

.4. Sltllinnmy Nuise A.Y.re.Y.~menl

( ll Vacant Lots I Additional Receplors: the Record of Consultation indicates thnt .. There ore no vncunt Jots capable of future development ns Compnss Minerals owns some of the vacant land surrounding the site'._ However the revised Noise Impact Assessment includes an ownership map in Appendix E that indicates the presence ot'vacnn& lands owned by ··Goderich Town." Confinnation letters should be provided by Compass Minernls and the Town ofGodL'Tich indicating that no noise-sensitive development is intended on these vocont lands. The letters should also clnrify which lands nrc owned by Compass Minerals and which lands are awned by the Town ofGoderich; consequently the above-mentioned Appendix E ownership map should be updated to illustrate these clarifications. Falling canflrmotion thnt development is not Intended for these lands. un examination of the zoning by-law should be performed to determine if noise-sensitive uses ure permitted on these vacant lands. The zoning mops in Appendix E should also be updated to show the points of reception (including any future points of reception, If opplicoble),

(4) Operations of Sino Canada nnd Goderich Elevators: 11 wharf ownership mop wos provided In Appendix E of the revised Noise Impact Assessment. TI1e Record of Consultation funher Indicates that ·•since the owners for nearby industrinl sources ore different than the proponent of the whnrfe:<pnnsian. the noise from the existing facilities cnn constitute the background sound level," This is consistent with the MOE nppronch ond ullows for the use orthe higher SO dBA evening/night noise limit at Receptor I, provided that these existing facilities ore nat under consideration for noise abatement by the Munlclpulity or the Ministry ot'the Environment. Confirmation to that effect should be provided.

(6) ~oise Source Data: for the stationary noise nsscssment, on-site truck volumes nre nat included (i.e. number of trucks used for the "Truck Departure" and ·•Truck Arrival .. source listed in Appendix B). Moreover. nlthough specific equipment dotn may not yet be ovailnble, swnple equipment doto from similar projet:ts. mnnuthcturer dotn or noise textbook literature should be used.

(7) Sound Level Calculations: one sample suund level calculntion should be provided tor the worst case (i.e. the closest nnd most exposed) point of reception. The assumed locution of all noise sources should be clearly indicated, as it is unclear rram the current mup provided in AppcndilC B if the sources are Jocutcd on the proposed whnrf expansion under study or on Slfto Canada Inc. lands shown on the ownership mnp of Appendix E.

(8) Noise Control Measures: n figure should be provided to :ihow the locution of the conceptual 400 rnetre<i-long, 6 metres-high sound bniTicr recommended in Tobie 4. "Expanded Wharf Mitigation Options".

B. Trttn.worlalinn N11ise .As.~e.s.~menl

( 12) Noise Control Measures: puge 16 of the Noise Impact Assessment states thot ·•the minimum surface density of the noise control measures should be 20 Jbs./sq.ft. or 4

2

kglsq.m··. All recommended noise bonicrs should have a minimum surface density of 20 kg/ml (-t lb/fil). As per Section 9.0 of the Noise lmpnct Assessment, it is understood that noise mitigntlon for the dwellings located on the north side of North Harbour Rood Is feasible and has been recommended, while noise mitigntion for the dwellings located south is not practicnl due to tcchnicnllimitntlons and therefore not recommended. Section 9.0 also stntes that "'A more detailed review ofthc recommended noise control measures should be completed during the Detail Design phnse of the project.''

In summllt'Y, bnsed on the submitted infonnotion, the report has derived the nppllcnble sound level limits 115 per Ministry Publication NPC-2059 and the predicted noise emissions from the proposed stationary sources Indicate that this project Is fenslble with regards to MOE noise ~uidelincs. A detailed Acoustic Assessment Report (AAR) should be provided when the upplication for an Environmental Campllance Approval is submitted to the Ministry. The AAR should address the above noted Statlmwry Nni:re A.r.fossment comments and should also n:commend the necessary noise control measures to ensure thnt the sound levels will be in complinnce with the upplicnble sound level limits, in accordance with Ministry Publicntion NPC-300.

We trust the above noise review comments would be of assistance to you.

1 f you ltuve nny questions. plt:nse contact PI em: Godbout, P .Eng., MBA at 416·212-4205.

Pierre J.R. Godbout, P.Eng., MBA Senior Noise Engineer

Jan Greason. P.Eng. Director uppointed for the purpo!!es af Pnrt 11.1 l,)f the Em•irmtmental Pmtec:tlon .-let

3


Sauthwestem Region

Mtnlst6ra dai'Envlrannamant

Direction Rl!gianale de Sud-Ouest 733, rue Exeter 733 Exeter Road

London ON NBE 1L3 Landon ON N6E 1l3 Tel.: 519 873-5000 Tt!l.: 519 873-5000 Fax: 519 873-5020 T611!1c.: 519 873·5020

April 23, 2014

MEMORANDUM

To:

From:

Andrew Evers Project Officer, EAS

Gerald Diamond, Ph.D. Air Quality Analyst

f'~ t :> r Ontario

Re: Goderich Harbour Wharf Expansion - Air Quality Assessment

Throughout the document, the author makes frequent use of terms such as "assumed", "will likely", and "expected". This undermines its credibility. A study such as this must be based upon measurements, reported data, or other verifiable sources.

Page35 As in the TOC the author gives a photograph of the area where the sampler is place but does not indicate its location.

The report does not include the monitoring data. The report cannot be accepted without access to this data. In addition, there is no mention of the instrument's servicing procedures and schedules, nor discussion of who operated it. This information must be supplied.

On page 38, the pollution roses are labelled, in part, with the following notation: Calm: 0,2 [ J.tgfma]

What does this mean?

The data suggests that particulate levels fell over the course of the monitoring session despite the fact that late summer and early fall are usually drier than the spring months. Does the proponent have an explanation for this?

On page 44, the author says that "Performing a log transformation on the data would show the data fitting a normal distribution curve." But instead the data is shown untransformed. Why? How good is the fit when the data is transformed and what statistics are derived from it?

On page 45, the author says "It has been stated that the South pier terminal handles 250,000 tonnes grain [sic] per year ... ". What is the source of this quote? Upon what data is it based?

In section 4.2.1.2 the author discusses the effect of fleet aging on emissions. However, this discussion is limited to the effect of replacing older vehicles with newer ones which were

produced to meet stricter standards. It does not discuss emission degradation for those vehicles still in service and so presents an unrealistic estimate. As well, this section does not discuss how fleet composition is determined.

The document notes that the on-site equipment "conforms to" certain standards but it is unclear from the .text if this was at purchase or each is regularly recertified.

The same concerns hold true for PAH in the next section.

On page 65 the author makes this remark: "The marine simulation suggests that tugs would only be required when the winds are in excess of 15 knots or above 7·7 mfsec. At this wind speed dispersion would be significant and the effect of the addition of the tug's emissions to those of the vessel would be minimal so they have not been included in the evaluation." However, they offer no values or estimates. This is not acceptable.

On page 73 the author notes that the selection of 15 rail cars hauled out of the harbour every day varies and so "no attempt was made to model this activity". This is unacceptable. In any case with significant variability it is the proponent's responsibility to use the most conservative estimate (worst case) in a model such as this.

On page 74, the author says "It has been assumed that it takes 15 minutes for the locomotive to get to the sidings ... " Can 'this not be checked?

On page 81, the author says "diesel engines emit contaminants at a rate related to the amount of power being generated by the engine at any given time". This is not always true. In particular, during idling the engine will cool. If the vehicle then moves a short distance and stops again, the engines will not have time to warm to optimal operating conditions and combustion will be incomplete. Other non-optimal situations may also occur. As well, even in ideal conditions, the engine must be properly maintained or emissions will be higher than expected. Did the author ascertain that this is the case?

The document then follows with a discussion of acceleration versus emission. However since the power needed to accelerate on a grade will differ from that on a level surface, and since the trucks must deal with a significant grade, is this simplification warranted?

On page 89, the author makes this statement. "It is presumed that trucks spend no longer than 6o minutes in the harbor area thus each truck leaving has a matching entry emission pattern in the same hour". In fact if the stay is approximately 60 minutes, the two trips would rarely occur in the same hour.

On page 101 the author says ''It is assumed that these operation would result in only limed organ carbon in the emissions. It was assumed that to% of the particulate matter emissions were organic carbon." Is there any support for this statement? Is it based upon measurements or published data?

On the following page the author estimates that units will operate at 75%. Why?

On page 103 the author "estimates" that VOC emissions account for 0.002% to 0.0002% of the mass of the asphalt mix and then uses the smallest value to estimate emissions. This

does not conform to standard practice which requires proponent to present worst case values.

On page 118, the author states that to account for low temperatures and precipitation in April and May they would reduce the loader emission factor by 75%. Where did this number come from? Do they have any support for this value or the validity of their approach?

On page 119 (and elsewhere) the text contains the expression "Error! Reference source not found." The report should be repaired where these notations exist. Is a reference available?

On page 128, the author says that since there are two places where grain loading could occur, the calculations were performed assuming that the loading would take place at the more westerly spot. This is not the more conservative assumption, rather it would seem to lessen the apparent impact of any particulate emissions. As such, this is unacceptable.

The first plot in the results shows values for 99·5 percentile. It is unclear why the graph does not reflect maxima. AAQC are normally compared to maxima or averages to evaluate ground level concentrations.

Also missing from their discussion is any evaluation of annual concentrations.

The discussion of PM:~.5 reflects only the current Canada Wide Standard for fine particulate. However, as of 2015, a new Canadian Ambient Air Quality Standard will be in place which encompasses a lower benchmark of 28 J.1g/m3 as well as an annual average of 10 J.lg/m3. Both of these figures will be reduced again in 2020. Information may be found at the following website.

On page 151, the author suggests that the background concentration can be characterised by the goth percentile concentration. This is not true. To use this number to give an indication of exposure, one would also have to specify a concentration distribution, and have a sense of its accuracy and year to year variability. They offer neither. They acknowledge that their data does not span an entire year, nor does it agree correspond to data from other stations which they wished to use as characterising the local conditions. They then again speak of maxima but only give the 99.5% data.

Section 6.g.1.4 is labelled "Future Operations Scenario". It describes the results if"3 million tonnes of bulk materials are transported from the dock are by truck" - presumably per year. Does this cover all material including salt, grain, and whatever else may be transshipped? A summary table of the various scenarios and results would have help clarify this question and the discussion in general.

Section 6.4 discusses B[a]P modelling and notes that due to the irregular and infrequent emissions the annual value becomes "too small to register in the model output". Since modelling may be done using larger values and the results scaled, I do not find this convincing. However, even if this were true, the ministry also has a 24-hour AAQC that

could be used as a comparison for worst-case daily emissions. Some effort should have he made here.

The report includes none of the modelling input, output, meteorology, etc. Thus it is not possible to verify any of the modelling results. While the author notes that all the modelling was done with AERMOD, no mention is made of the version number or which, if any, of the options were used for modelling.

Gerald Diamond

cc. A. Homewood

Evers, Andrew (ENE)

From: Sent: To: Subject:

FYI

From: Smith, Ryan {ENE) Sent: Aprtl3, 201412:48 PM To: Whitmore, Michelle {ENE)

Whitmore, Michelle (ENE) April 3, 2014 12:54 PM Evers, Andrew (ENE) FW: Goderich Harbour Wharf Expansion EA

Cc: Abernethy, Scott (ENE); Ho, Jason (ENE); Dobrin, Dan (ENE); Sealey, Bob (ENE) Subject: RE: Godertch Harbour Wharf Expansion EA

· Hello Michelle:

For Surface Water Concerns, I've reviewed the Individual Environmental Assessment Report dated February 2014.

As I mentioned In the past, overall, based on the proposed expansion It does not appear that there will be many surface water concerns.

However, I note that my previous comments haven't necessarily been Incorporated Into the revised document. My main points of concern continue to be that monitoring for turbidity are followed.

In my previous email, I noted that during the Construction Phase, any turbidity monitoring should be conducted In accordance with the CCME guideline.

The most recent iteration of this document still states that the turbidity levels In Lake Huron shall be kept within the specifications of the Provincial Water Quality Objectives (PWQO). As before, I suggest that the PWQO's should be used as a general guidance of background Turbidity levels In the lake, but for specific works, the CCME guidelines would apply. These guidelines have already been supplied In my previous correspondence.

Further, the proposed monitoring frequency found in Table 6-7 under "Construction Phase- Water Quality In Lake Huron" Is inadequate. Only sampling the Turbidity one time per month during the construction phase will not ensure environmental protection. While they are working In-water, a more rigorous sampling program should be undertaken which the proponent should propose.

Otherwise, I have no further concerns with the report at this time.

Ryan.

Ryan Smith Work: (519) 873-5038 [email protected]

.,J:;. Please consider the environment before printlng this emall.

1

From; Ho, Jason (ENE) Sent: February 26, 2014 3:14 PM To: Abernethy, Scott (ENE) Cc: Smith, Ryan {ENE); Dobrin, Dan (ENE); Sealey, Bob (ENE) Subject: Goderfch Harbour Wharf Expansion EA

Hello,

This email is In regards to the Goderlch Harbour Wharf Expansion Environmental Assessment (EA file NO. EA 02-08-10).

The environmental assessment has been submitted by Goderlch Port Management Corporation (GPMC) on behalf of the Town of Goderlch to the Minister of the Environment for review. The EA will be delivered to GRT members for review and comments which are due Aprll4, 2014. The purpose of the Review Is to evaluate the EA with respect to the requirements of the EAA. If the contact for this project has changed, and this request should be directed to someone else, please let me know as soon as possible.

The purpose of this EA Is to provide additional loading/unloading space for ships, provide additional storage space for salt as well as other commodities, and provide wind and wave protection to the Inner harbour. The EA can also be viewed online at: http://www.goderichport.ca/Wharf Excanslon/index.php. Please see the attached memo for more details regarding this project.

Also attached in this email is an Acknowledgment of Receipt Form, if this form could be filled out and returned to Michelle Whitmore, that would be greatly appreciated.

Should you have any questions, please contact Ms. Michelle Whitmore at 416-314-7225 or by e-mail at [email protected].

Thank you,

.Jason Ho :\iinisll:}· of Euvironm(•nt Environmcntnl Assessments & Approvals lknnrh ~St. Clair An•nnc Wt·st Toronto, Ontario :\!.tV ti..; 't•lt'phunt•: 416·3'1l-:J:J5!.! I Email: ,[email protected]

2


Environmental Assessment and Approvals Branch

2 St. Clair Avenue West Floor 12A Toronto, ON M4V 1 L5 Tel.: 416 314-8298 Fax: 4t6 314·8452

April3, 2014

MEMORANDUM

TO: Andrew Evers Project Officer

Mlnlstere dei'Envlronnement

Direction des Avaluallons et des autorlsatlons envtronnementales

2. avenue St. Clair Ouest Etage 12A Toronto, ON M4V 1 L5 T61.: 416 314-8298 T616c. :416314-8452

Environmental Assessment Services Section Environmental Approvals Branch

FROM: Stefnnos Habtom Senior Wastewater Engineer Environmental Approval Services Section Environmental Approvals Branch

f')h:

t -:> r Ontario

RE: Goderich Port Whnrf Expansion Environmental Assessment EA FILE NO. 02-08-10

Pursuant to your memorandum of February 14, 20 14, I have completed my review of the Goderich Port WhnrfExpnnsion Environmental Assessment dated February 2014 submitted by Goderich Port Management Corporation and I provide the following comments for your considemtion:

1. The outline provided for the design nnd operation of the storm water management servicing the expanded Goderich Port Wharf is acceptable with respect to the mandate of the Wastewater Unit, EAB, under the Omario Water Resources Act (OWRA). As indicated in the report, the proposed stormwater management facility requires an approval under Section 53 OWRA and the proponent needs to submit a completed application and a design brie( for the proposed stormwater management facility.

If you require any additional information, please do not hesitate to contact me at (416) 314 8298.

Yours sincerely,

Stefanos Habtom, P. Eng.

c: Edgar Tovilla, Supervisor (A), Environmental Approvals Services Section, EAB

Evers. Andrew (ENE)

From: Sent: To: Cc Subject:

Andrew,

Gass, Scott (ENE) April 9, 2014 10:08 AM Ho, Jason (ENE) Evers, Andrew (ENE) RE: Goderich Harbour Expansion EA • Comment Period Ending

I have briefly reviewed the Information relating to the Goderich Harbour Wharf Expansion Environmental Assessment (EA file NO. EA 02·08-10). The District does not have any comments to provide at this time.

Sincerely,

Scotty Gass Sr. Environmental Officer Ministry of the Environment Owen Sound District omce 1Dl-17th Street East Owen Sound, Ontario N4KOA5

Tel: 519.371.4409 Fax: 519.371.2905 [email protected]

NOTE: This message is callfidential and may privileged and exempt from disclosure under applicable law. If you are nat the intended recipient or an agent of that buUridual or organization, any use, copying, or distrihutfan of this message by you is strictly prohibited. U you received this communication in error, please contact me hy return e-mail and delete this message. Thank you.

NOTE: Ce cauniel est destine exclusivement au(x) destf.nataire(s) menttonne(s) ci·dessus at peut contenh' de l'lnf'ormation privil&giee, confidentielle etlau dispensee de divulgatian aux termes des lois appUcahles. Si vaus avez rec;u ce message par erreur, au s'fi ne vous est pas destine, veufilez le mentianner immediatement a l'expediteur et effacer ce caurriel. M~rci

From: Ho, Jason (ENE) Sent: April 03, 2014 1:01 PM Cc: Evers, Andrew {ENE} Subject: Goderlch Harbour Expansion EA • Comment Period Ending

Hello,

This em allis In regards to the Goderich Harbour Wharf Expansion Environmental Assessment (EA file NO. EA 02-08·10).

The environmental assessment has been submitted by God erich Port Management Corporation (GPMC) on behalf of the Town of Goderich to the Minister of the Environment for review. The EA was delivered to GRT members for at the beginning of March 2014.

If you have not already done so, please forward your comments to Andrew Evers at [email protected] by Aprll4, 2014. If you do not plan on making comments or do not have any comments to make regarding this EA, please send a follow up to Andrew. ·

1

Should you have any questions, please contact Andrew at 416-314-7213 or by e-mail at [email protected]

Thank you,

.JnsonHo Ministry of Em·ironment Environml'ntnl Approval~ Bmm:h !! St. Cluir Avcmur West Toronto, Ontario M4V 1L5 Telephone: 416·314-~l352 I Email: ,[email protected]

2

You can go directly to b.ttJtil.:Rc ait-atris.q_g_dnc,::~D.df$.C "!/utris · onlifJQ/ and begin research In ATRIS. At the ATRIS "Help" button, there are answerS to frequently asked questions, a glossary, and Instructions on how to navigate the system. Please familiarize yourself with the Information available there so you can carry out your research using ATRIS.

Please keep In mind that some of the Information provided by ATRIS will be contextual. Depending on your project, the Information that comes up In a search may or may not pertain to Aboriginal or treaty rights In your particular project area. In most cases, therefore, the Aboriginal communities ldEmtlfled by ATRIS are best placed to explain their traditional use of land, their practices, or their dalms that may fall under section 35 of the Constitution A~ 1982.

If you have specific questions on how to con dud: research using ATRIS, we will endeavour to assist you If you contact the as through the e-mail address: !lC.~.:.CA1!.@:':9;Jdo~:..i1-lD_\ic.ge;::_,Ql . Should you have comments regarding the contents In ATRIS, please complete the "Provide Feedbackn form available In the "Helpn or provide them through e-mail. Your Input Is valuable as ATRIS Is contlnuaUy evolving through the addition of new Information and the observations and contributions of users.

Regional Subject Experts Consultation Information Service (OS) Consultation & Accommodation Unit Aboriginal Affairs and Northern Development canada

2

Evers, Andrew (ENE)

From: Sent To:

Constance Agnew <[email protected]> May 5, 2014 11:14 AM Evers, Andrew (ENE)

Subject FW: Aboriginal consultation - Goderich Harbour Wharf expansion - ON

HI Andrew,

I was going through my In box and came across this. Did you hear back directly from AANDC?

Would you like me to add this to the comment/response matrix? I should have a response to the CEAA letter shortly.

Connie

Constance J. Agnew, B.Sc., rcjl Manager, Senior Planning Ecologist LGL Umited environmental research associates 22 Fisher Street, P .0. Box 280 King City, Ontario L7B 1A6 Telephone: 905-833-1244 Fax: 905-833-1255 Email: [email protected]

From: Nancy Macwhlrter [rna!lto:[email protected]] Sent: April-24-14 2:17PM To: [email protected]; [email protected] Subject: Aboriginal consultation - Goderlch Harbour Wharf expansion - ON

Hello Project Leadership;

Aboriginal Affairs and Northern Development Canada (AANDC) offldals do not partldpate In environmental assessments that pertain to projects off-reserve, nor does the department track how other parties carry out their EAs. Therefore, please omit AANDC officials from your contact list. Only when a project Intersects with reserve land, should the Environmental Unit of AANDC be contacted.

AANDC has launched the Aboriginal and Treaty Rights Information System (ATRIS}. This Web-based system uses a mapping Interface to provide Information to federal officials and other interested parties on the location and nature of established and potential Aboriginal and Treaty rights. With ATRIS bringing together lnfonnation regarding Aboriginal groups such as their exact location, their established rights (through treaties and other agreements) and their asserted rights through claim processes and also enabling users to relate many types of AANDC corporate data within a geographical and consultation context, ATRIS.has become the main platform for Canada to disseminate Its real or constructive knowledge of section 35 rights.

1

-2-.. -For more Information on CEAA 2012, please access the following links on the Canadian Environmental Assessment Agency's (the Agency) website:

Overview of. CEAA 2012 http://www .ceaa.gc.ca/default.asp?lanq=En&n=16254939~ 1

Regulations Designating Physical Activities, and Prescribed Information for a Description of a Designated Project Regulations http:J/www.ceaa.gc.ca/default.asp?lang=En&n=9EC7CAD2-1

If It appears that CEM 2012 may apply to your proposed project, you must provide the Agency with a description of the proposed project. Please see the link below to the Agency's guide to preparing a project description.

Guide to Preparing a Description of a Designated Project http://www.ceaa.qc.ca/6303D025-223B-49C9~A 1 B9-DDB9A3BDAOE6/Gulde to Preparing a Description of a Designated Protect under CEAA 2012.pdf

If you believe the project Is not subject to a federal environmental assessment, and do not submit a project description, we kindly request that you remove the Agency from your dlstribullon list. If you have questions, please get In touch with our office through the switchboard at 416-952-1576.

Sincerely,

Anjala Puvananathan Director, Ontario Region Canadian Environmental Assessment Agency

canadian Environmental Assessment Agency

A,qence canadlenna d evaluation envlronnementala

55, annue SL Clair Est,

. ·-·-- - I I I o

~~..a ~ ~ •

55 Sl. Clair Avenue East. Room907 Toronto ON M4T 1M2

pl6ce907 Toronto ON M4T 1M2 .1hl n 1 2014

Aprll17, 2014

Ms. Michelle Whitmore Ministry of the Environment 2 St. Clair Avenue West, Floor 12A Toronto, ON M4V1 L5

Dear Ms. Whitmore:

MIJIIIST~W <lf TltE ENVIFIUII-1!!! /t 1

OlVIf Cr.~AI.APPROVA!.!~ CC.!'lS ;•, SEAJ•CE II'ITEGAATIOtl Ono\, . : . :I

EHVIMOI'<MENTAL APPROVALS llRAtiCit :

Sent by mall

Re: Information on the Canadian Environmental Assessment Act, 2012

Thank you for your correspondence of February 14, 2014 regarding the Goderlch Harbour Warf Expansion Environmental Assessment Study.

As part of the Government of Canada's plan for Responsible Resource Development which seeks to modemlze the regulatory system for project reviews, the Canadian Environmental Assessment Act, 2012 (CEAA 2012) came Into force on July 6, 2012. CEAA 2012 focuses federal environmental reviews on projects that have the potential to cause significant adverse environmental effects In areas of federal jurisdlcUon.

The CEAA 2012 applies to projects described In the Regulations Designating Physical Activities (the Regulations). Based on the lnforrnatlon provided, your PfO)ect does not appear to be described In the Regulations. Kindly review the Regulations to confirm applicability to your project Including section 1 (g), which relates to ,wildlife areas and migratory bird sanctuaries.

According to section 24 (c) of the Regulations the construction, operation, decommissioning and abandonment of a marine terminal designed to handle ships larger than 25, 000 dead weight tonnes (OWT), unless the tennlnalls located on lands that are routJnely and have been historically used as a marine terminal or that are designated for such use In a land use plan that has been the subject of public consultation, may require a federal environmental assessment.

..• 12

Regulation for Diving Operations O.Reg. 629/94", this sentence should be modified as there Is no guidelines with that title. The sentence could refer to either MTCS's 2011 Standards and Guidelines for Consultant Archaeologists or the older 1993 Archaeological Assessment Technical Guidelines. Also, there is reference to a Stage 1 and Stage II archaeological assessment however this section appears to be referring to the Marine Archaeology Assessment (Appendix K), which Is completed under a different process and archaeological license, and the reference to stages is relevant only for land-based archaeology. Therefore, this section needs to be modified to remove the reference to Stage 1 and II archaeological assessment work. There appears to be no land archaeology component to this project, only marine archaeological work and this needs to be clear.

Section 6.3. 14. 1 In-water Construction At the end of the subsection on Potential Impact, the last sentence states "The Cultural Heritage Assessment Report was submitted to the Ministry of Tourism, Culture and Sport for review and they concurred that there are no Impacts to the nine built heritage features in the primary study area". This sentence needs to be modified slightly as we Indicated that "MTCS has no Issues with this technical assessment report nor with the cultural heritage resources Identified and addressed with respect to project lmpactsM, which Is different In its Intent as MTCS must review and "concur with" or •accept" reports for archaeologists to meet Ontario Heritage Act archaeological licensing requirements.

There Is a recommendation within the Cultural Heritage Assessment Report (Appendix J), which is also summarized In the EA report, for heritage Interpretative plaquing to occur In the Goderlch Wharf and MTCS would like to see a commitment to this recommendation In the EA report.

The above are MTCS's comments on the Goderich Harbour Wharf Expansion Individual Environmental Assessment.

Please do not hesitate to contact me If you have any questions regarding the above.

Sincerely yours, Penny Young

Penny. [email protected] Heritage Planner Culture Services Unit t. 416-212-4019

copied: Constance Agnew, LGL Limited Matt Pearson, B.M. Ross and Associates Ltd.

2

Ministry of Tourism, Culture and Sport

Culture Services Unit Programs and Services Branch

Mlnlstere du Tourtsma, deJa Culture etdu Sport

Unlt6 des services culturela 01111Ctlon des programmes at des services

t'):..:

t?ontario 401 Bay Street, Suite 1700 Toronto ON M7A OA7 Tel. 418212-4019 Fax: 418 314-7175

April11, 2014 (EMAIL ONLY)

Michelle Whitmore Special Project Officer, EAB Ministry of Environment

401, rue Bay, Bureau 1700 Toronto ON M7A OA7 T61.: 416 314-7147 T616c.: 416 314-7175

2 St. Clair Avenue West, Floor 12 A Toronto ON M4V 1 LS emaii:[email protected]

Project: Goderlch Harbour Wharf Expansion, Submission of Individual Environmental Assessment Report

MTCS File: 40EA015

Dear Ms. Whitmore,

The Ministry of Tourism, Culture and Sport's (MTCS') interest In this project relates to its mandate of conserving, protecting and preserving Ontario's cultural heritage resources including archaeological resources, built heritage and cultural heritage landscapes. As such, MTCS reviewed and provided comment on the Terms of Reference for the individual Environmental Assessment (EA) on June 23, 2010 and on the draft Cultural Heritage Assessment report on March 11 and September 27, 2013 for the Goderlch Harbour Wharf Expansion Project.

The EA Act defines environment broadly to include cultural conditions that influence the life of humans or a community. Cultural heritage resources are important components of those cultural conditions.1

The EA report and technical studies included as appendices are intended to examine and evaluate the potential environmental effects of all aspects of the Goderich Harbour Wharf Expansion project.

MTCS Comments and Recommendations Section 3. 3. 6 Archaeological Resource Assessment Under the Methodology subsection within this section 3.3.6, the report indicates "the archaeological assessment was undertaken in accordance with the Ministry of Tourism, Culture and Sport's Stege 1-3 Archaeological Assessment Guidelines, Ontario Heritage Act, and

1 Under the Environmental A~essment Act the "environment• means: (a) air, land or water, (b) plant and animal life, Including human life, (c) the social, economic and cultural conditions that Influence the life of humans or a community, (d) any building, structure, machine or other device or thing made by humans, (e) any solid. liquid, gas, odour, heat, sound, vibration or radiation resulting dlrec1ly or lncflredly from human adlvltles, or (I) any part or comblnaUan of the foregoing and the Interrelationships between any two or more of them, In or of Ontario; ("environment")

1

Ooderich llarbour Wharf f:xpansion EA ... I•g2

Thank you for the opportunity to comment at this time. Feel free to contact this office if you have any questions.

Yours sincerely,

Brandi Walter Environmental Planner/Regulations Officer Maitland Valley Conservation Authority

C.c. Constance J. Agnew, Senior Planning Ecologist. LGL Limited

Maitland Valley Conservation Authority

April3, 2014

Michelle Whitemore Special Project Officer Ministry ofthe Environment Environmental Approvals Branch 2 St. Clair Avenue West, Floor 12A Toronto, Ontario M4 V I LS

Dear Ms./ Mrs. Whitemore;

Re: Godericb Harbour Wharf Expansion Final Environmental Assessment

The Maitland Valley Conservation Authority (MVCA) has reviewed the final Environmental Assessment (EA) Report (February 2014) for the proposed Goderich Harbour Wharf Expansion with respect to natural hazards and Ontario Regulation 164/06. Based on our review, we offer the following comments:

1. The technical studies submitted with the EA concluded that there is no additional impact on costal processes as a result of the project. It is our opinion that the proposed work meets the flooding and erosion tests of Ontario Regulation 164/06 (Development. Interference with Wetland.v and Alterations to Shoreline.li and Watercourse.v Regulation) made under the Cmuervatitm Authorities Act fR.S.O. /990. chapter C.27J. A MVCA permit is required, pursuant to 0. Regulation 164/06, prior to commencing the work.

2. The storm water collection system is proposed to be divided into two separate systems to address salt contamination. It should be noted that there is potential for other storm water containments such as oil and grit. The EA states that the stormwatcr collection system will be equipped with an oil and grit separator. We recommend that measures should be taken so that all storm water runoff is treated to at least a "normal water quality standard".

3. The EA report details that all till will be appropriate material that is free from contaminants. The testing and control of till material will be included as a condition of MVCA' s permit.

, .·\AlTLAND Vr\LLEY CO NSERVATION AU C HORII Y

I o<n i'v1arietta Street.. nox 12 7, \Vroxder, ON NOG 2XO .51 (j i3s>3s.si · Fax·: S:i'~) ~~:3.S-3si· b Eni1il: ·rn<Ii0ar1d(cj)ni\.lccl:. ori.c~i

Member of

Conservation ONTARIO.

5195242301

FAX:

To: Mr .. -\ndrew Evers

From: Richnrd H. Peever

Re: Oodcric:h WbarfE,;pnnsion Proj:ctNoise Issues

1\Jaltlnnd Vallll! ""rtiUI Ltd. !GO Nortla Harbour no1ul W

P~GE 01/09

'P.O. Bn 175 Gndertcll ON~.\ JZl 1519) 5l4 <MOD (Ph) (519) 524 1301 (Filt:)

Fax: 1-415-314-8452

Date: April9, 2014

Pogcs: 9 pngcs (including cover page)

. . . . . . . . . . . . . . . . . . . . . . . . . ,. . .

~4/D7/2Dl4 19:4e

i\ptil8. 2014 Mr. S. Kulendrnn

5195242JD1

J.E. Coulter Associates Limited 1210 Sheppnrd Ave East. Sultelll Toronto. On tart" ~lK I FJ

Dear Sir.;

PAi.E o:uog·

:O.Initlnlld V~Uc:y r.u. so . " · Claderid1. ON

N7A3Z2 Tel, (519) Sl4...&409 F&n Ul91 S24-2Jill

t hn.vo not had n reply to my letter of March t 9, 2014 which r look forward to. I hnvr: reviewed the Goderich WltarfE,;ccutlvc Summary - Nol&c and ha\'e the following commenL&:

I. We arc in support in principle of the prapo~ ~po.nsion wharf 2. We have some concerns thnt hnve not been addrc:sscd 3. lt is such n huge study, It is difficult to meaningfully review iL in lite allotted time prior to April f I, 2014.

Since thnt Jetter the news has reponed lhc likelihood (•f tbc project proceeding. A number of our clients have queAtioncd us about the project. They recognize the nrea is being e:ocpandcd. production is being expandct:l, mil facilities wUI be expomded. tr.msportation will be grentl~r Increased and possibly more ruil tmclcs wiJJ be Installed. Their c:onc:cm is noise ·- day nnd nigltt, stone du.qr, J;Dil dwt and CDTTQsion on tJu:: boats and cars. As per our enclosed previous tetter Maitland Inlet ~arina is 200 metres from the proposed C'll:panslon. TI1c boats in the: mlll'inn are used I1S scnsonnl cottnges by many of our clic~ntclc which is \\ithin the zoning bylaw of a. mnrinn. This area should hnve heen 11 receptor area.

A I Maitland Vnllcy Marina. we planted evergreens (cedars :mel spruce) many, yeats ago to tl!sist in im)tallng I he nol!ic nl our entrance lha.t has hod some modemte effect in cuUlng the nnise at our entrance. At Maitland Jnlcl Mnrina we tried this but the evergreens were killed by the salt dust which can be signillcont in o liOUthwest bn:e7.e,

On 11 windy day wilh winds out of the south I south~I!Sl I we.~t. any activity in tbe proposed new nreo with :1ggn:gutes or aalt wilt hnvc significant mnificndons. We feel now 19 the time to inslnll 11 noise and sail/dust barrier llimilar to your report TI11: noise bllrricr should l•c installed on the top of a portion the concrete tivCT wnlt and nlong the south side of the stona river breakwall. T~is noise barrier could bave overlapping openinss to allow fishermen ru:cc:s!l nlong the river. I have enclosed !A.

1~" a sketch of the combined deeded property limits of Maitland Valley nnd Maitland Inlet mor!nas. Thill property tttle chain is from the Ca.nadinn National n.ailways which at the time wns an ann or lite Fedeml Oovemm,:nt. Most of this property Wll! part of the Harbour Port Lllnds thallhey O\\'Tit'd. This is the property th:st we ~ay tii.Xes on. Tilis property ;tarts 100 feet out from the concrete and stone river brenlcwalt.

We hnvc ll group of clients th11t hnvc fanned a comndtlce thllt would like to have a meeting with you to further dlsC\tlt'l their concerns nnd attempt to resolve the issues with you. TI1eir mandnte is to have lhe issues addressed and rectified but not ta Interfere or slow down the dc:vulopmcmt. T have also enclosed a letter rram a respected member of our client committee thnt should have been fJrwnrdcd to you 11nd addressed in your report. He can be contacted by email: j_pticyMsri.i>.o;lc:mcns.com. Please orrnngc to hove a meeting dntc:.

Yours truly, / . ~·

£__~~~ Oick Peever ___,..-President, Maftlrmd Valley Morina Vice Prcs1c!enl. Mnltlund Tnfet ~onno.

• 04107/2014 19:40 5l952423BL PAGE 03/09

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"-

March 19, 2014

Mr. Sam Knlc:udmn J.E. Coulter Associ11tes Limited l210SbeppanlAve. E., Suite211 Toronto. ON M2K.lB3

P.O. Boa 17!, Godcric!l. ON N7A3Z2

Ta~($19)514-4409

fa (519) .5%4.2301

k Proposed Goderich WluufExpiiD.Sfoa- Nol!c Impact.A.sacssmcut

Deat Mr. Kulcmcbu:

I would lila: to prefiu:a the letter that follows with oW' llSSW'IUlCCS that we are supportive of the Oodrmc:b HarbDW' Expansion Project and hope thlll it ptocceds.

Wa b11Ve some serious noise conccms in reganh to some shortcomings in your report In regards to tho proposed expansion and haw it relatca to onr Maitland Valley MarfDA and TIIIilcr .Parle aita ond Maitlaad Inlet Mllrina.

In Y9Uf report yau identify fo1U' [4] recepton: 1! 4 being Maidand Valley Mariml and Truilcr Park. A ~~~~ receptor should be included, MoitlaDd Inhlt Mnrfoa which is 200 m awa.y and directly ncroas the l'ivCr .&am the proposed project.

Many of onr baa.ters at both matinus DSG their boats a.s a cottage, living on them during the week md on weda:ads. !hey. like most people, are there to et!Joy the ou13id.B amenities mctuding swimming, beach bon1ires, boating and the sumcts. '

The mnbfeo~ noise itom the mine aod Joadiag ships is oat a problem.

The greatest problems an: ns follows: 1) Safety alarms at aU boms ii'om:

a. Mine hoisting eguipmc:nt b. Backup a1mmJ

i. Moving equipment u. tandem

c. Loaders being run at exgessive speedlblgh RPM

Continued on PDBe !?.

04107/2014 19:40 5195242391 F'AGE D4/e9'

·-

·-

-. ..

Maid1111d Vnlley Mariua Limited

2) Otbcrnaisc thnt mny not be ccmsidered iD your study: o. Sh~g nd1 em b. JolDJDg ran c:ar5 together with excessive forctt c. Locomotives idling for c:xteadcd periods d. Rail cars squealing 111 they romui the comc:r 11t the entrance to MVM

3) Trnclc:nolses: a. GolDs up bill ftom standlog start b. Engine over revving comiDg down the hill to a stop c. Tailgate slamming an dump tmck:

P:s.ge 2

4) ·The other pomt skipped aver in tha n!port is bow significantly noise tmvels over water and reb01111ds off the wiley bllllks and cement rata1ning wall

I :tppreciate thnt some of the above ara cxistfug ':onccms but aa you can appreciate with, tho proposed cxpnr1stou the problem is solos to increase substantially,

We feel that some of tba noise bm.lers in your ~ sbould be coustructed in conjunction with tho cxplltiSion proposal a.s follows:

1) Noise battier should be installed aJcnB the concrete river retaining wall 2) Noise barrier sbouJd be insmlled aJong the river stone wull at the north side of the

pmposed expao.sion

Wo would like the opportunity to meet with you aud the committee to discuss this praj~!!:l We can meet nt your earliest convenlcncc after Mlll'Ch 25, 2014.

As you CliO appreciate with a project of this sir.e, which could last twa years, the noise should be addressed before the start of construction.

Twill review the report ln more detnil and forward any other comment&.

Wo do not want to bold up the project in any WB]' but our concerns need to be adth'essed.

y~_.;L~ Dick Peever Pn:aidcot, Maitland Vulley Marina Limited

' ~4/U7/2D:4 19:~D 51952423Dl

September 24,2013

Mr. Mike Gauthier Compass Mlnemls PO BoiiC 370, North Harbour Rd. Godarfch, Ontario, N7A 3V9

Dear Mr. Gauthier:

1 am writing to mquet Slfto's Goderlch mine to eliminate lnapprtlprtate levels of ambient nolea being emitted by the site.

P~E 05/09

My family spencla summer weekends and hclfda!IS on our boat In Mall land Inlet Marina (adjacent to the rnlne site) and have done sa for lhe past 13 years. Over that time we have experienced various temporary lncanvenlences t,elng located near lha lndu&frfal hRrbour (nol&e, dust, excess fghtlng) but these ara ror lhe most part transient and we haw learned to accept them gillen the proldmtty.

OVer the past many monlhs, the mine has empiOfad a new/modified system of horn signals that operate 24fT. These have slgnfflcanuv raduced the quality of fiVing for lhasa neighbouring the harbour.

The days aro rrustraUng but almost every night we are awakened at all hours by horns In a process I can only assume Is amne fo1T11 cf safety signally. This has fJUStrated my family's enjoyment of Godertch and now limiiD our desire Ia rettrn to the area.

While I admire any affor1to increase safely an your site, Compass needs to emplay a less lntruutve signaling method that does not Infringe upon the quality of life of your neighbours. The tenants of Maitland Inlet Marina wtU be hauling lh~lr boats cut shortly whiCh gives Compass the winter months to resolve the Issue.

Should you wish further information from myself or ether tenants of Maitland Inlet Marina, please feel free to contact me at your convenience.

Regards,

· rk Rcwe, Gerry Rogers, Compass Minctrals

Laszlo ear11, MOE, Operations Division Dick Peever, MaiUand Marinas

--------------------·---- ·····• -- . -D~ID7/2Dl4 1~:4e 51952421a1 PAGE 0&/09

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PAGE D7/D9 • iJ4107/2Dl4 19:40 51 Dl

i14/D7/2D14 19:40 51952423Bl PAGE CB/09

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a41D7/2D:4 19:48 51952423BL PAc=; D91UCJ

JB70s - Majo~: Harbour works; tivc.t b.te:lkwatu. r·ew ll11ifoiaJ cbtaanel dredscd for Maitland River tBBOs-1!)25 .. Ownership disputes & lnw suits at Hnrbour llOd Watu&ont' printe lnndawnc::s, Goderh:li ElCTDtcrS, Town of Godcrlch, Rnilwl\ys including BLHRR successor CNR, God::ich and Guelph lWl\Wf Company (CPR); Attrllls, Ssunuel Platt, and otbw.

1884-1888 Lcttc:s Patent issued to Town fn.r 'a~r' 60 foot: wide Harbour QWI.y .roudmy oftet lwbow: pic::s ~:c:-Jocated north. D.mwiag by fotmc.t HD.rbou: Master. Tom Pri:.dwd shows fish houses, icehouse on right, but does not show the CPR 'FloUJ: Shed' (Gteen »ntbing House) nor the steel dnd stctnge wuehouse to the ~t • all oa 'Hsabour Quay'. This area bas com:i.aued to be u:red far tammerdal & rea:c:lticnsd purposes. '!he Patents manda.ted that access fa: "vehicles and wagons" be maintained.

ASH HOU&ES-TO)I PlU'ICRAli.J), HABBOUJlltAStlill

1912 - Land agreemcms between Town and CPR fat 'Flou: Sheds' and cpreJght Sheds' on south Hnrbour Qusty. ToWD putebased 'Flour Shed building from CPR La 1931

1926 - Quit Claim Deeds tD finalize ownc:ship is;ues: (C~ CNil, Oscu:: Fleming). Present bounda.rics o£ Fede:al Harbour esmbliahcd.

~·.C.

...

Name: David Lew

Contact: [email protected]

519-524-8394 X3312

Location : Goderlch, CAN-Ontario

Comment: I have reviewed the electronic copy of the EA and at this time I have no further comments. Thank you Dave Lew

2

Evers, Andrew (ENE)

From: Sent: To:

Whitmore, Michelle (ENE) March 31, 2014 11:16 AM Evers, Andrew (ENE)

Subject: FW: Goderich Wharf Expansion EA I Wharf Expansion Website E-'Mail

FYI

From: Constance Agnew [ma!lto:cagnewlmlg!.coml Sent: March 3, 2014 10:22 AM To: Whitmore, Michelle (ENE} Subject: FW: Goder!ch Wharf Expansion EA I Wharf Expansion Website E-Mail

Second comment received vla the proponenfs website.

Constance J. Agnew, B.Sc., rcJI Manager, Senior Planning Ecologist LGL Limited environmental research associates 22 Fisher Street, P.O. Box 280 King City, Ontario L7B 1A6 Telephone: 905·833-1244 Fax: 905·833·1255 Email: [email protected]

From: Usa Courtney [ma!lto:lcourmey!mbmross.net] Sent: February-2+14 8:24AM To: 'Constance Agnew'; 'Kauffman_Grant'; 'Sowel Kang'; 'Rowland Howe'; AJ Hamilton Cc: 'Pearson_Matt' Subject: FW: Goderlch Wharf Expansion EA 1 Wharf Expansion Website E-Mail

Comment received from the wharf expansion website below.

Lisa J. Courtney, MSc. B. M. Ross and Associates Limited Engineers and Planners 62 North Street Goderich, ON N7A 2T4

Ph: (519) 524-2641 Fax: (519) 524-4403 [email protected] www.bmross.net

From: [email protected] [mailto:[email protected]] Sent: February 24, 2014 8:05 AM To: [email protected]; [email protected]; [email protected]; [email protected] Subject: Goderlc~ Wharf Expanslpn EA I Wharf Expansion Website E-Mail

1

Evers. Andrew (ENE)

From: Sent: To:

Whitmore, Michelle (ENE) March 31, 2014 11:16 AM Evers, Andrew (ENE)

Subject: FW: Goderich Wharf Expansion EA I Wharf Expansion Website E-Mail

FYI- to follow-up.

From: Constance Agnew (mal!to:[email protected]] Sent: March 3, 2014 10:21 AM To: Whitmore, Michelle (ENE) Subject: FIN: Goderlch Wharf Expansion EA 1 Wharf Expansion Website E-Mail

HI Michelle,

We have received two comments on the EA via the proponent's website. I'm not sure whether the commenting party has provided their comments to you as well?

I will send the second under separate cover.

Connie

Constance J. Agnew, B.Sc., rcjl Manager, Senior Planning Ecologist LGL Limited environmental research associates 22 Asher Street, P.O. Box 280 King City, Ontario L78 1A6 Telephone: 905-833·1244 Fax: 905-833-1255 Email: [email protected]

From: Lisa Courtney [mallto:[email protected]] Sent: February-24-14 10:29 AM To: 'Constance Agnew'; 'Sowel Kang'; 'Kauffman_Grant'; 'Rowland Howe'; AI Hamilton Cc:: 'Pearson_Matt' Subjec:t: FW: Goderlch Wharf Expansion EA 1 Wharf Expansion Website E-Mail

Comment from website.

Lisa J. Courlney, MSc. B. M. Ross and Asscclates Limited Engineers and Planners 62 North Street Goderich, ON N7 A 2T 4

Ph: (519) 524-2641 Fax: (519) 524·4403 I courtney@ bmross.net

1

www.bmross.net

From: [email protected] [ma!lto:[email protected]) Sent: February 24, 2014 10:19 AM To: [email protected]; [email protected]; [email protected]; [email protected] Subject: Goderich Wharf Expansion EA I Wharf Expansion Website E-Mail

Name:

Location : Goderlch, CAN-Ontario

Comment : I have reviewed the EA and In particular the assessment of truck traffic. ll!ve on the bank above North Harbour Road (32 Caledonia Terrace) and I have become extremely annoyed with the existing truck traffic as many use their engine brake on the way down the hill and then they are gearing up as they cross the railway track to get up the hill. At 4 am this not only wakes me up but keeps me up. An Increase In this traffic will make living In our house extremely unbearable. I am all for Industrial development but not at the expense of peace and quiet 1 should be able to have In my house and In my backyard. 75000 trucks per year wlllllmlt this. No where on the EA was the continuous noise of the additional truck traffic addressed. If the expansion proceeds, for the sake of those living at the top of the hill above North Harbour Road. this must be addressed. I will look forward to hearing from you Taylor Lambert

2

April10,2014

Mr. S. Kulendran J.E. Coulter Associates Limited 1210 Sheppard Avenue East, Suite 211 Toronto, Ontario, Canada, M2K 1 E3

Dear Mr. Kulendran:

I have reviewed the document "Goderlch Harbour Wharf Expansion -Appendix D, Noise Impact Assessment Report" as issued by your firm February 13111

, 2014. Your report Is of consequence to me as the harbour facility borders upon my summer residence at Maitland Inlet Marina.

I acknowledge the significant effort and detailed analysis put into developing this report but I am concerned with a primary omission that limits the validity of the data presented. Specifically, the report overlooks a 5111 receptor which is the closest (and most Impacted) residential area to the Sifto mining operation being Maitland Inlet Malina. Maitland Inlet Marina (not to be confused with Maitland Valley Malina) Is directly opposite the mining operation on the north side of the Maitland River. The Image below (from your report) shows the proximity of Maitland Inlet Malina to the mine.

The boats and the marina grounds are a seasonal residence for locals from Godelich and visitors from the surrounding region. During the summer, people stay on their boats throughout the week with the numbers obviously swelling on the weekends.

My family has made Maitland Inlet Marina our summer "cottage" residence for the past 14 years. Over that time we have experienced various temporary inconveniences being located near the industrial harbour (noise, dust, excess lighting) but these are for the most part transient and we have leamed to accept them given the proximity.

J.E. Coulter Associates Limited April10,2014 Page2

As mentioned earlier, my main concern Is that no consideration In your report was given to the impact upon the closest residents (Maitland Inlet Marina -5tli receptor) to the Industrial harbour. This impact needs to be Investigated Including the following:

1. Current Impact of the Industrial harbour upon receptor 5.

o Inappropriate Increase in noise from the mine site In 2013 (see Attachment 1: letter issued September 24, 2013 for details)

o Monitor impact of noise, dust and light pollution during day and night operations.

2. Impact upon receptor 5 during construction phase of Wharf Expansion Project.

o Noise, dust and light pollution

3. Impact upon receptor 5 after construction phase of Wharf Expansion Project Is completed.

o Noise, dust and light pollution

In response to my letter from last fall, Compass (Sifto) advised that they would review my noise concerns. It Is our expectation that the issue has been resolved prior to returning to the marina In May 2014.

As a separate concern, has there been appropriate study of any potential negative impact to vessel navigation from modified silting within the entrance to the Maitland River? Keep In mind, small vessels use this navigation channel dally and modified nearshore currents from the north wall construction may change sand deposition potentially becoming a hazard to navigation while accessing this safe harbour.

As you can Imagine, the seasonal residents of Maitland Inlet Marina are m.ost interested in how the Wharf Expansion Project and the day-to-day operations of the harbour will strive to minimize any negative impact their operation has upon their neighbours. If not handled appropriately, seasonal residents will relocate which will have a negative economic impact not only upon the marina operators but the local retail community as well.

Finally, I want to be clear that I fully support the economic vitality of Goderlch and the needs of the industrial base that supports this community. We have come to enjoy Goderich over the past 14 summers and my family wish to continue spending our summers at Maitland Inlet Marina. With proper planning, the Industrial harbour and the neighbouring summer residents can continue to share this space on Goderlch's waterfront

Please contact me at your convenience should you wish to discuss further.

;!@~~. ~

Attachment 1

September 24, 2013

Mr. Mike Gauthier Compass Minerals PO Box 370, North Harbour Rd. Goderich, Ontario, N7A 3Y9

Dear Mr. Gauthier:

I am writing to request Slfto's Goderich mine to eliminate inappropriate levels of ambient noise being emitted by the site.

My family spends summer weekends and holidays on our boat In Maitland Inlet Marina (adjacent to the mine site) and have done so for the past 13 years. Over that time we have experienced various temporary inconveniences being located near the industrial harbour (noise, dust, excess lighting) but these are for the most part transient and we have learned to accept them given the proximity.

Over the past many months, the mine has employed a new/modified system of horn signals that operate 24n. These have significantly reduced the quality of living for those neighbouring the harbour.

The days are frustrating but almost every night we are awakened at all hours by hams In a process I can only assume is some form of safety signally. This has frustrated my family's enjoyment of Goderich and now limits our desire to return to the area.

While I admire any effort to Increase safety on your site, Compass needs to employ a less intrusive signaling method that does not infringe upon the quality of life of your neighbours. The tenants of Maitland Inlet Marina will be hauling their boats out shortly which gives Compass the winter months to resolve the issue.

Should you wish further information from myself or other tenants of Maitland Inlet Marina, please feel free to contact me at your convenience.

cc: Mark Rowe, Gerry Rogers, Compass Minerals Laszlo Bartl, MOE, Operations Division Dick Peever, Maitland Marinas

Attachment 1

Attachments: Slfto Mine, Goderlch, Noise Issue, 2013-09-24.pdf

From: Sent: September-24-13 3:52PM To: '[email protected]' Cc: '[email protected]'; '[email protected]'; Dick Peever ([email protected]); '[email protected]'

Subject: Inappropriate levels of noise being emitted by the Sifto Goderlch mine site

September 24, 2013

Mr. Mike Gauthier Compass Minerals PO Box 370, North Harbour Rd. God erich, Ontario, N7 A 3Y9

Dear Mr. Gauthier.

I am writing to request Sifto's Goderich mine to eliminate Inappropriate levels of ambient noise being emitted by the site.

My family spends summer weekends and holidays on our boat In Maitland Inlet Marina (adjacent to the mine site) and have done so for the past 13 years. Over that time we have experienced various temporary inconveniences being located near the industrial harbour (noise, dust, excess lighting) but these are for the most part transient and we have learned to accept them given the proximity.

Over the past many months, the mine has employed a new/modified system of horn signals that operate 24/7. These have significantly reduced the quality of living for those neighbouring the harbour.

The days are frustrating but almost every night we are awakened at all hours by horns In a process I can only assume is some form of safety signally. This has frustrated my family's enjoyment of Goderich and now limits our desire to return to the area.

While I admire any effort to increase safety on your site, Compass needs to employ a less intrusive signaling method that does not infringe upon the quality of life of your neighbours. The tenants of Maitland Inlet Marina will be hauling their boats out shortly which gives Compass the winter months to resolve the issue.

Should you wish further information from myself or other tenants of Maitland Inlet Marina, please feel free to contact me at your convenience.

Regards,

..

cc: Mark Rowe, Gerry Rogers, Compass Minerals Laszlo Barti, MOE, Operations Division Dick Peever, Maitland Marinas

<< ... >>

2

Ms. Michelle Whitmore, Special Project Ofllcer Ministry of the Environment Environmental Approvals Branch 1-418-314--8452

Dear Ms. Whitmore,

Ret Respoue to the PIC Cor the Godcrldl Barbour WhufEspamaloo.

Por tho past number of yean n:strlctiou.to publlc au:cess 111 the Goderlch Harbcm and Lake Fraat has continued to escalate. The proposed Wharf Expansion will make Lake access DS the public cun'Ciltly enjoys lt impossible. We have been told by Rowland Hawe that Vehicle acce15 will not be pmnitted, the public road will be closed. Maybe, they will build pedestrian accas.

Pedestrian access is impractical !or mnny oithc cum:nt users. MJmy havo moblUty constraints and vehicle access Is tbe oaly way 1hay will bo able to enjoy the Wl11ln" front as tltl!)' currently da. Already. rec:au ''improvements on the South Pier have mada it impassible for lndlvJduals with moblllly l!l!luea ·to enjoy tbe lake as ther used to, Infact from a wheal chair you cannot cvcu see the Lake over the concrete Wllll anymore, not 10 mention fi!hing.

1 prcpnred drawinp durt would provide u publlc access to the Lake far :fishin& recreation and el\}oymcnt JJUI]JOII!S that would not negatively impact the project. In a publlo ~entation I was told 11Wcll that's not gains to happen". They appear m the EA documents as black blob! that are Ulegible.

I would like to 11harc these documents in thdr legible ibrm with you. They can be cmailed lf you wiab.

1'hc cum::nt plans fer the Harbour WbmfExpBD.!IJon propose 10 fhrthcr restrict access to the North Pier Blld rock river wall. Both oftheso locatloos an: popular ftsldng and recrcatioD.IIllocatlons that the publiG hLWC: IU\Iaycd ahu:c their consuuotion decades ago. RawlllDd Howe of the Ciodcricll Port Munosc:m.cnt corporatian statl!d that acccu to the "Dolphins" (concreto struetum 1hAt are uaod for manoeuvrbls ships) located at the west end of the north pier will be maintained. Access to this location is propom:l along the north aide of the harbour clwma1 betWeen the loading boom and the location that ships mcor to be loaded. Ha also stated that tbls access will only be available while there me no ships in port. The times available for acceiiS especlnlly with the:~ proposed praductfon lncreua wUJ be vety Umited since boats already arrive nearly every day during the shipping season. ~ n:cently as last year the public enjoyed vehicle ncc:caaiO the Dolphins and rock river wall. This will cease 'Under tb: current expansion proposlll.

To date rccrclltioDDllw:bour usca have not been consulted with cbzmses 10 acceu and the impact of construction at the lwbaur. It wns a "reqllfrement for the Canada Cmnpuy MS to suarante" public ucccss to the port" nc:arJy 200 years qa. Transport Canada preserved publlo accou wblla the harbour ?ill In their control. Furthennore, the original purclwo agreement In 1999 from Her Majesty tho Queen in the RfHht of Clllll.1da (Tl'DDSport Canada) included the requirement to maintain public ac=csa to the harbour.

11 2

~R.~··t - 201~ JE 48 P"l Ccun~y of H~;·~n Hgnways ~ep~ a19·524 ·9291

The Qodcric:h Harbour WluarfExpanslon offers opportunities to mitiptc these restrictiaDS ta sociAl and recreational activltles. None of the 3 proposed Altamatives WiD utilize the unprotected north {rock riva- wall) and weal side (csxlstfng break wall) of tha harbour expansion for loading or unloading vessals. Tho rock river wall !& currantly used extCDSivcly for ftahlq and recreation.. Land a.ccess tD the c:risting btuk wall would provide increased opportunity far rccn:ation and fishing. Furthc:more tbe existing break "'1111 would be onldcullocation to c:reate flah habitut as piU1 o£ the mitlaatlon measures .required to campeosate for lost fish habitat. Both the .rack waU 1U1d break wall exWld beyoad lhe expansion wblcb l\lrther offers opportunities for n:crcatioaal users ifrbey have access.

The proposcci usc of tho Wharf Harbour Expansion i! the stmaae ofbulk materials. The proposal indicated that there will be no buUcllngs or permanent suuctures constructed en the land. Tha limits of the bulk stomgc of salt and other materials are setback from the river mouth and lake to prevent tho material from entering the 1\DtUtlll environment u ahawa in the £A dOAUDCntalion. The: publi; access area ~uld bo located lllaog the north and west edge of the expurudon where materials will nat be stored. Thl: attached drawing shows possible public access without restricting storage capacity. This access IU"C& would provide public access and iDdustriol access ta various pa1'b afthe expansion. ~ludiag vehicle acccss1o tho north sldo and west sldo fm n:crcaliaaal liSe. Included with the public access should be auffiafeJU parking al.oas the river walland a pntk like publlc access paint at each end of the existing bleak -y,uJJ wilh sufficiem plll'ldns and occeaslbWty 10 accommodate recrcatlooal usezs and users with limited mobility. LocatJag thcso acc:ess points in the conu:ra of lhc expansion should minimize the imp~~&.1 to industrial users, wbila providlus an an:a for reautional use.

A stllc.cholder group ofrcc.reatlonal users should provide input to the chamges lD the immedhue harbour area and work with the Godcrich Part Mmmg~:mam Carparatlon ta prascrvo the social and r=cational usc of the harbour that bas existed far aver 200 years. The rcc:reatlanal users have llblucd the barbour and the smroUDding lands with Industrial users for that entire time. There is room far all harbour uaan to exist in the Godedch Harbour. Tho Harbour Wharf Expansion pmvidcs extended oppartuaitii:S ror that relationship to continue. Mutual rc:specrt. proper road desisn and a minimal amount of iafra.muCUU'e can help assure that.

If this expansion is allowed ta continue as is without regard for the recreational port users, it wJII be a travesty that unfortunntely will never be corrected.

lf you have lillY questions with rcprd to my concerns please CGaus;t me.

Ia

. .. Evers, Andrew (ENE)

From: Sent To:

Constance Agnew <[email protected]> April14, 2014 10:47 AM

[email protected] Cc: Subject

Evers, Andrew {ENE); Rowland Howe; Hamilton_AI; Kauffman_Grant; Stuart_Dan RE: Message from GPMC EA website

Good morning

Thank you for your comment on the God erich Harbour Wharf Expansion EA. We appreciate you advising us of your concern regarding the quality of the drawings, provided In the Record of Consultation Appendix H, you submitted to the study team following PIC #3.

Formal comments on the EA are to be submitted to the MOE Project Officer. As such I have copied Andrew Evers on this email so that he may have a record of your concern.

We appreciate your continued participation In this study.

Regards,

Constance J. Agnew, B.Sc., rcjl Manager, Senior Planning Ecologist LGllimlted environmental research associates 22 Fisher Street, P.O. Box 280 King City, Ontario L7B 1A6 Telephone: 905-833-1244 Fax: 905-833-1255 Email: [email protected]

-Original Message-From: mallto: ) Sent: Aprll-11-14 6:27 PM To: [email protected] Cc: [email protected] Subject: Message from GPMC EA website

HI Matt and Constance.

I am disturbed to see the poor quality that you were able to achieve on my submission to the EA for the Harbour expansion.

Through numerous attempts, I have been unable to replicate that poor of quality on my own scanner.

It Is obvious that no one will even take the time to look at such a poor image of what many people Indicate Is a reasonable design.

I'm sure this is an oversight, please let me know how best to distribute my own digital copy for the convenience of the people that are attempting to make some sense out of it. It Is obvious that my response relates directly to 2 images that are Illegible. -

1

Truly

[image:4112014_62256_0.png)

This email message, Including any attachments, Is for the sole use of the Intended reclplent(s) and may contain confidential or privileged Information. Any unauthorized review, use, disclosure or distribution Is prohibited. If you are not the Intended recipient, please contact the sender and destroy the original message and all copies.

2

tt I \ t tl K. l C'

SAUGEEN M~TIS

Historic Saugeen Metis 204 High Street

Southampton, Ontario NOH 2LO

Direct Line (519) 483·4000 Fax (519) 483-4002

April tO, 2014

Environmental Assessment Services Ontario Ministry of the Environment 2 St. Clair Ave. W. Floor 12A, Toronto ON M4V U.S

Attention: Andrew Evers, Project Officer

Re: Darryl M. Robins Consulting Inc. Review of God erich Harbour Wharf Expansion Environmental Assessment and the Sediment Transport Impact Analysis on behalf of the Histori~ .Saugeen Metis. EA File No. EA 02·08·10

Attached are the peer reviews by Darryl M. Robins Consulting Inc., on behalf of the Historic Saugeen Metis, of the Environmental Assessment and the Sediment Transport Impact Analysis for the Goderich Harbour Wharf Expansion Project

HSM Council is satisfied with the reviews and as a result has no observed issues with the proposed God erich Harbour Wharf Expansion at this time. The proposed recommendations that HSM would like to follow through with are;

1. Request an opportunity to review the stormwater management report/ design when it is complete;

2. Request an opportunity to review the 'For Tender Drawings' to ensure that sediment control measures are in place to minimize the risk sediment entering Lake Huron;

3. Request an opportunity to review and consult on the proposed construction methods to minimize the sedimentation to Lake Huron;

4. Request to be notified of the status of all approvals including, but not limited to, the MOE's Environmental Compliance Approvals, the Maitland Valley Conservation Authority's Permit for Development, Interference with Wetlands and Alterations to Shorelines and Watercourse Regulations and Transport Canada's approvals (Navigable Water Protection Act); and

5. Request that the HSM be notified of any archaeological findings during construction.

6. Request that HSM be regularly informed of the projects progress and details to confirm that the construction details of the wharf expansion do not differ from the twin-sUp option parameters evaluated In the STIA and the EA.

1

HSM staff and Council would like to express their appreciation to the Goderich Harbour Wharf Expansion Project team including the God erich Port Management Corporation and their consultants LGL Limited and B.M Ross and Associates Ltd. for working with HSM to make this review possible. HSM Council is better able to understand the project and any environmental effects associated with it due to the consultation with the project team and the peer review work completed my Darryl M. Robins Consulting Inc. HSM Council looks forward to keeping up to date with the God erich Wharf Expansion project as it progresses.

If you have and questions of concerns regarding the review or the requests please contact HSM's Lands and Resources Consultation Coordinator, Audrey Holden at [email protected] or 519-483-4001.

Yours very truly,

Archie Indoe, Acting President Historic Saugeen Metis

Attachments-2 Preliminary Review of the Environmental Assessment Documentation for the Goderich Wharf Expansion Project And Review of Sediment Transport Impact Assessment Report (Appendix F) Preliminary Review of the Environmental Assessment Documentation God erich Wharf Expansion Project.

2

DARRYL M. RoBINS CoNSULTING INc. CIVIL & ENVIRONMENTAL ENGINEERING

M14006

March 14, 2014

Historic Saugeen M6tis 204 High Street, Box 1492 Southampton, Ontario NOH 2LO

Attention: President Archie In doe

Re: Preliminary Review of the Environmental Assessment Documentation for the Goderlch Wharf Expansion Project Historic Saugean Metis

Dear President lndoe:

We have been retained by the Historic Saugeen Metis (HSM) to review the Environmental Assessment documentation for the Goderich Wharf Expansion Project. We have completed a preliminary review of the EA report. Please note that this did not Include a review of all the technical appendi~es or the complete Record of Consultation. We have only completed a review of the consultation records that pertained to the HSM. We respectfully request direction to proceed with the review of the Technical appendices. It was expected that completing a review of the EA Report would be sufficient to prepare a summary report and only review the technical reports that were relevant to the HSM's concerns (if required). A detailed report would be completed If required, following the review of the applicable technical appendices and/or other reports as required.

We understand that the HSM have been residents of the Lake Huron I Georgian Bay shoreline for the last 200 years and want to maintain healthy aquatic systems in their territory. The basis and focus of our review Is guided by these facts.

Purpose of the Proposed Project:

The Town of Goderich owns the harbour, but the Goderich Port Management Corporation (GPMC) manages the port facilities. The Port of Goderich is the only deep water port on the eastern shore of Lake Huron. The EA report Identifies that there Is currently insufficient storage for existing users and no storage available for future users of the port. The port is also noted as sometimes being exposed to adverse lake conditions. GPMC Is proposing the Wharf Expansion project to:

a) Provide stable loading /off-loading and on-shore storage areas; b) Provide greater shelter within the harbour, and

4844 HrGHWAY No. 6, M1L1.ER l.AI<E, ONTARIO, NOH 1 ZO EMAIL: [email protected]

T~HONE:519-795-7094 FAX:519-795-7094

Tou. FREE 1-Bn-795-7094

Historic Saugeen Metis Peer Review- Goderfch Wharf Expansion Project

c) Improve the North Harbour Road If necessary.

Summary of the Environmental Aaseasmant (EA) Report:

M14006 Pg.2

GPMC Initiated the project to address concerns relating to Insufficient storage space, to provide better shelter and to Improve the North Harbour Road (If necessary). The Terms of Reference of the EA were Initiated In May 2009 and approved by the Ministry of the Environment In February 2011. Seven (7) options were reviewed In the Term of Reference to resolve the above noted concerns. Option Number 7 was selected as the 'preferred option' and this option was to expand the wharf facilities at the Goderlch Harbour.

The EA focused on alternative methods of carrying out the proposed undertaking Including reviewing alternative wharf sites and alternative wharf designs. A qualitative evaluation was completed to select the preferred alternative which was a twin-slip design In the area encompassing the north rlverwall, the north breakwater and the existing wharf.

The above noted option had the smallest footprint and as such, would have the least Impact on fish and fish habitat. This option required the least amount of fill, which would minimize the project cost. It would provide addHional protection for ships and provide more docking space.

The traffic assessment Identified that no improvements were warranted for the North Harbour Road.

Salt, aggregates and machine parts will be stored on the expanded wharf. No new structures are proposed on the wharf to maximize flexibility. Salt must be covered at all times, except when loading or unloading salt.

The proposed option does result in the loss 7.67ha of fish habita~ with 6.75ha considered to be permanent Mitigation measures are identified in the EA Report to mitigate the loss of fish and fish habitat. A Fish Compensation Strategy is also proposed to achieve •no net loss• of the productive capacity of fish habitat. This strategy was prepared In consultation with Rrst Nations communities. It was noted during the review that the HSM was not involved In the discussions regarding the Flsh Compensation Strategy.

It is understood that the HSM was consulted throughout this project, Including the preparation of the Terms of Reference and the EA Report.

Status of the Environmental Assessment:

The Environmental Study Report Is available for pubUc review until April11, 2014.

DARRYL M. RoBINS CoNSULTING INc.

Historic Saugeen M#Jtls Peer Review- Goderlch Wharf Expansion Project

Concerns with tha Project:

M14006 Pg. 3

The HSM have rights to harvest resources along the Lake Huron shoreline. We understand that the HSM would have the following concerns regarding this proJect:

1. Loss of Fish & Flah Habitat The proposed project will result in the loss of fish and fish habnat. It Is noted In the EA report that the Goderich Harbour Is not an environment that supports fish habitat due to the high boat traffic. GPMC are proposing mitigation measures to minimize any losses. In addition, a fish compensation plan Is proposed. The fish compensation plan wiD result In 6.00ha of new or restored habitat

2. Archeological & Heritage Reports It Is understood from the EA report that the HSM have reviewed the Natural Heritage Report, the Cultural Heritage Report and the Archaeological Assessment Report and no formal comments were provided by HSM.

3. lnflll & Sedimentation Controls The Wharf Expansion requires the placement of fill. Sedimentation In lake Huron would have an Impact on water quality, fish and fish habitat. The EA Report summarized the mitigation measures proposed for the In-water work. It is proposed that any fill for the proposed wharf expansion from areas of unknown origin will be tested. Contaminated material will not be accepted for the proposed wharf expansion. The turbidity of the water will be monitored during construction. The construction methods will be finalized when the contractor is selected following the tendering process. It is recommended that the HSM request an opportunity to review and consult with respect to the construction methods to minimize the impacts of sedimentation to Lake Huron.

We recommend completing a review of the Sediment Transport Impact Assessment (Including the addendum) to verify the Impacts of sedimentation on Lake Huron.

4. Stormwatar Management A collection and containment system will be designed to collect and hold stormwater. Salt stored on the wharf must be covered at all times. The salt would be covered with tarps. Two (2) stormwater collection systems will be designed and constructed. The exterior collection system will be a series of catchbaslns and storm sewers around the perimeter of the area Intended to catch surface water off the tarps. This stormwater should have low salinity and would discharge directly to the lake. The Interior coUection system will be comprised of catchbasins and stcnn sewers In the centre area of the wharf. The paved asphalt surface will be graded towards the centre area. The collection system will be designed to capture and store the saline stormwater. This stonnwater would be reused in the mining process or diluted at an approved rate. The stonnwater management design (report) will be

DARRYL M. RooiNs CoNSULTING INc.

Historic Saugeen Metis M14006 Peer Review- Goderich Wharf Expansion Project Pg. 4

prepared during the detailed design. We suggest that It be reviewed by the HSM when It has been completed.

5. Risk of Contamination The Phase 1 Environmental Site Assessment Identified that there was potential for contamination (present & historic) by Slfto, from fuel storage and dispensing, laboratory and chemical analysis, salt storage and handling, motor vehicle operations and maintenance, port activities and Importing fill material of unknown quality. The EA report identified that the sources and extent are typical for an active Industrial port facility and based on the historical use of the harbour, there was nothing to Indicate concerns regarding the mobilization of unacceptable contaminants. A Phase 2 ESA was not recommended. The MOE did not Identify any additional concerns. It Is proposed that any fill for the proposed wharf expansion from areas of unknown origin will be tested. Contaminated material will not be accepted for the proposed wharf expansion.

6. Air Quatrty An air quality assessment was completed as part of the EA. The results of the analysis Identified In the EA report Indicated that the dally average concentration was less than 101Jg/m3 and It did not exceed the criteria level of 301Jg/m3. A GRIMM 164 monitor will continue to monltor·the air quality during construction and post construction. A 'GRIMM 164 monitor' monitors the particulate matter and ambient weather conditions In the study area.

Recommendations

1. Complete a more detailed review of the Sedimentation Transport Impact Assessment (Including the addendum);

2. Request an opportunity to review the stormwater management report I design; 3. Request an opportunity to review the 'For Tender Drawings' to ensure that sediment control

measures are In place to minimize the risk of sediment entering Lake Huron; 4. Request an opportunity to review and consult on the proposed construction methods to minimize

the sedimentation to Lake Huron; 5. Request to be notified of the status of all approvals Including, but not limited to, the MOE's

Environmental Compliance Approval, the Maitland Valley Conservation Authority's Permit for the Development, Interference with WeUands and Alterations to Shorelines and Watercourse Regulation and Transport Canada's approval (Navigable Water Protection Act); and

6. Request that the HSM be notified of any archaeological findings during construction.

We respectfully request direction to complete a more detailed review of the Sedimentation Transport Impact Assessment (Including the addendum) and the Stormwater Management Report (when it has been completed), as it would have an effect on water quality.

DARRYL M. RoBINS CoNsULTING INc.

Historic Saugeen Metis Peer Review- Goderich Wharf Expansion ProJect

If you should have any questions, please do not hesitate to contact us.

Yours truly,

DARRYL M. ROBINS CONSULTING INC.

Laura Swanson, P.Eng. Vica.PresidenUSecretary Civ!J.Envlronmental Engineer

M14006 Pg.5

(llhp8200-1\userslpublk:ldocumentsldmn: mailldmrc • pro)ects\20141M140061!oclerich wharf expanslon'=rrespondencellellll3\11Sm man::h 14, 2014.doc

DARRYL M. RoBINS CoNsULTING INc.

DARRYL M. RoBINS CoNSULTING INc. CML & ENVIRONMENTAL ENGINEERING

M14006

April7, 2014

Historic Saugeen Metis 204 High Street, Box 1492 Southampton, Ontario NOH 2LO

Attention: President Archie lndoe

Re: Review of Sediment Transport Impact Assessment Report (Appendix F) Preliminary Review of the Environmental Assessment Documentation Goderlch Wharf Expansion Project Goderfch, ON

Dear President lndoe:

We have been retained by the Historic Saugeen Metis (HSM) to review the Environmental Assessment documentation for the Goderich Wharf Expansion Project. We have previously completed a preliminary review of the EA report and the results of that review were summarized In a letter to the HSM dated March 14, 2014 from our finn. A recommendation of the above letter was to review the Sediment Transport Impact Assessment (STIA} Report {Appendix F) dated August 2012, of the respective EA. The HSM provided direction to Danyt M. Robins Consulting Inc. (DMRC) to review Appendix F and the following letter summarizes the results of our review.

We understand that the HSM have been residents of the Lake H,uron I Georgian Bay shoreline for the last 200 years and want to maintain healthy aquatic systems In their tenitary. The basis and focus of our review Is guided by these facts.

Summary of the Sediment Transport Impact Assessment Report:

The purpose of the STIA was to address the potential Impacts that the wharf design alternatives would have on the sediment transport regime of the local coastal areas.

It was noted that the existing features of the Goderfch Harbour, as a whole, Is a historical obstruction to the coastal process of the Lake Huron shoreline, but due to the harbou~s age, the littoral regime has already responded and adapted to the harbour.

4844 HIGHWAY No. 6, Mlll.fA LAKE, ONTARIO, NOH 1 ZO EMAit.: [email protected]

TB.EPHONE 519-795-7094 FAX: 519-795-7094

Tau. FREE 1-877-795-7094

Historic Saugeen Metis Peer Review- God erich Wharf Expansion Project Sediment Transport Impact Analysis

M14006

Pg.2

The STIA included computer modeling of the sediment transport processes of the different design alternatives for the wharf expansion Included In the EA. The purpose of the computer modeling was to detennlne n the proposed works would cause any change to the long-tenn morphollc evolution, not to model actual long-term sediment transport results. The modeling Inputs In summary considered the bathymetry (including high and low lake levels of the lake and MaiUand River), wave and storm cUmate, sediment size and nature, and the physical features of the proposed design alternatives. Littoral drift processes are primarily affected during periods of significant wave action, thus the condiUons of the 11n 50 year stonn event was used to simulate the situation for potential sediment transport In the modeling. In the wrlte~s opinion, the modeling approach, assumptions and Inputs appeared to be reasonable for the preferred twin-slip wharf expansion option. It should be noted that the twin-slip optl.on Is within the limits of an area already delineated by existing breakwall structures.

The impact assessment noted that there would be no Impact or change in shoreline processes to the north of the Goderfch wharf area since the littoral drift direction Is from north to south. The modeling concluded that there were would be no noticeable differences In sediment transport rates or lakebed elevaUons due to the twin-slip alternative beyond the Immediate area where the twin-slip alternative would be constructed. The STIA report also Indicated that the results of the respective study are consistent with previous studies which found little sensitivity to littoral transport rates for proposed modifications within the harbour.

An appendix to the STIA report was Issued by the original consultant to address comments provided by the technical reviewers for the Saugeen Ojibway Nation (SON). These comments were basically focused on clarification of the modelling parameters and clarifications that the modeling was to determine if a change in sediment transport would occur. not a detailed examination of future morphological changes. No changes. to the original report or modelling were required for.the preferred twin-slip wharf expansion.

Status of the Environmental Assessment:

The Environmental Study Report Is available for public review until April11. 2014.

Concerns with the Project:

The purpose of the STIA was to determine if the implementation of the proposed alternatives for the wharf expansion would have a significant Impact on the processes of sediment transport In the area. The results of the STIA as ouHined in the report and addendum Indicate that the Implementation of lhe twin-slip option would n'ot Impose any long-term significant changes on the processes of ~edlment transport in the area and thus no morphological changes would occur that would potentially endanger the HSM's interests and concerns for natural coastal resources.

DARRYL M. RosiNs CoNSULTING INc.

c::arl-------------------------' .

Historic Saugeen Metis M14006 Peer Review- Goderfch Wharf Expansion Project Sediment Transport Impact Analysis Pg. 3

It Is Important to note that the purpose of the STIA was to address potential long term coastal morphological changes for the project, but not specific sediment control that should be addressed for the construction and operation of the completed facilities. These speclflc sediment control measures will be part of the project's construction sediment/erosion control plan and stormwater management design. DMRC's correspondence of March 14, 2014 to the HSM provided spaciflc recommendations In this regard.

Recommendations

Our recommendation In regard to the STIA for this project, Is for the HSM to request to be regularly Informed of the project's progress and detans to confirm that the a~tual construction details of the wharf expansion do not differ from the twin-snp option parameters evaluated In the STIA and the EA.

If you should have any questions, please do not hesitate to contact us.

Yours truly,

DARRYL M. ROBINS CONSULTING INC.

~~~ Darryl M. Robins, P.Eng. PresldenVTreasurer Civil-Environmental Engineer Designated Consulting Engineer

DMR/br

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DARRYL M. RosiNs CoNSULTING INc.

. _,

04/~~/2014 Pat 18120 PAJ ~11111/VO::!

Walpole Island First Nation Council of Three Fires

WALPOLE ISLAND HERITAGE CENTRE

FROM:

DATE: _...~..lf.~/"L::::.lllf":....-__ ___._. =-20=1~

FAXNO.:_j 'iJ,6L3..!!L- f!i:rs-1.-

SUBmCT:~~~~~~~~~==~~~~~~~==~~~

CO~DMENTS: ________________________________________ 1

SHOULD THERE BE AMY PROBLEMS RECEIVING THE FULL TRANSMISSION PLEASE PHONE (619) 627-1475 AND ASK FOR u-~" ""~

1Kill FACII&MJll! 1!1 DIBR1VIIN IDIIDENCf taf.S.llQ 1BE I'£IISIIi JNI!D ADtft'f. .liiiJ 'I!/Ali'4GT ODREBMlll! Ill! IIUmUJMIII, cafi!D OR I!JICIIISED. 11 \'GV !lAW ~IMO

UIIS fACBIMIUIIN EBIDI, I"Wft l'tGIIfY W MIEIIIDU'I.

R. R. 3 • Wallaceburg • Ontario • NBA 41<9 • Phone: (519) 627-1475 • Fax: (519) 627-1630 Walpole Island Heritage Ceutre NIN • DA • W ~ • nG

04/2!12014 PRI llt~O PAl

April23, 1014

Andrew Eve11

........... -......JWANONG TERRITO Y

The Council ofThree Fires

Project omcer- Envlronmentul Assessment sa.vlces Ministry of the Environment 2 St. Clair Ave. W Floor 1lA

. Toronto, ON M4V 1LS

Dear Mr. Evers,

"""' .. , """

Walpole Island First Natfan has port!dpated In the consultrtlon process for tha Goderich Horbor E~rpansfon project Fofover two years, The God erich Port Management Cooperation along with their

· cansultantr, LGl, has been very receptive In lncludlns concams and faadback from WIFN whle contemplating lhls project. WIFN's main c:anc::em has been wlth the fisheries compensation ploln. GPMC worked with WIFN to develop a compensation project at swan Lake mllnh In caopat'atlan with the Walpolalsland Land Trust. Enclosed Is a letter of support from Chlaf Burton ICewaycstl far compensation plan that Includes this pro(ect a Ions with proposal! ta Increase 5tUf'IJeon habitat In the Huron·Erle

·corridor. We look forward to continuing aur mutuallv beneftdal relationship wllh GPMC lor manv years to came. ·

Sincerely,

' ' c.e. Rowland Howe, Pnuldent. Godc:rlch Port Manasemant Corporation

lUL #3t WALPOIEmAND, ONTARI NB.\ 'flU

Tlfl.1 (519) &UM181 PAXa (!lf) 07-IH.fO

!J

04/:15/2014 PlU Uall PAX

The Council of Three Fires

cr:tabera, zou

Dave Gibson, Fish Habflat Blalaslst Dtpatti'IU!nt of Flllharfel IIJid Oceans canada Southern Dtsa1ct, Ontario-Great LakU Anll 904-3017 HaM!Jtar Rolnl Butltnatan. Ontario L7R 41C3

Dear Dave Gibson.

'n!a Walpola'lsland FJm Nation fUitV !Upports tlla ent:IO!IId prop.o$11 R!&ardlng "lmprovlns Fish Habllat at swan Lake Morth• as sutnnluad by the Wolpola Island Hllftase Centre.

lhiS proJect resulted fram over a vaar af c:ansultatlons bel wean Walpale ltliVId First Nation and Goderfdl Port Minaaement Ccrporatfan.

I

Wo would like Ia see lite flsh habitat ccmpensatlan plan Implemented as sa on as possible.

We 11nt uba suppart.lva of AamJiwnaafll(s prgpasals tD lnmaH Sturaoon habitat In tho Huran·Erle Corridor. As ~:turaean·are historically and cultural IV af araat Importance Ia aur Rrst Nations.

· vaur~ sincerely,

V;k~ Burton Jtewavash Ctlef

c.c:. Raw land Howe, Pre.sldent, God erich Pan: Manapmerrt Ccrparatlan Joe cavallo, Senlar Flsharfu BloiDSist, LGL Umlted

R.R. 13, WALPOLE ISLAND, ONTARJONBA41C9 • T8L: (519) 621·1481 • PAX: (519) 627·04.40

Gl/~5/2014 PRI 16130 PAX

PROPOSAL Improving fbb Habitat at Swa Lake Manh

011 Che WaJpoleiiiJaad Firat Nalfoo

October B, 2013

Blstol')' Swan Laka Mmtl fa a. 171 acre dybd-fn coastal wetland (see reference maps) localed on SL A.ane Walld, Walpole .bland Pint Nation. ll is located wi1hln Lwo major tlywaya (the Atlantic; and Misalssippi fiywayala southwest Ontado)i Is part ofa core Jmbf.tat within SL Clair ruvcrArCQ of Concem RAP Area lA; and is UnGd to tho .Eastcm Lako St. Clatr Important Bird Area. Thtt D1IJ'Sb. bas a long hlstary ofbcinglcasc:d by bunt olubs far watcrfi:JwVSIIIIlB bird Jumdus and hu clumged banda mOlly times over tho put few decades. tD more recent years, thls mmhhu bec:n under pres aura .liom Phraprltu eac:roachment and lnfestatfcms, dccUnlns water levels, and loss of wctlaD.d-onocioted fish llBd wild lUi: apecles. SWill Lake Mamh waa deemed one af the lcost bio-dlvasa of Walpole lslond FJrstNadoa's Wdlaadllln 1111 aqwuJc colllD11Ulltks study.

In tDJtlng to ronm:r JMDAgen ami community ruourcc-use:rs -the ibUowtag Is a list of 6sb that used to bo found In the Swan Lab Marsh or rlSilspe.cicalhat will beftefit fiam its tehublli1atlaa: Orass Pickerel BIDCJc Bullh=l Pumpltinael=d Black. Crappla Commoa Cmp Perch Bluagtll CJwmcl Darter Spottail Sbhlcr Rock Bw Smallmauth Bw Whlto Sucker Sunfish Largemouth Bw

Keep in mind tho Swua Lake Manh used to be mon: opc11 with larger open ponds. Rc:ccnt sampling in August of this year with the Roynl Ontario Museum (BrUns Holm) and DFO (Dm: Glbsgn and Oaw Balint) bas conthmed 1he presence ofyouna-of-~year Grass Pickerel (Era.r amtrlCttrnu WI'IJ'Iicultllrll) a pnnincial and fedc:alspcaics ofSpcoild Coaccm as well IL!I Larpmaush Bw (Micropteru.r .ralmofdu), a sportfisb species, aad other baltft!h species. These specica hava cultural, educational and rccn:ulional valuo to WIPN.

Llko the other "waob$bkoldin" marshes on Walpole lslacd rmt Notloa, Sw~~n Lob Manb bas a c:ulturallmportMca that Ia linked to the Finrt Nations people In many ways, Swaa Labs Matsh has been used as a resource that bas pmvided communlty members with .faad (lbh. muskmta, duck!. eta.), medicines, c:mftlns DWetiAla, re:reatlon. and Ills & plw! of spiritual conrw:tlan. Jt wu cvca rafcaed lO as a .. grocery store" by some community Bidets who hAve pii!Scd on. Thfs cultural coPDGCtion wiU bo rekindled aa we: educate youth and bring them tosadu:r with Elden and community members to help them to leJU'Illlbout wetland consmvarion and n:stol'lllion, ethlcallumtina pract!cu, survival tedmiqw:s.IJmsuase & srorics, c:WturaJ teachJna5, eta,

BaclqJroand OD the ProJect (a 2009, the Walpole lllland Lend Tru.s~ Jn cooperation with community partDCrB ond with suppan from local and aatioDal groups, catered intu a 1 D-1ear conservation lcasfna 11m111gcmcnt (2009-lO 19) with the~ Wlllpole Ishmd Fast Nadon, which set iD motion 4 vision to improve the ovc:aU health, ftlnlldoa, DDd biodlvcnity of this degraded mmh.

Wltb COUiributitmS from additianal funding partDcrs and support from volunteets, the Walpole Csland La.nd Tnzsl and lhc Walpole Island Hc:rltqc Ccnue canied out habitat uses.unenls and

Walpole Island Herlrasa Centre, CRJ 1

II u

04/~5/2014 PRZ 16120 ~AX

October 8, 2013

fish & wildlife surveys 1D begin to gather baseline data to aid In developing llllliUlli.Fmcnt 1!t. restoration planlhat will sufde reatoratloa activiUes at SWIID Lake Marsh.

lsllues aad Cballcllps Swun tllke Marsh experiences dramatic seasonal chrmgcs Jn water levels lhat drop up to ll inches from spring to fall, which results in wmner water tem.penmues. 'Ibls WlltDili1g may limit tlm apcclcs of:flsh that can survive in this mmh. Pish access IU1d water .recharge and dlscharae to this marsh are rastdl:ted by the dykes that 5UI%0und tbia nslatiwly IIIDDil JDIII'Sb.

Objedlves to Improve Fish Habitat • Cant!Dua 1111 ongoing dlologuo with 1he Walpole l'aland community to bw1d aud nudnlllin

BUpport IUid hrvolvement; • Conduct fish aempUng aunayr, • Pun:busc 11 portable Hood pump and use it to mufnlllin l11DI1Ih watar lavels within Swan Luko

Marsh (os an interim. JnCIIliUr'e);

• Ass• and implement options to enable coathwous watet !law in EUUI out ofthb dykcd~in wedand using IU1 altemadvc: c:ncrSY solution (u a 1oDQ-tenn meuute) and to maintldn water lave Is tbr a. heDlthy manh;

• Create habitat ror Grass Pickerel. 11 spccles ot risk and spor:ttish habitat within tha marsh interior that will contribute to increasing fish blodlvc:nlty;

• lmpJcmcalll01ians to lmprow Dlld sustain 1lsb bnbiiAt in Swllll Lake Marsh; and • Carry out angoins monitoring of fish within tha DWBh to evaluate effectiveness ofpl'tljcct

octlvftl.ca and atd adaptive m.aru~gemc:nt approochcs.

Beoeftb The benefits and results of this ptOject lnaluda;

Q Rchabllitatlan of fiah habitat and Improved tlaberla in the existiag canal • Creadon of 60 ha of fish habitat Dlld new sportfiaberlcs in the .marsh inb:rlar through

mdgins of deeper ponds' aad cbnnnels and ~~~-ns water levels o Water levels that are mainto.ined to support tho Ufa stuges offish and other wildlJ!e • Watk towards meeting Canod.ian RAP ImpJom.cntadan Commtttco Wodcphm for the St.

Clalr-Area af Coru:em

llJOO 9/005

• AbiUty to support wetlanll-woclaled fish and wildlife species and incml!cd t\mctl.oaallty of the wc:t1and

• Better undcrstDDdlng and documentation ofwetland species at the aitc, wbidt wiU aid In mnklns infilaned habi1at maDSgcmcnt d=isions

o Knowledge a; skills tranlfar and cnluuu:ed woddDg rchdf.anshlps IUllCUig.!t partners • The promotion and encourogenu:nt of ISUStainablo ftsblng ii:lr Wolpola Is1lmd Flnt No.tion

and the geneml public a Improved fi&h.lns accessibility for tba general public • Coascrvadan of fish spcoies at risk

Walpole Island Heritage centre, CRJ z

l

CHIEFS AND COUNCILS

SAUGEEN OJIBWAY NATION

Chippewas of Saugeen, RR 1, Southampton ON NOH 2LO 519-797-2781 Chippewas of Nawash, 135 Lakeshora Blvd, Neyaashiinlgmilng ON NOH 2TO

519-534-1689

Andrew Evers Ministry of Environment Environmental Approvals Branch 2 St. Clair Avenue West Toronto, Ontwio M4V 1L5 Via email: [email protected]

May 22, 2014

Dear Mr. Evers:

Re: Comments on the EA for the Goderich Harbour Wharf Expansion I

Thank you for the opportunity for the Saugeen Ojibway Nation (SON) 19 comment on the I!nvironmental Assessment package for the Goderich Port Management Corporation's (GPMC) proposed Wharf Expansion project.

The SON have been in communication with the GPMC, regarding this project. since 2012. As you may be aware, SON is concerned that the project has potential Aboriginal rights and Aboriginal land claims impacts, specifically with respect to our Aboriginal commerciul fishery in the area.

SON entered into an agreement with the OPMC in May 2013, that guaranteed that SON expert advisers had the opportunity to review a number of the technical expert reports prepared by GMPC for this project (a list of the reports which we reviewed is attached as an appendix). As a result of these review by our experts, the proponent made some modifications to the project. SON subsequently entered into a supplementary agreement with GPMC that guamnteed that GPMC will fund a stable isotope study, called the Study on tire Influence of the Goderich Harbour Wharf Expansion Project on the Structure and Function of the Adjacent Aquatic Ecosystems, as part of the environmental LtSsessment tor the Project in order to ensure a fulsome betbre-after, control-impact approach. This assists the proponent GPMC nnd SON in tracking (and. if necessary, later addressing) any harmful impacts on tish.

llur ~l\pcn .tJ\·i-;ol'l\ tlcLI h)' Dr. Neil Ruun\:'Y at the I ' nih~rsity uHiudph) ha\c subsequently reviewed the recently-posted Environmental Assessment Report. Jn the 'ic\\ nf 1111r cxpcrb, the rc~lnra liun dlilns and n:L'I' crcutiun plan'lpmpus~d .m: all approrriatc mitigation plans for the project. There arc small details which require additional resolution. regarding the proposed monitoring and fish compensation, but we trust that these small details can be addressed in the monitoring process.

We nrc satisfied, after our review, that a robust and appropriate environmental assessment process for the project is reflected in the Environmental Assessment Report.

If you have any questions about these comments, please teet free to contact me.

R~spectfully, r 0. q~--

Janna Chegahno Territorial Resources Coordinator Saugcen Ojibway Nation Environment Office

l'age 2 of4

-·

APPENDIX: LIST OF TECHNICAL REPORTS FOR GODERICH WHARF

EXPANSION REVIEWED BY SON EXPERTS

Title Date Prepared By

1. Traffic Report November 2012 Paradigm Transportation

' Solutions Ltd.

2. Natural Heritage Report December 2012 lGLUmited

3. Water and Sediment Quality: April2012 LGL Umlted Existing Conditions Report

4. Cultural Heritage Report December 27, Scarlett Janusas 2012 Archaeological Heritage

Consulting and Education

s. Archaeological Assessment Report July 21, 2012 Scarlett Janusas Archaeological Heritage Consulting and Education

6. Property Waste and Contamination December 2012 LGL limited Report (Phase 1 ESA)

7a. Preliminary Geotechnical Design August 2012 Golder Associates Ltd. Report

7b. Preliminary Geotechnical Design November2, Golder Associates Ltd. Report- Addendum Letter 2012

8. Sediment Transport Impact August 2012 Shoreplan Engineering Assessment Report Limited

9. Wave Climate Assessment and October 15, HCCI Coastal and River Evaluation of Alternatives Report 2012 Engineering, Water

Resources and Environmental Hydraulics

10. Marine Simulation Analysis Report May 16,2012 Great Lakes International Marine Training and Research Centre

11. Air Quality Assessment Report January 31, AJ. Chandler and 2013 Associates Ltd.

12. Noise and Vibration Assessment Pending J.E. Coulter Associates Report limited

l'agc J or4

APPENDIX C

SUPPLEMENTAL INFORMATION

TABLES

Goderich Wharf Expansion EA

1

Table 1: Government Review Team Comments Reviewer Comment Received Proponent’s Response Status Ministry of the Environment (Ministry)

Project Officer, Environmental Assessment Services

Section 1.0: Introduction and Background:

Under Section 1.3.1.2 of the Environmental Assessment (EA), it states that the EA contains information in accordance with s. 6.1(2) of the Environmental Assessment Act (EAA). Section 2.0 of the approved Terms of Reference (ToR) states that the EA will be completed in accordance with s. 6.1(3) of the EAA. Please confirm in accordance with which section of the EAA the EA is being completed, and if it is different from what is stated in the approved ToR, please provide justification for this change.

The EA was prepared in accordance with Section 6.1(3) of the EAA.

The Ministry is satisfied with this response.

Section 2.0: Consultation and Engagement:

In Section 8.2.5 of the approved ToR and Table 2-1 of the EA mention that the Study Team may elect to hold a fourth Public Information Centre (PIC). In Table 2-1 of the EA, it is mentioned that the Study Team elected not to hold the fourth PIC. Please provide justification for not holding the fourth PIC.

The study team decided that a fourth PIC was not necessary during the EA Phase. Two rounds of PIC were held during the EA Phase. The first PIC presented alternative options of the project and the second PIC presented the alternative designs of the project and the preferred design along with potential impacts and proposed mitigation measures. Therefore, it was concluded that the additional PIC will be more constructive if it were held during the Detail Design Phase of the project when more design details are available.


In Table 2-4 it is noted that Saugeen Ojibway Nation stated in a meeting held on September 6, 2012 that the proponent would need to demonstrate benefits to the local Aboriginal community. The Study Team’s response only notes funding and review of the technical documents, as well as a Memorandum of Understanding for the completion of an isotope analysis as part of the fish habitat compensation plan. Please

Please note that in Table 2-4 the Saugeen Ojibway Nation has noted that the benefits could include revenue sharing, employment opportunities, or environmental monitoring work. Please note that the same reference is also found in Page 2-90 of the EA Report. As noted, funding and a Memorandum of Understanding for the isotope analysis are benefits that the Saugeen Ojibway Nation has identified to the study team. Please note that Saugeen Ojibway Nation has actively participated during the course of the project and attended several meetings with the



2

Table 1: Government Review Team Comments Reviewer Comment Received Proponent’s Response Status

explain what the benefits are to Aboriginal communities and where this explanation or assessment can be found in the EA Report.

study team (see Section 2.2.3.1 of the EA Report). The study team also attended two public meetings hosted by Saugeen Ojibway Nation within their communities. During that time, they have had opportunities to present their comments and the study team has worked to address Saugeen Ojibway Nation’s requirements. The Saugeen Ojibway Nation has not indicated any opposition to the project.

In Section 2.2.3.1 it mentions that the Study Team attended two Community Information Sessions on February 20 and 21, 2014 with Saugeen First Nation and Nawash First Nation, respectively. Please provide details of this meeting including the materials distributed, comments/concerns from these Aboriginal communities and how they were addressed and if there are any outstanding concerns.

A copy of the public notice for the meeting issued by Saugeen Ojibway Nation and the display materials are provided. Participants did not convey any issues/concerns to the study team. The study team was commended by Saugeen Ojibway Nation representatives for engaging Saugeen Ojibway Nation in the planning of the project, for providing participant funding for technical reviews and for agreeing to fund the stable isotope study. To the best of our knowledge, there are no outstanding concerns for Saugeen Ojibway Nation.


Section 2.3 of the EA notes that a workshop was held on August 29, 2012 with Fisheries and Oceans Canada (DFO), Ministry of Natural Resources (MNR), Maitland Valley Conservation Authority (MVCA) and Town of Goderich staff to discuss strategies for the loss of fish habitat due to the wharf expansion. Please confirm if Aboriginal communities were invited to this workshop or informed of the content presented at this workshop, and if not, please justify. In addition, please note where in the Record of Consultation (RoC), meeting minutes, materials and correspondence can be found regarding the workshop.

Aboriginal communities were not invited to this workshop as the focus was to obtain information associated with regulatory requirements of the project. This workshop was a brainstorming meeting to discuss fisheries issues. Please note that subsequent meetings regarding fisheries issues were held with Aboriginal communities. Minutes of the August 29, 2012 workshop are attached.


In the memorandum dated December 10, 2013 from the Ministry providing comments

As stated in Section 7.3, page 7-5, of the EA Report: “On-going consultation with Aboriginal communities will be

The Ministry is satisfied with


3


on the Draft EA, it was requested that 2.3.1 provide a summary of next steps in consultation, including consultation with Aboriginal communities. Currently it is still unclear what the next steps will be in consulting with Aboriginal communities during project design and in finalizing the fish habitat compensation plan, as well as any other outstanding concerns. Please provide the plan of next steps for consultation (i.e., PIC during project design as mentioned in Section 7.0).

carried out to refine and advance the fish habitat compensation agreement. The study team will also seek input from Aboriginal communities on the Environmental Management Plan (EMP). An in-person meeting with local Aboriginal communities will be held during detail design similar to the five meetings that were held during the EA. The study team will meet with other Aboriginal communities, as requested, during detail design.”

this response.

Please confirm that representatives from the Ministry’s Drinking Water Inspection Program were added to the stakeholder list as mentioned in Section 5.3.1 of the approved ToR.

During the EA phase of the study, while trying to establish a contact with the Ministry Of the Environment’s (MOE) Drinking Water Inspection Program, the study team was instead directed to two other contacts. Mr. Jack Colonnello, Agricultural Environmental Officer, MOE London District and Dr. Todd Howell, Great Lakes Ecologist, MOE Great Lakes Monitoring Unit. These individuals were contacted to confirm MOE monitoring stations in the vicinity of Goderich and to assist with establishing LGL Limited’s monitoring stations for the benthic and water quality analysis undertaken during the EA. No further contact with the Ministry’s Drinking Water Inspection program was considered warranted.


Section 3.0: Summary of the Existing Environment:

Section 5.1 of the approved ToR provides a brief explanation of the primary and secondary study areas. The overall study area is not described in Section 3.0 of the EA so it is unclear if the study areas changed in the EA from those described in the approved

The primary and secondary study areas referenced in the ToR remained unchanged for the environmental assessment phase of the project. The environmental components referenced in Section 3.0 of the EA all considered the same primary and secondary study areas referenced in the ToR. Evaluation of alternatives and environmental impacts on each environmental component considered the primary and secondary study areas. The study area identified in Figure 3 of the ToR remains valid.



4


ToR. Some of the environmental component study areas are described for each discipline in Section 3.0; however, in some cases no study area is presented (i.e., bedrock geology, noise). According to Section 4.2.3 of the Code of Practice: Preparing and Reviewing Environmental Assessments in Ontario (CoP), the boundaries of the overall study area, study area for the alternatives and study areas for the environmental components must be clearly described. Please provide descriptions of the overall study area, the evaluation of alternatives and the study areas for those environmental components not provided in Section 3.0 of the EA. If the overall study area is different from the one described in the approved ToR, please note these differences. Currently, it is unclear if the description of the existing environment and the effects assessment have been completed within the boundaries of all of the defined environmental component study areas. In addition, please provide a figure of the overall study area. Please indicate which sources were used to complete the secondary source investigation on Physiographic in Section 3.1.1.

Two secondary sources were reviewed to complete the Physiography section. The first is provided in Section 3.1.1 Physiography – Results, second paragraph: Golder Associates Limited. 2012. Preliminary Geotechnical Design Report – Proposed North Wharf Expansion, Goderich, Ontario. Prepared for B.M. Ross and Associates Limited. The second reference was inadvertently omitted from the Results section: Lower Maitland Stewardship Group (LMSG). 2006. Lower Maitland Report – 2006



5


www.lmsg.huronstewardship.on.ca/images/stories/maitland_report.pdf

Section 4.0: Identification of Alternatives and Evaluation Process:

Consultation on the alternative designs, method for evaluation and preferred design was completed during PIC #3, as indicated in Appendix H of the RoC. Please note if any comments were received specifically on the alternative designs and evaluation method, and if any modifications to the methods evaluation were implemented based on these comments (i.e., weightings). Section 4.2.1 identifies that the “orange” and “red” sites were carried forward as the preferred locations for the wharf expansion. These designs were then presented at PIC #2 for discussion. Section 4 does not indicate how the decision was made to select the red site over the orange site for the wharf expansion. Was it based solely on the results of PIC #2? In Section 6.1.2 of the approved ToR, it mentions that criteria and indicators will be developed to compare alternative methods with respect to: - Potential environmental effects; - Impact management measures; - Net effects; and - Advantages and disadvantages of the alternative method. In Section 4.2.2 of the EA, Step 2, it notes

No comments were received on the evaluation criteria, weightings, methods or results at PIC #3. The technically preferred alternative, the twin-slip option, has never been challenged by the public, external agencies or First Nations. The “red” and “yellow” sites were combined to create an “orange” site. The “orange” site was carried forward to Stage 2 (alternative wharf designs) and all three wharf design alternatives were generated within the “orange” site. The “yellow” site did not achieve the wharf expansion objectives on its own, while the “red” site did achieve the wharf expansion objectives on its own, so the “red” site was also carried forward. However, when the “red” and “yellow” sites were combined, the “orange” site was technically preferred to the “red” site on its own. The evaluation of alternative wharf sites was not based on a net effects assessment. This evaluation was based on how well each of the wharf sites met the objectives listed in Table 4-1. This approach was considered reasonable and sufficient to arrive at a technically preferred site for wharf expansion. The rationale for this change from the ToR is presented on p. 4-3. The evaluation of alternative wharf designs was based on net environmental effects. Impact management measures were incorporated into the wharf design options where practical and feasible as described in Section 5. In many cases, the impact management measures were identical and inherent for all three wharf design options; therefore, this aspect was not considered decision relevant. The design and cost considerations were taken into account during the evaluation by identifying criteria and indicators to account for these attributes/trade-offs. The design and



6


that the original criteria were selected entirely based on environmental considerations, not on technical and cost considerations. Please explain how impact management measures, net effects and advantages and disadvantages were considered in selecting the criteria and indicators and subsequently used to compare the alternative methods for wharf sites and designs. If the alternative method evaluation was altered from what is provided in Section 6.1.2 of the approved ToR, please provide rationale for the change. Section 6.1.2 of the approved ToR mentions that a sensitivity analysis would be completed on the results of the evaluation methods. The results of this sensitivity analysis do not seem to be presented in Section 4.0 of the EA. Please comment on how the criteria weights influenced overall decision making and the selection of the preferred wharf design. Table 4-4 in the EA provides the information used to complete the evaluation of alternative methods for wharf designs. Table 4-5 provides the weights and rationale for the criteria and indicators used to evaluate the alternative wharf designs. From here it is unclear how the results were determined in Figure 4-5. Please provide a table that shows what each wharf design scored according to each indicator that summed to the results provided in Figure 4-5 (i.e., what was the score for each indicator to sum to 67 for the twin slip option). Section 4.2.4: Assessment and Evaluation in

cost considerations were also assigned a weight to account for their level of importance in decision making. The advantages and disadvantages of the wharf design options were reviewed to ensure that the VISA model was outputting defensible results. The advantages of the twin-slip option are described on p. 4-35. Sensitivity tests were performed using the VISA software. The weights of several factor groups (i.e. natural environment, cultural environment, technical and cost, socio-economic environment) were modified to gain an understanding of how the level of importance assigned to each factor group influenced the results of the analysis. Weights were not tested at the criteria or indicator level of analysis because many of the criteria and indicators were not able to distinguish significant differences among the wharf design options. The criteria and indicators that were able to make a distinction among wharf design options were assigned a greater weight to increase the “spread” for the base case. The weight assigned to each factor group was increased progressively to isolate the factor group to gain an understanding as to which factor groups played the biggest role in decision making and how the weightings affected the selection of the twin slip option. The sensitivity tests indicated that under all practical weighting scenarios, the twin slip option had the highest overall score. The VISA software carries out the calculation using a built-in algorithm. The software does not provide a function for printing out these interim calculations, only the data, weights and resulting overall scores. The advantages and disadvantages for each alternative wharf site are presented in Table 4-1. A summary of the relative advantages and disadvantages for each


7


the CoP indicates that the proponent must determine and clearly articulate the rationale for choosing the preferred alternative, taking into account relative advantages and disadvantages. In Section 4.2.2 a list of advantages for the twin slip option is provided and advantages and disadvantages of the preferred undertaking are provided in Section 6.5.5. Although advantages and disadvantages of the undertaking are provided for the preferred undertaking, these are not explained relative to the other alternative methods (i.e., no slip and single slip alternatives). Please provide a summary of the advantages and disadvantages for each of the alternative methods of wharf sites and wharf designs evaluated in Section 4.0. In Section 4.2 of the approved ToR, it mentions that alternative methods also consider construction methods. Although no formal alternative methods evaluation was completed on construction methods, an informal evaluation was described in Section 5.1.3 of the EA. Please confirm that when considering the construction methods to be used for the wharf expansion, environmental effects, impact management measures, net effects and advantages and disadvantages will be considered in choosing the preferred construction method, and described the evaluation method that will be used for selecting the preferred construction methods. In addition, please confirm that the construction methods being considered, and subsequently the preferred construction method is consulted on during a PIC at the

alternative wharf design is attached. The anticipated construction method is described in Section 5.1.3 of the EA. This construction method represents a reasonable and practical scenario for the purposes of conducting a net environmental effects assessment. However, each construction company will propose their own construction methods in an attempt to be innovative and to gain a technical and economic advantage over their competitors during the competitive bid process. At that stage, the study team will review contractor proposals to ensure that the proposals are in line with environmental requirements including legislation, permits/approvals, EA commitments and EA conditions of approval. Proposals that do not meet these environmental requirements will be deemed non-responsive and/or the bidders will be provided the opportunity to revise their proposals to demonstrate how the environmental requirements will be met. The preferred construction method will be consulted on during the PIC to be held during the detail design phase, during meetings with regulatory agencies and First Nations, and during preparation of the EMP as committed to in Section 7.3.


8


project design phase, as indicated in Section 7.3 of the EA.

Section 5.0: Project Description:

Please provide a sequential schedule of construction activities to be completed within the construction schedule of 26 months provided in Section 5.1.4. Will any of these construction activities be weather/seasonally dependent? If so, please explain.

The attached schedule of construction activities is an opinion based on probable order of work activities for this project. Each construction company will have their own schedule based on their abilities and resources which will influence the work activities. At times, multiple activities could be occurring in different areas of the site. Many construction activities will be affected by cold weather and ice conditions but in most cases this will only affect methods. The only activity unlikely to proceed in winter conditions is the compaction of fill above water level. Water-based activities such as placement of rock revetments or barge-based pile driving will be affected by daily wind and wave conditions.


Section 5.1.5: Operation and Maintenance provides a description of operation activities to be completed. However, maintenance activities are not described until Section 5.1.7: Decommissioning. Please clarify why maintenance activities were described under the decommissioning phase, and also provide a description of the activities that would be required to decommission the wharf since only maintenance activities are listed. A list of maintenance activities are provided in Table 5-2. Please provide a brief explanation as to what these maintenance activities would involve. Also, please confirm that all maintenance activities provided in Table 5-2 have been assessed according to the activities listed under operation and maintenance in Table 6-1.

The wharf will not be decommissioned in the foreseeable future; however, there will be maintenance required for features of the wharf over the next 100 years. The activities associated with the maintenance and capital repairs, as listed in Table 5-2 are:

• Re-pave surface – existing surface will be pulverized in place and used as a base for a new asphalt surface.

• Replace lights and poles – replacing luminaires as required and poles will be replaced on the existing foundations.

• Maintenance Dredging – routine maintenance dredging currently occurs at the harbour approximately every 10 years to remove natural littoral drift sediment from the navigational areas. Removal of dredge material will involve use of a dredge machine to excavate the material.

• Repair storm sewer – when storm sewer components reach the end of their serviceable life,



9


they will be removed and replaced. This activity will occur in conjunction with re-paving activities.

• Repair concrete – spot repairs to concrete as required to address spalling and delamination as a result of freeze-thaw action and aging.

• Restore armour stone – spot replacement of armour stone as required to address displacement and fracturing from wave action. New armour stone will be trucked in and set in place.

These maintenance activities are expected to have minimal impacts.

Section 6.0: Impact Management, Mitigation, and Monitoring:

In Section 8.2.3 of the approved ToR, it mentions that the following issues will be discussed with Aboriginal and Métis communities during the EA phase: - Identification of lands with First Nations and Métis interest in the study area; - Identification of land use/activities by First Nations and Métis communities within the study area; - Potential impacts of the study on land used for traditional activities within the study area; and - Proposed mitigation/compensation of impacts to land used for traditional activities within the study area. Although extensive consultation with Aboriginal communities is presented in Section 2.0 of the EA, please confirm if Aboriginal interests, traditional activities or concerns raised in the meetings with Aboriginal communities were considered in

Please note that representatives from Aboriginal communities have identified interest in the study area:

• Page 2-100, the Saugeen Ojibway Nation indicated in an email on April 3, 2012 that the location of the project is in an area that has Aboriginal Title claims and territory for the Chippewas of Nawash First Nation and Chippewas of Saugeen First Nation. The Saugeen Ojibway Nation representative indicated interest in meeting with the study team to discuss their Aboriginal and Treaty Rights. Subsequently, the Saugeen Ojibway Nation representative attended numerous meetings and communication was on-going throughout the EA phase.

• Page 2-90, the Walpole Island First Nation pointed out that the Lake Huron lakebed is not covered by any First Nations’ treaties and it is the local Aboriginal communities’ position that they hold these lands in Aboriginal title. A federal title claim has been filled related to this issue. Also it was noted that any impacts to the Lake Huron fish community would be extremely important to consider given First Nations’ commercial fishing rights. It was noted that there are opportunities to undertake fisheries projects at Walpole Island as



10


Section 6.0, specifically in Sections 6.3.10, 6.3.11, 6.3.12 and 6.3.13 of the EA for the assessment of effects on the Socio-economic environment. If not, please provide justification for the omission.

part of the project’s compensation strategy. Please note that Walpole Island First Nation participated in a number of meetings and was informed of the project’s progress. No concerns or opposition to the project was expressed during the EA Phase.

• Page 2-91, Walpole Island First Nation inquired about opportunities for Aboriginal businesses to use the new wharf facilities or be partners. The study team noted that Goderich Port Management Corporation will be looking for new partners and there may be opportunities for Aboriginal businesses to use the new wharf facility. Goderich Port Management Corporation has had a previous discussion with Saugeen Ojibway Nation regarding opportunities for Saugeen Ojibway Nation’s commercial fishing fleet to use Goderich Harbour. Further consultation with Aboriginal communities will occur during detail design as stated in Section 7.3 of the EA Report.

Overall, the local Aboriginal communities have two major interests: impacts to fisheries and possible business opportunities. As presented in the EA report, numerous meeting with Aboriginal communities were held to develop a fisheries compensation plan which included funding support in implementing fisheries projects and Goderich Port Management Corporation has expressed interest in forming partnerships with Aboriginal communities in the use of the expanded wharf.

In Section 6.3.3.2 it mentions that transportation of fill material by truck represents a “worse case” scenario over transportation by ships. How was this determined and please justify this statement. Also, transportation by ship is the only impact management measure mentioned for import of fill material in Section 6.3.3.2. If trucks

The statement reflects the results of the detailed air quality study which notes that delivering fill material by ship instead of by truck reduces traffic volumes. With the average truck hauling 35 – 40 tonnes of fill and a ship moving 20,000 tonnes each load by ship replaces at least 500 trucks. Impacts from truck transportation relate to both exhaust emissions and re-suspended dust from road surface. The Air Quality report recommends that



11


need to be used, what impact management measures would be implemented?

newer trucks be employed to reduce emissions and that attention be paid to keeping paved roads cleaned to minimize dust emissions.

Please clarify for consistency that Table 6-7 should include monitoring at homes if blasting is implemented as mentioned in Section 6.3.4.1.

Table 6-7 should include noise and vibration monitoring at sensitive receivers should underwater blasting be required. Pre-blasting inspections will also be undertaken, as necessary, at nearby structures not affiliated with wharf operations.


Were traffic collisions with wildlife considered for the import of fill material in Section 6.3.7? Please justify why collisions with wildlife were not considered an impact.

Traffic collisions with wildlife were not considered for the import of fill material as North Harbour Road already exists, it runs parallel to and does not cross the major wildlife corridor associated with the Maitland River Valley, there is no historic evidence to suggest that wildlife/vehicle collisions are a problem on North Harbour Road, and the increase in traffic volumes are not anticipated to result in a significant increase in wildlife mortalities.


In Section 6.3.9.1 it mentions that the fish habitat compensation strategy will identify 62 ha of new and/or restored fish habitat. Only 6.0 ha of new and/or restored fish habitat is mentioned in the Executive Summary and in Section 6.6.2. Please confirm the amount of new and/or restored fish habitat mentioned in the strategy. Throughout the EA it is mentioned that a fish habitat compensation strategy has been drafted and submitted to the DFO for review. What is the status of this review and when is it expected that the strategy will be finalized?

The correct area of compensation is approximately 6.0 ha as reported in the Executive Summary for all the fisheries compensation opportunities, at present.

The strategy has received a preliminary review and approval in principle from DFO. The study team has had numerous discussions with DFO staff with regards to the fisheries compensation strategy. At present, the compensation strategy is being finalized with each of the stakeholders (First Nations, MVCA).


In Section 6.4.6.1 it is mentioned that stormwater management will be monitored on a regular basis for the life of the facility. In Table 6-7 it mentions that the stomwater management system will be monitored twice per year or after a spill for five years post construction. Please clarify, for consistency,

The stormwater management system will be monitored and maintained on a regular basis for the life of the facility. Surface water sampling will be undertaken twice per year or following a spill for five years post-construction as part of the compliance monitoring program.



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the monitoring program for the stormwater management system. In Section 6.4.11.1 it mentions that no permanent lighting will be erected at the facility. However, new down directional lighting focused on the pier deck will be installed. If this lighting is not permanent, how long will it be in place for?

The new down-directional lighting referenced in section 6.4.11.1 refers to lighting installed on the existing North and South Piers as part of improvements to these areas of the Port and is unrelated to the proposed wharf expansion. Goderich Port Management Corporation does not intend to erect permanent lighting at the expanded wharf facility.


Section 6.4.16.1 mentions that traffic monitoring will be implemented annually to determine if advanced warning systems are required. Table 6-7 indicates that traffic monitoring will be completed as required. Please clarify, for consistency, how often the traffic systems will be monitored, and if it is needed on an as required basis, please clarify what will determine when traffic monitoring is required.

Goderich Port Management Corporation maintains records of all materials sent/received at the port. Based on the capacity of the trucks entering/exiting the port, and the total volume of materials passing through the port, the total number of trucks using North Harbour Road can be calculated. As a result, Goderich Port Management Corporation is able to establish on a daily basis the truck traffic volume on North Harbour Road. Traffic monitoring, to determine if warrants for intersection improvements are required, will be undertaken annually at the peak of the trucking season.


Table 6-5 provides a summary of the environmental components, the potential impacts, mitigation measures and the net effects. It is unclear how the net effect was determined based on the assessment completed in Section 6.0 because net effects are not mentioned until Tables 6-5 and 6-6 of the EA. Please clarify how net effects were determined (i.e., effect following the implementation of impact management measures).

The net environmental effects were determined based on the professional judgement of the study team. Based on the likelihood and significance of adverse environmental effects and the known effectiveness of impact management measures including avoidance, mitigation, monitoring and compensatory mitigation, the net or residual environmental effects of the project were assessed. These net environmental effects are presented in Tables 6-5 and 6-6, which serve as a summary of potential impacts and mitigation measures during construction and operations and maintenance respectively. The “net environmental effects” column provides as a concluding statement to illustrate which environmental effects are considered by the study team to be residual.


Table 6-7 outlines monitoring to be implemented during the pre-construction

No construction activities will occur during the pre-construction phase. The pre-construction phase will be

The Ministry is satisfied with


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phase. The pre-construction phase is not mentioned throughout the rest of the report. Please provide an explanation of the activities completed during pre-construction.

used to conduct further baseline monitoring as identified in Table 6-7. A geophysical survey may also be required to confirm local lakebed conditions. The survey would be carried out using a jet probe with negligible environmental effect.

this response.

Table 6-7 Please confirm who will receive each monitoring report for review. Will it be the agencies that are listed to be consulted for each monitoring component?

The agencies that are listed to be consulted for each monitoring component will receive each monitoring report for review.


Please confirm that the draft monitoring plan provided in Table 6-7 for fish and fish habitat will be updated based on the finalization of the fish habitat compensation strategy. In addition, is it anticipated that the restored areas (Section 7.2.3.1) will be monitored for the success of establishment?

The monitoring plan will be revised in LGL Limited’s EMP document which will be completed at detail design and serves as a guide for construction activities and mitigation of impacts to the natural environment. The monitoring plan in the EMP will reflect conditions placed in the Fisheries Act authorization which will likely include type, duration and frequency of monitoring of the wharf expansion as well as requirements for monitoring of the effectiveness/success of the compensation measures.


In the memorandum dated December 10, 2013 from the Ministry providing comments on the Draft EA it was requested that more detail be provided regarding timing and season of sampling for each component. Although more detail has been provided regarding frequency of monitoring, are any of the sampling programs seasonally, time of day, peak level dependent?

Table 6-7 is considered preliminary; it will be updated and augmented during detail design as further details of the project are developed and environmental permits/approvals are obtained. Details related to the seasonality, time of day, peak levels, etc. will be identified in the subsequent environmental permits/approvals. The EMP to be prepared during detail design will include a detailed monitoring and contingency plan that will include these details based on further consultation with external agencies, securement of environmental permits/approvals and advancement of project design elements.


Monitoring for snow removal is mentioned in Section 6.4.6.2; however, there is no mention of snow removal monitoring in Table 6-7. Please confirm for consistency that snow removal monitoring will be included in the final monitoring plan and provide a summary of what the monitoring plan for snow removal will include.

Snow will be stored in stockpiles around the Port. Should the volume of snow exceed the Port’s storage capacity, snow will be removed to an inland depot. The storage areas at the port will be monitored visually to identify when/if their snow storage capacity is reached.



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Section 7.0: Commitments to Future Work: In Section 7.3 of the EA it is mentioned that a PIC will be offered during the project detail design phase. Please summarize who will be invited to attend and what will be presented at this PIC, including but not limited to the conditions on EA approval, final project design, procurement of the contractor, construction methods and evaluation of construction methods, and the final EMP. Please confirm that a PIC summary will be provided to the Ministry similar to those provided in the RoC Appendices. Also confirm the sections that will be included in the PIC Summary.

The detail design PIC invitation will be circulated to current project contacts including: project Government Review Team (GRT) and Regulatory Agency Advisory Group (RAAG) members, Aboriginal communities actively engaged in the project, representatives from local municipalities, local stakeholders and members of the public. The PIC will present information including but not limited to the conditions on EA approval, final project design, procurement of the contractor, construction methods and the final EMP. MOE will be invited to attend the PIC and will be provided with a PIC summary report similar to those prepared for PICs held during the EA phase of the project. For PIC Summary Report content please refer to EA Record of Consultation Appendices G and H.


Section 4.3.5 of the CoP explains that the EA must provide a plan that sets out how and when all commitments, including impact management measures, will be fulfilled and how the proponent will report to the Ministry. Although Table 6-7 in the EA presents a comprehensive monitoring plan, and Section 7.0 provides a summary of additional approvals required following approval of the EA, a number of commitments to be implemented during project design were mentioned throughout the EA. Please provide a comprehensive list of commitments to be implemented during project design.

A comprehensive list of detail design commitments made in the EA report is attached.



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Table 1: Government Review Team Comments Reviewer Comment Received Proponent’s Response Status Senior Noise Engineer. Environmental Approvals Services

Stationary Noise Assessment:

Vacant Lots/Additional Receptors: the Record of Consultation indicates that “There are no vacant lots capable of future development as Compass Minerals owns some of the vacant lands surrounding the site”. However the revised Noise Impact Assessment includes an ownership map in Appendix E that indicates the presence of vacant lands owned by “Goderich Town”. Confirmation letters should be provided by Compass Minerals and the Town of Goderich indicating that no noise-sensitive development is intended on these vacant lands. The letters should also clarify which lands are owned by Compass Minerals and which lands are owned by the Town of Goderich; consequently the above-mentioned Appendix E ownership map should be updated to illustrate these clarifications. Failing conformation that development is not intended for these lands, an examination of the zoning by-law should be performed to determine if noise-sensitive uses are permitted on these vacant lands. The zoning maps in Appendix E should also be updated to show the points of reception (including any future points of reception, if applicable).

If in the future sensitive development is proposed, the Town of Goderich through their municipal planning process will review any development applications with respect to additional noise studies as per standard MOE policy. The Town of Goderich and Sifto Canada Corp. will not issue a binding letter saying that the surrounding areas will never be developed for sensitive uses. According to the Town of Goderich Consolidated Zoning By-law 38-1985 the vacant lots depicted in Appendix E (and attached for reference) are zoned: • OW – Open Water; • OS1 – Public Open Space; • NE – Natural Environment; • H1 – Harbour Commercial; • H2 – Harbour Industrial; • H2-1 – Harbour Industrial; • H2-2 – Harbour Industrial; • H2-3 – Harbour Industrial; • H2-4 – Harbour Industrial; and, • C7-2 – Recreational Commercial. With the exception of C7-2, noise sensitive uses are not permitted in the above land use zones. What appears to be a vacant lot in the C7-2 zone, is not actually a vacant lot. The aerial photography is from 2010, and since then a restaurant has been placed on that lot. Given that there is a restaurant on the site, there should not be an issue with noise control measures for this location. The study team’s noise consultant did, however, run some quick calculations in the hypothetical (though unlikely) situation that some part of this land could be rebuilt as a hotel. Compared to Receptor 1 (located on the hill just south of the restaurant's lands), the ambient sound level will be



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higher due to the closer proximity to the harbour, the grain elevators, truck traffic on Harbour Street, and the tourist/local visitor traffic to the beach area. At a point 120 m north of the restaurant, ambient levels were measured to be approximately 53 dBA Leq in the absence of everything but grain elevator noise. With other noise present (such as a boat in the harbour and roadway traffic noise), the ambient sound levels jump up to approximately 56-58 dBA Leq during the daytime. Note that Harbour Street is one of the main access roads to the grain elevators and the ambient sound levels are even higher when there is trucking. This beach area is quite busy with tourist and local visitor traffic. Under the salt storage condition on the expanded wharf, the sound level from operations (uncontrolled) will be approximately 51 dBA Leq at the restaurant. Under the aggregate storage condition, the sound level from the project at the restaurant will be approximately 45 dBA Leq. Receptors 1 through 4 are typically more sensitive due to closer proximity, lower ambient sound levels, and/or clearer line-of-sight to the expanded wharf's noise sources. For example, Receptor 1 would be the more critical receptor since it has a lower ambient sound level and is much more exposed to any potential noise from the expanded wharf. Noise control measures have been recommended due to the impact at the other, more sensitive PORs. With the measures in place, the sound levels at the hypothetical hotel would be 49 dBA Leq under the salt storage condition and 44 dBA Leq for the aggregate storage option in a location where the ambient sound level is approximately 53 dBA Leq.


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Operations of Sifto Canada and Goderich Elevators: a wharf ownership map was provided in Appendix E of the revised Noise Impact Assessment. The Record of Consultation further indicates that “Since the owners for nearby industrial sources are different than the proponent on the wharf expansion, the noise from the existing facilities can constitute the background sound level.” This is consistent with the MOE approach and allows for the use of the higher 50 dBA evening/night noise limit at Receptor 1, provided that these existing facilities are not under consideration for noise abatement by the Municipality or the Ministry of the Environment. Confirmation to that effect should be provided.

Compass Minerals and Goderich Port Management Corporation have confirmed they are not aware of any noise abatement considerations by the Town or by MOE.

Noise Source Data: for the stationary noise assessment, on-site truck volumes are not included (i.e. number of trucks used for the “Truck Departure” and ‘Truck Arrival” source listed in Appendix B). Moreover, although specific equipment data may not yet be available, sample equipment data from similar projects, manufacturer data or noise textbook literature should be used.

The number of trucks per hour of operation is approximately 50 trucks per hour. There are then a total of 100 truck movements on site, 50 arriving and 50 departing, in a given hour of operation. Sound level data from a large size front-end loader was used. Cut sheets for this equipment will be provided. For the conveyor system, approximate sound data for a 100 kW diesel generator was used to estimate the sound level of this system.

Sound Level Calculations: one sample sound level calculation should be provided for the worst case (i.e. the closest and most exposed) point of reception. The assumed location of all noise sources should be clearly indicated, as it is unclear from the current map provided in Appendix B if the sources are located on the proposed wharf expansion

Sample CadnaA calculations were provided for all receptors and Stamson calculations were provided for all receptors as well. A clearer set of figures is attached.


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under study or on Sifto Canada Inc. lands shown on the ownership map of Appendix E.

Noise Control Measures: a figure should provided to show the location of the conceptual 400 metres-long, 6 metres-high sound barrier recommended in Table 4, “Expanded Wharf Mitigation Options”.

Please see figure attached.

Transportation Noise Assessment:

Noise Control Measures: page 16 of the Noise Impact Assessment states that “the minimum surface density of the noise control measures should be 20 lbs./sq.ft. or 4 kg/sq.m”. All recommended noise barriers should have a minimum surface density of 20 kg/m2 (4lb/ft2). As per Section 9.0 of the Noise Impact Assessment, it is understood that the noise mitigation for the dwellings located on the north side of North Harbour Road is feasible and has been recommended, while noise mitigation for the dwellings located south is not practical due to technical limitations and therefore not recommended. Section 9.0 also states that “A more detailed review of the recommended noise control measures should be completed during the Detail Design phase of the project.”

Comment noted.

In summary, based on the submitted information, the report has derived the applicable sound level limits as per Ministry Publication NPC-205, and the predicted noise emissions from the proposed stationary sources indicate that this project is feasible

Comment noted. An Acoustic Assessment Report will be submitted with the application for an Environmental Compliance Approval.


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with regards to MOE noise guidelines. A detailed Acoustic Assessment Report (AAR) should be provided when the application for an Environmental Compliance Approval is submitted to the Ministry. The AAR should address the above noted Stationary Noise Assessment comments and should also recommend the necessary noise control measures to ensure that the sound levels will be in compliance with the applicable sound level limits, in accordance with Ministry Publication NPC-300.

Senior Wastewater Engineer, Environmental Approvals Services

The outline provided for the design and operation of the stormwater management servicing the expanded Goderich Port Wharf is acceptable with respect to the mandate of the Wastewater Unit, Environmental Approvals Branch (EAB), under the Ontario Water Resources Act (OWRA). As indicated in the report, the proposed stormwater management facility requires an approval under Section 53 OWRA and the proponent needs to submit a completed application and a design brief for the proposed stormwater management facility.

An application for the stormwater management facility will be prepared and submitted to MOE during detail design.


Surface Water Specialist, Technical Support Section

As I mentioned in the past, overall, based on the proposed expansion it does not appear that there will be many surface water concerns. However, I note that my previous comments haven’t necessarily been incorporated into the revised document. My main points of concern continue to be that monitoring for turbidity are followed. In my previous email, I noted that during the Construction Phase, any turbidity monitoring should be conducted in accordance with the Canadian Council of Ministers of the Environment (CCME) guidelines.

The EMP and monitoring plan will reference the CCME guidelines, as appropriate for turbidity monitoring. The Study Team proposes regular weekly turbidity monitoring during construction activities with a turbidity metre and daily visual monitoring for turbidity during construction, with associated turbidity readings as required. Should turbidity levels resulting from placement of fill exceed CCME guidelines, during construction of the wharf expansion related construction activities will stop in order to address the situation.



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The most recent iteration of this document still states that the turbidity levels in Lake Huron shall be kept within the specifications of the Provincial Water Quality Objectives (PWQO). As before, I suggest that the PWQO’s should be used as a general guidance of background Turbidity levels in the lake, but for specific works, the CCME guidelines would apply. These guidelines have already been supplied in my previous correspondence. Further, the proposed monitoring frequency found in Table 6-7 under “Construction Phase- Water Quality in Lake Huron” is inadequate. Only sampling the Turbidity one time per month during the construction phase will not ensure environmental protection. While they are working in-water, a more rigorous sampling program should be undertaken which the proponent should propose. Otherwise, I have no further concerns with the report at this time.

Situations of non-compliance will be documented and remedial actions will be report to the MOE District Office. These revisions to the monitoring plan will be incorporated into the EMP to be prepared during detail design.

Air Quality Specialist, Technical Support Section

Throughout the document, the author makes frequent use of terms such as “assumed”, “will likely”, and “expected”. This undermines its credibility. A study such as this must be based upon measurements, reported data, or other verifiable sources.

Clearly the study must be based upon verifiable information however at best the creation of a pattern of operation both existing and future will be built upon assumptions made by the author and because there is some uncertainty involved in those assumptions it is appropriate to indicate that uncertainty.

The Ministry has requested more information to clarify the response and will continue discussions following publication of the Ministry Review.

Page 35 Page 34 paragraph 4 describes the location of the The Ministry


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As in the Table of Contents (TOC) the author gives a photograph of the area where the sampler is placed but does not indicate its location.

monitor. Figure 3.1 is an enlargement of Figure 2.1, the study area, which sets the location of the project with respect to the community and other areas around the harbour. Figure 3.1 includes a box and an arrow identifying the monitor’s location. Figure 3.2 provides a picture of the monitor, which as the description referenced above states is approximately 10 m above grade, or twice the local structure height. Given the location other photographs of the monitor, taken from far enough away to include the buildings do not clearly show the monitor.

has requested more information to clarify the response and will continue discussions following publication of the Ministry Review.

The report does not include the monitoring data. The report cannot be accepted without access to this data. In addition, there is no mention of the instrument’s servicing procedures and schedules, nor discussion of who operated it. This information must be supplied.

The monitoring data is available as txt files by day. For the purposes of the report, the data was downloaded from the Grimm web site. The web site was used to monitor the operation of the instrument. The first paragraph of §3.5.4 states that the monitor was installed by the supplier. He was assisted by staff provided by Goderich Port Management Corporation who provided power and the Internet cabling required for the unit. The selection of this particular instrument was made on the basis of the limited maintenance it would require. Unfortunately, power interruptions and data communication issues limited the data that was gathered. More recently the instrument had to be removed to accommodate reconstruction work on the wharf. Goderich Port Management Corporation arranged to have the unit returned to the supplier for its routine maintenance and are in the process of identifying a new location for the unit.


On page 38, the pollution roses are labelled, in part, with the following notation: Calm: 0,2 [ μg/m3 ] What does this mean?

The pollution roses were extracted from the Grimm web site with their templates. It appears that there is an error in the template – one presumes that the units on the calms should be percent.

The Ministry has requested more information to clarify the response and will continue discussions following


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publication of the Ministry Review.

The data suggests that particulate levels fell over the course of the monitoring session despite the fact that late summer and early fall are usually drier than the spring months. Does the proponent have an explanation for this?

As noted in the report, August and October data are incomplete in that data is available for less than 75% of the days in those months. September’s record was complete and the Goderich weather from Environment Canada shows measureable precipitation on 14 days that month with a total of 87.7 mm. Since fugitive dust is likely the major contributor to dust in the area, and rainfall is known to reduce the emissions of such dust, rainfall on three or more consecutive days in the month would be expected to reduce dust levels. While the data set is incomplete for August, the mine was on strike for a period starting towards the end of that month.


On page 44, the author says that “Performing a log transformation on the data would show the data fitting a normal distribution curve.” But instead the data is shown untransformed. Why? How good is the fit when the data is transformed and what statistics are derived from it?

The criteria for assessing air quality data are based upon the actual measurements, although in the past geometric averages have been used to deal with the effects extremes in the data set. The explanation in the text explains the apparent difference between the distribution as evidenced by the histogram plots and the normal distribution curve superimposed on the plot. The important observation of the predominance of lower concentrations is noted in the text.


On page 45, the author says “It has been stated that the Southpier terminal handles 250,000 tonnes grain [sic] per year …”. What is the source of this quote? Upon what data is it based?

Operating data presented in the report on operations at the grain elevators was obtained through personal communication with Goderich Port Management Corporation. They obtained data from the facility operators. Inadvertently the reference was missed.

The Ministry has requested more information to clarify the response and will continue discussions following publication of


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the Ministry Review.

In section 4.2.1.2 the author discusses the effect of fleet aging on emissions. However, this discussion is limited to the effect of replacing older vehicles with newer ones which were produced to meet stricter standards. It does not discuss emission degradation for those vehicles still in service and so presents an unrealistic estimate. As well, this section does not discuss how fleet composition is determined.

This section includes a discussion on the age of the trucking fleet and references the source of that data. It goes on to present the assumptions used to establish the age distribution of the Heavy-Duty Diesel Truck (HDDT) vehicle fleet. This section provides an overview of the approach used to define vehicle emissions, further details are provided in Chapter 5, and particularly §5.3.2.3 where it is noted that the salt and grain trucks were assumed to be 2002 era vehicles regardless of the year being considered. The traffic volumes for the different functions were then assigned to the appropriate VMY emissions as discussed in §4.2.1.2. The emission degradations discussed in the MOVES documentation uses information on the frequency of engine component failures and multiplies the emission impacts of these failures by the failure rates to estimate Tampering and Maintenance Emissions. The US Environmental Protection Act (EPA) (2011 Conference Presentation hd-exhaust-moves-2011.pdf) assumed no age effect on NOx emissions from engines that have no after treatment equipment, meaning the 2002 engines assumed to continue to run to the end of the study period have no change in emissions. The aggregate increase for post 2010 engines was assumed to be 87% increase over the useful life of the engine – four years for HDDT – and after that it stays constant. It is noted, Final CRC E-68a paper – V6, that there is no increase in NOx emissions for pre-2010 engines in the MOVES simulation. Since the emission factor for post 2010 is 0.2 g/bhp-hr versus the 4 g/bhp-hr values used for the 2002 engines, the effect of failures and malmaintenance on NOx emissions that would be identified in the modelling would be insignificant. The high levels throughout the scenarios are related to the salt and grain haulage with 2002 VMY trucks.


The document notes that the on-site equipment Given the relatively young age that the mine replaces its The Ministry


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“conforms to” certain standards but it is unclear from the text if this was at purchase or each is regularly recertified. The same concerns hold true for PAH emissions in the next section.

on-site equipment, the units would only just be out of warranty when disposed. Even at that, the findings of the US EPA for the MOVES study suggest the post 2010 equipment will see less than a doubling of NOx emissions as they age. Unlike the NOx conclusions related to malmaintenance and aging PM emissions are assumed to increase – CRC paper referenced above suggests that the percentage increase in particulate would be 74% for 2002; 48% for 2003-06; and 50% for later VMY. However, there is a relationship between particulate, elemental carbon and organic carbon emissions which varies with operating mode. Since the modelled conditions show that the truck emissions are dominated by existing hauling operations, there could be some change in the PAH emissions. However, the data is very sparse and to develop any further assessment based upon malmaintenance, wear etc. would be unreliable. The EPA mentions that more work is required on this issue in the MOVES documentation.


On page 65 the author makes this remark: “The marine simulation suggests that tugs would only be required when the winds are in excess of 15 knots or above 7.7 m/sec. At this wind speed dispersion would be significant and the effect of the addition of the tug’s emissions to those of the vessel would be minimal so they have not been included in the evaluation.” However, they offer no values or estimates. This is not acceptable.

Emissions from the use of tugs needs to be considered; when the tug might be used; the assumptions used for modelling vessel emissions; and the wind conditions at that time of the day. The typical tugboat has several diesel engines, 1800 rpm units. The main propulsion units, there could be 2, are similar to large emergency generator engines, CAT 3512C or equivalent. Smaller auxiliary power units are on the order of 200 kW size and power electrical systems on board. An ARB report – Evaluating Emission Benefits of a Hybrid Tug Boat – provides operating information for tugs testing in Los Angeles and Long Beach California harbours. The average power during operation was 718 kW for transit; 608 kW for ship assist and 754 kW for barge movement. Barges did not have engines so all power was delivered by the tug. At 714 kW total



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production the 3512 engines emitted a combined 2.25 g/s of NOx. This amounts to an additional 25% to the NOx emission values estimated for ship manoeuvring operations. The reference cited in the report states that tugs are only expected to be required when the winds are over 7.7 m/s or 15 knots. A review of the meteorological data used for the modelling indicates that winds are at this level about 15% of the time over the 5 years of available data. More importantly, for the purposes of the study, vessel movements were modelled for 6 am and 9 pm because these were the hours that were found to have the highest predicted concentration when these movements were modelled for every hour of every day. During these hours the wind speed data indicates that there is only a 12% probability of having winds greater than 7.7 m/s. Since vessels do not arrive every day of the month, and they vary by month the joint probability of high winds during vessel movements on an annual basis is 8%. That percent decreases to less than 2.1% or less for the May to August period while rising to 23% in December. Lastly, the periods with the highest one hour average concentrations from vessel emissions had wind speeds of 1 and 1.5 m/s indicating that low wind speeds are more likely to produce high concentrations than high wind speeds. Higher winds produce more dilution of the emissions. The modelling of existing vessel movements indicates that the 99.5 percentile ground level concentrations of NO2 in the residential areas around the harbour are in the range of 50 – 70 ug/m3 even adding 25% to this level, if tugs were used during the low wind conditions would result in a concentration increase to 62.5 to 87.5 ug/m3, well below the criteria level.

On page 73 the author notes that the selection of 15 rail cars hauled out of the harbour every day varies and so “no attempt was made to model this

The quote is in reference to the Trackmobile unit that transfers rail cars from the sidings to either the grain elevator or the salt mine. This unit is equipped with a 160

The Ministry has requested more


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activity”. This is unacceptable. In any case with significant variability it is the proponent’s responsibility to use the most conservative estimate (worst case) in a model such as this.

HP diesel engine. The maximum emissions estimated for this source are 1/10th those for the railway engine in the yard area and less than the emissions from trucks operating on site. In light of this small contribution, occurring on an as needed basis over the whole site, it was excluded.

information to clarify the response and will continue discussions following publication of the Ministry Review.

On page 74, the author says “It has been assumed that it takes 15 minutes for the locomotive to get to the sidings…” Can this not be checked?

This was considered a conservative estimate suggesting that emissions would occur over this period. If the arrival is faster than this the total emissions would decrease. The assumptions about operating data were reviewed by Goderich Port Management Corporation staff and considered appropriate.


On page 81, the author says “diesel engines emit contaminants at a rate related to the amount of power being generated by the engine at any given time”. This is not always true. In particular, during idling the engine will cool. If the vehicle then moves a short distance and stops again, the engines will not have time to warm to optimal operating conditions and combustion will be incomplete. Other non-optimal situations may also occur. As well, even in ideal conditions, the engine must be properly maintained or emissions will be higher than expected. Did the author ascertain that this is the case?

No. Historically vehicular emissions have been modelled in Canada using the MOBILE 6C approach which simply characterizes emissions based upon average cycle performance. This study went a step further recognizing the difference emission performance depending upon loads in line with the US EPA MOVES protocol. In that protocol the US EPA found that there was conflicting data on the performance of diesel engines to the point where they concluded that the cold start and warm start NOx emissions do not vary. Since the protocol looks at differing emissions for different load conditions the effects the reviewer notes, while possible, are likely insignificant in the context of this study.


The document then follows with a discussion of acceleration versus emission. However since the power needed to accelerate on a grade will differ

Table 5.13 shows that the assumptions of speed and acceleration used for the trucks on site results in STP levels that put the operating mode into category 16, the



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from that on a level surface, and since the trucks must deal with a significant grade, is this simplification warranted?

highest mode possible for the speeds encountered on site. Adding a gravitational acceleration term to the last term above the line would increase the STP level but since the links with slopes are already in 16 it would make no difference to the result.

On page 89, the author makes this statement. “It is presumed that trucks spend no longer than 60 minutes in the harbor area thus each truck leaving has a matching entry emission pattern in the same hour”. In fact if the stay is approximately 60 minutes, the two trips would rarely occur in the same hour.

Traffic flows were averaged to an hourly basis for the purposes of the study. If the inbound average traffic in an hour is treated as one input to the source terms and the outbound average traffic is another input, it is immaterial if it is the same truck, or a different truck, that is included in the count.


On page 101 the author says “It is assumed that these operation would result in only limed organ carbon in the emissions. It was assumed that 10% of the particulate matter emissions were organic carbon.” Is there any support for this statement? Is it based upon measurements or published data?

§4.2.1.3 provides the basis for the approach to dealing with PAH emissions and contains references that state that as the output of the engine increases the OC level decreases.


On the following page the author estimates that units will operate at 75%. Why?

§5.4.2 uses fuel consumption data to estimate the average power expended by the loaders operating on the mine site, 66%. Since many of the activities during construction will involve less traversing but similar exertion due to pushing and levelling materials, 75% was assumed to be a conservative estimate of the average load. The Caterpillar Handbook suggests that Job Efficiency is also a function of operating time in the hour, and they suggest that 50 minutes of operation in an hour is typical. That would lower the maximum power to 83% of full power without any other adjustments.


On page 103 the author “estimates” that Volatile The reference for VOC emissions from asphalt in the The Ministry


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Organic Compounds (VOC) emissions account for 0.002% to 0.0002% of the mass of the asphalt mix and then uses the smallest value to estimate emissions. This does not conform to standard practice which requires proponent to present worst case values.

report is a National Asphalt Pavement Association fact sheet that provides a range of values from no measurable emissions reported by a county in Arizona, to the US EPA reported value used for this study, and a number from a European report which the fact sheet notes includes a greater amount of VOCs due to the use of cut-back asphalt and asphalt emulsions, systems that are not used in North America. The study uses the US EPA emission factor, even though the county suggests that after the asphalt is produced there are no solvents and thus no emissions.


On page 118, the author states that to account for low temperatures and precipitation in April and May they would reduce the loader emission factor by 75%. Where did this number come from? Do they have any support for this value or the validity of their approach?

The report states that the silt content of the material in the salt reclaim area was reduced by 75% for March and April. This was an assumption that was incorporated recognizing that salt has an affinity for moisture which will reduce the fugitive emissions in much the same fashion as precipitation reduces emissions from paved roads. Rather than applying a precipitation correction factor, reducing the silt content has the same effect.


On page 119 (and elsewhere) the text contains the expression “Error! Reference source not found.” The report should be repaired where these notations exist. Is a reference available?

There are three instances where the tables in the report are not properly referenced due to a coding error. On page 93 and page 119 the table that should be referenced is 5.15 which deals with emissions from the trucks. On page 96 the reference should be to Table 5.16 that addresses the weighting factors for truck emissions based upon monthly shipping volumes. It was also noted that the reference to 5.18 on page 96 is incorrect, it should also be 5.16. The coding error occurred when some tables were moved to Chapter 4 for clarity.


On page 128, the author says that since there are two places where grain loading could occur, the calculations were performed assuming that the loading would take place at the more westerly

Since emissions from material handling are influenced by the ability of the wind to liberate dust from the material handled, and control strategies are usually aimed at limiting the drop distance, or sheltering the transfer points,

The Ministry has requested more information to


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spot. This is not the more conservative assumption, rather it would seem to lessen the apparent impact of any particulate emissions. As such, this is unacceptable.

the greater exposure afforded by the western location is more likely to increase emissions. Moreover, the western location is closer to the park area which could be considered more sensitive than the wooded hill that backs much of the rest of the grain elevator site. The topography rises more steeply behind the areas to east thereby leading to less chance of the dust spreading. By putting the grain receiving, head house emissions and dryer emissions in close proximity to each other the effect is to increase local concentrations, which one could suggest is more worst case.

clarify the response and will continue discussions following publication of the Ministry Review.

The first plot in the results shows values for 99.5 percentile. It is unclear why the graph does not reflect maxima. Ambient Air Quality Criteria (AAQC) are normally compared to maxima or averages to evaluate ground level concentrations.

The initial comments on the Air Quality technical report suggested that the average concentrations in the area should be presented in the report. To address that, it was decided that the model for NOx should be run to generate the percentile levels from 70% to 99.5% as well as the maxima. The 2nd full paragraph on page 131 provides details including the 99.5% data provides a much better way to compare the effects of the different operating scenarios.


Also missing from their discussion is any evaluation of annual concentrations.

The absence of any criteria related to annual NO2 concentrations led to the omission of these values from the study. The model output found the maximum concentrations on an annual basis for each of the operational alternatives to be Existing 42 ug/m3; Extra Salt shipping 27 ug/m3; Construction 29 ug/m3; and Future 23 ug/m3. These maxima occur on the mine site due to the operation of the loaders in a relatively small area. The differences reflect the replacement of an existing loader in Extra Salt shipping situation. The levels, just as the hourly values, are largely due to existing salt shipment activities since the analyses assume the same equipment will be used for this function throughout the period studied.


The discussion of PM2.5 reflects only the current The study team is aware of the upcoming changes in the The Ministry


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Canada Wide Standard for fine particulate. However, as of 2015, a new Canadian Ambient Air Quality Standard will be in place which encompasses a lower benchmark of 28 μg/m3 as well as an annual average of 10 μg/m3 . Both of these figures will be reduced again in 2020. Information may be found at the following website. http://www.ec.gc.ca/default.asp?lang=En&n=56D4043B-1&news=A4B2C28A-2DFB-4BF4-8777-ADF29B4360BD

PM2.5 standards however when the report was originally prepared, at the end of 2012 these standards had not been issued.


On page 151, the author suggests that the background concentration can be characterised by the 90th percentile concentration. This is not true. To use this number to give an indication of exposure, one would also have to specify a concentration distribution, and have a sense of its accuracy and year to year variability. They offer neither. They acknowledge that their data does not span an entire year, nor does it agree correspond to data from other stations which they wished to use as characterising the local conditions. They then again speak of maxima but only give the 99.5% data.

There are limitations in the available monitoring data. However the modelled results are in the range of the monitored data if one adds in a contribution for the background. It is important to note that the criteria for annual PM2.5 levels is the 98th percentile value, and the 98th percentile for the modelled data for PM2.5 was used for this discussion. All PM2.5 data in the report, with this exception of this paragraph is based upon the maximum predicted values.


Section 6.3.1.4 is labelled “Future Operations Scenario”. It describes the results if “3 million tonnes of bulk materials are transported from the dock are by truck” - presumably per year. Does this cover all material including salt, grain, and whatever else may be transshipped? A summary table of the various scenarios and results would have help clarify this question and the discussion in general.

The very first section of Chapter 6 outlines the four operating conditions assessed for the study. Existing; Existing with extra salt shipments in winter; Construction which includes the previous two alternatives and adds the construction related activities; and Future which is after the wharf is completed and includes existing operations and the addition of aggregate hauling from the wharf. The whole report is structured to address the emission at various stages. Table 5.8 delineates the various trucking activities associated with the operating scenarios. The worst case future shipping situation would be the movement of the aggregate from the wharf by truck. High



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valued commodities delivered to the wharf would occupy the space and force the aggregate operation to be scaled back thereby reducing emissions.

Section 6.4 discusses B[a]P modelling and notes that due to the irregular and infrequent emissions the annual value becomes “too small to register in the model output”. Since modelling may be done using larger values and the results scaled, I do not find this convincing. However, even if this were true, the ministry also has a 24-hour AAQC that could be used as a comparison for worst-case daily emissions. Some effort should have be made here.

Section 6.4 states that “the level of the annual concentration very quickly becomes too small to register in the model output.” The intent was to explain that aside from the BaP emissions from the loaders operating on site, the rest of the sources make little contribution to the annual concentrations – due largely to the intermittent emission rate. As to the 24 hour AAQC the Environmental Registry clearly states that this value that had been derived from the annual standard was to be dropped from the promulgated standard to take effect July 1, 2016. The 24 hour results were produced when the model was run, and the maximum 24 hour isopleths for BaP in all situations after the loaders are replaced shows the 24 hour average to be below the originally proposed 24 hour standard once outside a 100 m radius of the source location.


The report includes none of the modelling input, output, meteorology, etc. Thus it is not possible to verify any of the modelling results. While the author notes that all the modelling was done with AERMOD, no mention is made of the version number or which, if any, of the options were used for modelling.

The modelling procedures and data sources are discussed in Chapter 2 of the report. Sources terms are detailed in Chapter 5. The output from the models is presented in the form of plots generated by the model and superimposed on the aerial photos from the County web site. Modelling for this study used version 8.5.0 of AERMOD View from Lakes. The output can be provided on a CD should it be necessary.


Section 6.4 discusses B[a]P modelling and notes that due to the irregular and infrequent emissions the annual value becomes “too small to register in the model output”. Since modelling may be done using larger values and the results scaled, I do not find this convincing. However, even if this

Section 6.4 states that “the level of the annual concentration very quickly becomes too small to register in the model output.” The intent was to explain that aside from the BaP emissions from the loaders operating on site, the rest of the sources make little contribution to the annual concentrations – due largely to the intermittent

The Ministry has requested more information to clarify the response and


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were true, the ministry also has a 24-hour AAQC that could be used as a comparison for worst-case daily emissions. Some effort should have be made here.

emission rate. As to the 24 hour AAQC the Environmental Registry clearly states that this value that had been derived from the annual standard was to be dropped from the promulgated standard to take effect July 1, 2016. The 24 hour results were produced when the model was run, and the maximum 24 hour isopleths for BaP in all situations after the loaders are replaced shows the 24 hour average to be below the originally proposed 24 hour standard once outside a 100 m radius of the source location.

will continue discussions following publication of the Ministry Review.

Ministry of the Environment Owen Sound District Office

No further comments on the Final EA. N/A

Ministry of the Environment Waste Engineer

No further comments on the Final EA. N/A

Maitland Valley Conservation Authority

Environmental Planner/Regulations Officer

The technical studies submitted with the EA concluded that there is no additional impact on coastal processes as a result of the project. It is our opinion that the proposed work meets the flooding and erosion tests of Ontario Regulation 164/06 (Development, Interference with Wetlands and Alternations to Shorelines and Watercourses Regulation) made under the Conservation Authorities Act (R.S.O 1990, chapter C.27). A MVCA permit is required, pursuant to O. Regulation 164/06, prior to commencing the work.

The study team will apply to MVCA for a permit in accordance with O.Reg. 164/06 during detail design.

The Ministry is satisfied that the proponent will apply for the requested permit to meet the requirements of O. Reg. 164/06.

The storm water collection system is proposed to be divided into two separate systems to address salt contamination. It should be noted that there is potential for other storm water containments such as oil and grit. The EA states that the stormwater collection system will be equipped with an oil and grip separator. We recommend that measures

The stormwater collection system will be developed during detail design. MVCA will have an opportunity to review the proposed collection system at that time.

The Ministry is satisfied the MVCA will have the opportunity to review the stormwater


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should be taken so that all storm water runoff is treated to at least a “normal water quality standard”.

collection system during detailed design.

The EA report details that all fill will be appropriate material that is free from contaminants. The testing and control of fill material will be included as a condition of MVCA’s permit.

Fill used in the construction of the expanded wharf facility will be sampled in accordance with the Guidance on Sampling and Analytical Methods for Use at Contaminated Sites in Ontario (MOE 1996) and the Fill Quality Guide and Good Management Practices for Shore Infilling in Ontario (MOE 2011).

The Ministry is satisfied that the noted condition will be applied to the permit.

County of Huron

County of Huron, Emergency Medical Services

“I have reviewed the electronic copy of the EA and at this time I have no further comments. Thank you Dave Lew.”

Comment noted. N/A

Ministry of Tourism, Culture and Sport Heritage Planner Ministry of Tourism, Culture and Sport (MTCS)

reviewed and provided comment on the Terms of Reference for the Individual EA) on June 23, 2010 and on the draft Cultural Heritage Assessment Report on March 11 and September 26, 2013 for the Goderich Harbour Wharf Expansion Project. • Under the Methodology subsection within Section 3.3.6, the report indicates “the archaeological assessment was undertaken in accordance with the Ministry of Tourism, Culture and Sport’s Stage 1-3 Archaeological Assessment Guidelines, Ontario Heritage Act, and Regulation for Diving Operations, O. Reg. 629/94”, this sentence should be modified as there is no guidelines with that title. The sentence could refer to either MTCS’s 2011 Standards and

Clarification in regards to guidelines noted. Reference to MTCS’ Stage 1-3 Archaeological Assessment Guidelines was an error. The 2011 Standards and Guidelines for Consulting Archaeologists (MTCS 2011) were used to “guide” the marine heritage assessment component of the project as there are no existing standards and guidelines developed for marine archaeology in the Province of Ontario by MTCS. The marine archaeology report was submitted to MTCS as a condition of licensing in accordance with par VI of the Ontario Heritage Act, R.S.O. 1990, c 0.18. Guidance documents/resources used to complete the cultural heritage assessment included: • Ontario Heritage Act; • Ontario Heritage Act, Ontario Regulation 9/06 Criteria for Determining Cultural Heritage Value or Interest; and, • Heritage Resources in the Land Use Planning

The Ministry has confirmed that the MTCS is satisfied with this response.


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Guidelines for Consultant Archaeologists or the older 1993 Archaeological Assessment Technical Guidelines. Also, there is reference to a Stage 1 and Stage II archaeological assessment however this section appears to be referring to the Marine Archaeological Assessment (Appendix K), which is completed under a different process and archaeological license, and the reference to stages is relevant only for land-based archaeology. Therefore, this section needs to be modified to remove the reference to Stage 1 and II archaeological assessment work. There appears to be no land archaeology component to this project, only marine archaeological work and this needs to be clear. • In Section 6.3.14.1 In-water Construction: At the end of the subsection on Potential Impact, the last sentence states “The Cultural Heritage Assessment Report was submitted to the Ministry of Tourism, Culture, and Sport for review and they concurred that there are no impacts to the nine built heritage features in the primary study area”. This sentence needs to be modified slightly as we indicated the “MTCS has no issues with this technical assessment report nor with the cultural heritage resources identified and addressed with respect to project impacts”, which is different in its intent as MTCS must review and “concur with” or “accept” reports for archaeologists to meet Ontario Heritage Act archaeological licensing requirements. There is also a recommendation within the Cultural Heritage Assessment Report (Appendix J), which is also summarized in the EA repot, for heritage interpretive plaquing to occur in the Goderich Wharf and MTCS would like to see a

Process guide and associated Heritage Toolkit including: o Heritage Property Evaluation o Designating Heritage Properties o Heritage Conservation Districts o Your Community, Your Heritage, Your Committee; and, o Heritage Resources in the Land Use Planning Process. Section 6.5.2 of the ToR outlines the methodology for land-based archaeological assessments. Reference to a Stage I and Stage II archaeological assessment in the EA was an error. As suggested, the reference was to the Marine Archaeological Assessment. No land archaeology component was part of the EA process as no lands will be disturbed by the project. During the EA a traffic assessment was carried out and determined that there was no need or justification for improvements to North Harbour Road to accommodate the proposed wharf expansion. As no improvements to North Harbour Road were warranted, a Stage I archaeological assessment for the road corridor was deemed unnecessary. Furthermore, there are no previously undisturbed lands in the vicinity of the work zone for the wharf expansion that might reasonably be used for construction staging/lay down areas/equipment or vehicle parking/material storage etc. As a result a Stage I assessment was not undertaken for port lands in the immediate vicinity of the proposed expansion. While a formal Stage I archaeological assessment was not specifically undertaken as part of the EA, the scope of work associated with the marine archaeological assessment and cultural heritage assessment includes a thorough historic background summary for the study area, and included a


35


commitment to this recommendation in the EA report.

review of the following secondary sources: • MTCS Site Registration Database; • reports of previous archaeological work within a radius of 50 m around the study area; • topographic maps at 1:10,000 (recent and historical); • historic settlement maps such as historical atlases; • Sessional papers; • Surveyor’s notes; • nautical charts; • available archeological management/master plans or archaeological potential mapping; • commemorative plaques or monuments; • municipal official plans and heritage inventories; • Canadian Register of Historic Places; • Canadian Hydrographic Service Great Lakes Pilot; • Government publications; and, • historical newspapers/periodicals. The results of the marine archaeology assessment confirmed that there are no registered archaeological sites within one kilometre of the study area. The primary study area is contained within the existing Goderich Harbour – an area that has been subject to historic use, reuse, and repeated improvements over time. The possibility that remnants of the historic or archaeological features of early Goderich Harbour development might still be extant prompted the archaeological marine assessment, including a hydrographic survey of the harbour. The archaeological survey confirmed that material located during the assessment was from recent deposition, in particular material deposited during the August 2011 tornado. There was no evidence of any cultural remains, either prehistoric, native historic, or historic located during the archaeological assessment and no further archaeological assessment is proposed. Compliance regulations including Section 48(1) of the Ontario Heritage Act, the Cemeteries Act, R.S.O 1990 c. C.4, and the Funeral, Burial and Cremation Act, 2002, S.O. 2002, c.33 will be included in construction


36


contract documents. The cultural heritage impact assessment identified nine built heritage features and one cultural landscape has having cultural heritage value or interest: • BHF #1 – Siddall Fishery Building; • BHF #2 – Pavilion; • BHF #7 – Goderich Harbour Restaurant; • BHF #8 – Goderich Elevators (previously Southpier Terminals); • BHF #9 – 133 St. Georges Crescent; • BHF #15 – Sifto Canada Corp. complex; • BHF #17 – Lighthouse; • BHF #18 – CPR Railway Station; • BHF #19 – 103 St. Georges Crescent; and, • CLF #1 – Goderich Harbour. None of the built heritage features will be directly affected by the proposed wharf expansion. Some built heritage features will experience an alteration in sight line or viewscape, but their ultimate view will still be of an operating industrial port. CLF #1 will be directly impacted by the proposed wharf expansion, but the development proposed is in keeping with the historic evolution and activities of an operating industrial port. Heritage interpretative plaques will be designed during detail design, and will provide a historical account of the evolution of harbour development in Goderich. The study team has reviewed MTCS’ letter of September 27, 2013 to Ms. S. Janusas, in particular….”MTCS has no issues with this technical assessment report nor with the cultural heritage resources identified and addressed with respect to project impacts. MTCS is in no way liable and makes no representation or warranty as to the completeness, accuracy or quality of the cultural heritage assessment report. The


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report may be subject to further review, comments or suggestions made by the municipality.” and understand the limitations associated with the preceding statement.

Canadian Environmental Assessment Agency Director, Ontario Region

As part of the Government of Canada’s plan for Responsible Resource Development which seeks to modernize the regulatory system for project reviews, the Canadian Environmental Assessment Act, 2012 (CEAA 2012) came into force on July 6, 2012. CEAA 2012 focuses federal environmental reviews on projects that have the potential to cause significant adverse environmental effects in areas of federal jurisdiction. The CEAA 2012 applies to projects described in the Regulations Designating Physical Activities (the Regulations). Based on the information provided, your project does not appear to be described in the Regulations. Kindly review the Regulations to confirm applicability to your project including section 1(g), which relates to wildlife areas and migratory bird sanctuaries. According to Section 24(c) of the Regulations the construction, operation, decommissioning and abandonment of a marine terminal designed to handle ships larger than 25,000 dead weight tonnes (DWT), unless the terminal is located on lands that are routinely and have been historically used as a marine terminal or that are designated for such use in a land use plan that has been the subject of public consultation, may require a federal environmental assessment. For more information on CEAA 2012, please

The study team circulated CEAA on the EA distribution list as a courtesy based on their involvement during the ToR phase of the project and participation in the EA phase as a member of the project’s RAAG committee. Attached please find correspondence from CEAA confirming that the proposed wharf expansion would not require a Comprehensive Study and advising the study team that a CEAA approval is not required for this project (CEAA 2012). The study team has, in light of CEAA’s April 17/14 correspondence to MOE, reviewed the Regulations in particular sections 1(g) and 24(c) and confirms the Regulations do not apply to the proposed project. The study team will remove CEAA from the project contact list.

The Ministry is satisfied that the proponent confirmed the request by the CEA Agency.


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access the following links on the Canadian Environmental Assessment Agency’s (the Agency) website: • Overview of CEAA 2012 • Regulations Designating Physical Activities, and Prescribed Information for a Description of a Designated Project Regulations If it appears that CEAA 2012 may apply to your proposed project, you must provide the Agency with a description of the proposed project. Please see the link below to the Agency’s guide to preparing a project description. If you believe the project is not subject to a federal environmental assessment, and do not submit a project description, we kindly request that you remove the Agency from your distribution list. If you have any questions, please get in touch with our office through the switchboard.

Aboriginal Affairs and Northern Development Canada Regional Subject Experts Consultation Information Service (CIS) Consultation & Accommodation Unit

Aboriginal Affairs and Northern Development Canada (AANDC) officials do not participate in environmental assessments that pertain to projects off-reserve, nor does the department track how other parties carry out their EAs. Therefore, please omit AANDC officials from your contact list. Only when a project intersects with reserve land, should the Environmental Unit of AANDC be contacted. AANDC has launched the Aboriginal and Treaty Rights Information System (ATRIS). This Web-based system uses a mapping interface to provide information to federal officials and other interested parties on the location and nature of established and potential Aboriginal and Treaty

The study team will remove Aboriginal Affairs and Northern Development Canada from the project contact list.



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rights. With ATRIS bringing together information regarding Aboriginal groups such as their exact location, their established rights (through treaties and other agreements) and their asserted rights through claim processes and also enabling users to relate many types of AANDC corporate data within a geographical and consultation context, ATRIS has become the main platform for Canada to disseminate its real or constructive knowledge of section 35 rights. You can go directly to http://sidait-atris.aadnc-aandc.gc.ca/atris_online/ and begin research in ATRIS. At the ATRIS “Help” button, there are answers to frequently asked questions, a glossary, and instructions on how to navigate the system. Please familiarize yourself with the information available there so you can carry out your research using ATRIS. Please keep in mind that some of the information provided by ATRIS will be contextual. Depending on your project, the information that comes up in a search may or may not pertain to Aboriginal or treaty rights in your particular project area. In most cases, therefore, the Aboriginal communities identified by ATRIS are best placed to explain their traditional use of land, their practices, or their claims that may fall under section 35 of the Constitution Act, 1982. If you have specific questions on how to conduct research using ATRIS, we will endeavour to assist you if you contact the CIS through the e-mail address: [email protected]. Should you have comments regarding the contents in ATRIS, please complete the “Provide


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Feedback” form available in the “Help” or provide them through e-mail. Your input is valuable as ATRIS is continually evolving through the addition of new information and the observations and contributions of users.


Page 1

Table 2: Public Comments Reviewer Comment Received Proponent’s Response Status Public #1

Four noise receptors are present, one (#4) being Maitland Valley Marina and Trailer Park. A fifth receptor should be included at Maitland Inlet Marina which is 200 metres away and directly across the river from the proposed project. Many boaters at both marinas use their boats as a cottage, taking intermittent residence and associated recreational activities.

The zoning for the marina nearest the wharf expansion does not indicate explicitly that residential use is permitted. The Township of Ashfield-Colborne-Wawanosh Zoning By-Law indicates “The area zoned RC3-1 may only be used as a marina with the following accessory uses, a washroom/ clubhouse building, an office/ maintenance building and a storage building.” NPC-205 and NPC-300 (which replaced NPC-205 after this study was completed) do not explicitly consider marinas or boats as sensitive receptors.

A response letter will be prepared by the study team and sent to the commenting party. The Ministry is satisfied that the applicable NPC noise regulations will be met.

Concerns include noise from: safety alarms at all hours from mine and hoisting equipment, backup alarms for moving equipment and loaders, loaders being run at excessive speed/high RPM, shunting rail cars, joining rail cars together with excessive force, locomotives idling for extended periods, rail cars squealing as they round the corner at the entrance to Maitland Valley Marina, and truck noises such as going uphill from a standing start, engine over-revving coming down the hill to a stop, and tailgate slamming on dump trucks.

The majority of the concerns regarding noise are related to the existing mine’s operations. The operation of safety equipment such as back-up beepers and warning alarms are exempt from the noise guidelines.

Report fails to mention how significantly noise travels over water and rebounds off valley banks and retaining wall.

This item is discussed in Paragraph 3 of Section 6.1 in the Noise Impact Assessment Report (EA Technical Appendix D). The surfaces have been modeled as acoustically reflective.

Noise barriers should be installed along the concrete river retaining wall and along the river stone wall at the north side of the proposed expansion.

Mitigation options have been presented in the report for both the aggregate operations and salt operations on the expanded wharf. These items are shown in Table 4 of the Noise Impact Assessment Report. If aggregate operations are to occur during the evening and nighttime, a 6.0 m high and 400 m long noise barrier is recommended along the north side of the expanded wharf area. The Maitland Inlet Marina would also benefit by 5-6 dB from this barrier if it were constructed.


Page 2

Table 2: Public Comments Reviewer Comment Received Proponent’s Response Status

Noise issues should be addressed before the start of construction.

The commenter will receive a response letter from the study team addressing concerns raised in March 19, 2014 and April 8, 2014 correspondence.

Mr. Peever has reviewed the Goderich Wharf Executive Summary – Noise and wishes to express: • Support in principle of the proposed expansion

wharf; • Some concerns have not been addressed; and • The study area is “huge” and it is difficult to

meaningfully review it in the allotted time prior to April 11, 2014

In addition, the following concerns:

The study team appreciates Mr. Peever taking time to review and comment on the Environmental Assessment (EA), and his overall support of the project.

A number of Maitland Valley Marina’s clients have concern regarding expansion of facilities (total area, production and rail facilities), and density of transportation increasing. Clients are concerned with noise throughout day and night, stone and salt dust corrosion on their cars and boats. As previously discussed, Maitland Inlet Marina is 200 m from the proposed expansion and the marina should have been a receptor area.

For responses to concerns regarding current ambient noise see response to March 19/14 concern #2 above. Observations of intermittent dust issues from the existing operations will be brought to the attention of the companies operating on the wharf so that they can take appropriate actions to reduce their occurrence.

Maitland Inlet Marina planted evergreen trees to assist in isolating noise from entering the marina, however they were killed by salt dust caused by the significant southwest breeze.

Comment noted.

Aggregates of salt in the new proposed area will be carried toward Maitland Inlet Marina on frequent south to west winds. Now is the time to install appropriate salt and noise barriers. The noise barrier should be installed on the top portion of the concrete river wall and on the south side of the stone river breakwall. The noise barrier could have overlapping openings to allow fisherman access along the river. A sketch was enclosed of Maitland Valley and Maitland Inlet Marina property boundaries (the

For responses to concerns regarding noise barriers see response to March 19/14 concern #4.


Page 3


property they pay taxes on). This property starts 100 feet from the concrete and stone river breakwall. A group of Maitland Valley Marina’s clients request a meeting to further discuss concerns and attempt to resolve issues.

The study team will make arrangements to meet with Maitland Valley Marina to discuss further.

Enclosed letter from Jeff Evans (September 24, 2013): • Requests Sifto’s Goderich mine to remove

inappropriate levels of ambient noise being emitted by the site.

• Temporary inconveniences (excess light, dust and noise) have been noted by Mr. Evans at Maitland Inlet Marina where he and his family vacation on summer weekends and holidays.

• Over the past months (summer 2013) the mine has implemented a system of horn signals that are always in operation. This activity has been frustrating and intrusive.

• Compass needs to employ a less intrusive signalling method that does not infringe on the quality of life of its neighbours.

Compass Minerals addressed Mr. Evans concerns verbally within days of receiving his September 2013 letter.

Public #2

I have reviewed the EA and in particular the assessment of truck traffic. I live on the bank above North Harbour Road (32 Caledonia Terrace) and I have become extremely annoyed with the existing truck traffic as many use their engine brake on the way down the hill and then they are gearing up as they cross the railway track to get up the hill. At 4 am this not only wakes me up but keeps me up. An increase in this traffic will make living in our house extremely unbearable. I am all for industrial development but not at the expense of peace and quiet I should be able to have in my house and in my backyard. 75000 trucks per year will limit this. No where on the EA was the continuous noise of the additional truck traffic addressed. If the expansion proceeds, for the sake of those living at the top of the

The incremental noise increase as a result of the expansion has been evaluated in Section 7.0 of the Noise Impact Assessment Report. In this section, we acknowledge that noise increases of 7 dB or more would be present along North Harbour Road between the months of May and October in the event of aggregate storage on the expanded wharf. If the wharf were not expanded, there would be a 4-5 dB increase in noise along North Harbour Road during some of the winter months. In summary, for transportation noise, whenever a 5 dB or greater increase in noise is predicted, noise control measures (such as barriers) must be evaluated for the economic, technical, and administrative feasibility. Noise barriers are usually recommended to control

A response letter will be prepared by the study team and sent to the commenting party. The Ministry is satisfied that the applicable NPC noise regulations have been/will be met.


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hill above North Harbour Road. this must be addressed. I will look forward to hearing from you Taylor Lambert

transportation noise sources such as roadways and railways. In this case, the barrier would either need to be located at the base of the road or at the top of hill embankment on which the houses sit. A tall barrier at the base of the road would be extremely expensive and difficult to construct. A barrier at the top of the embankment, at the receptors, would produce a significant visual impact on these receptors. The Town of Goderich owns the property near the receptors, where the barriers would be located. Property access agreements would be needed in order to construct the barrier. Because of the imposing height and/or the visual impact, barriers have not been recommended for those receptors along the south side of North Harbour Road. More details of this evaluation can be found within the Noise Impact Assessment report. Note that the sound level increases predicted in the report would occur gradually and only when the traffic volumes reach those levels used within the assessment.

Public #3

Concerned with a primary omission that limits the validity of the data presented in the “Goderich Harbour Wharf Expansion – Appendix D, Noise Impact Assessment Report”: The report overlooks a 5th receptor which is the closest (and most impacted) residential area to the Sifto mining operation, being the Maitland Inlet Marina, Mr. Evans’ summer residence. The boats and marina grounds are a seasonal residence for locals from Goderich and visitors from the surrounding region, and during the summer months people reside on their boats as a summer “cottage” residence.

The zoning for the marina nearest the wharf expansion does not indicate explicitly that residential use is permitted. The Town of Colborne Zoning By-Law indicates “The area zoned RC3-1 may only be used as a marina with the following accessory uses, a washroom/ clubhouse building, an office/ maintenance building and a storage building.”

A further response letter will be prepared by the study team and sent to the commenting party. The Ministry is satisfied that the applicable NPC noise regulations have been/will be met.


Page 5


Temporary inconveniences located near the industrial harbour (noise, dust, excess lighting) have been mostly transient and residents have learned to accept them given the proximity, however it is concerning that the impact of the project upon Maitland Inlet Marina residents was not considered. The following needs to be investigated: • Current impact of industrial harbour upon the 5th

receptor including inappropriate increase in noise from the mine site in 2013 (a September 24, 2013 letter to Compass (Sifto) RE: inappropriate levels of ambient noise was attached. Compass (Sifto) advised that they would review these concerns. It is Mr. Evans’ expectation that the issue will be resolved prior to returning to the marina in May 2014).

• Monitoring impact of noise, dust, and light pollution during day and night operations.

• Impact upon receptor 5 during and after construction phase of the Wharf Expansion Project with respect to noise, dust, and light pollution.

NPC-205 and NPC-300 (which replaced NPC-205 after this study was completed) do not explicitly consider marinas or boats as sensitive receptors. Due to the proximity to active water (the waves breaking on the beach), the ambient sound levels here would be higher than in other areas. At the Maitland Inlet Marina, we would expect the west facing shoreline to have an almost continuous noise contribution day and night due to the size of the lake and the prevailing westerly wind direction. As a result, the sound impact on the Maitland Inlet Marina has not been detailed. The Maitland Valley Marina, further from the breaking surf, was analyzed as it has a trailer park component. The ambient sound level resulting from boats moving in and out of the marina would also be difficult to quantify as these items are not covered within the provincial guidelines or approved prediction procedures.

Has there been appropriate study of any potential negative impact to vessel navigation from modified silting within the entrance to the Maitland Valley River? Small vessels use this navigation channel daily and modified near-shore currents from the north wall construction may change sand deposition potentially becoming a hazard to navigation while accessing this safe harbour.

A Sediment Transport Impact Assessment (STIA) was conducted and is included as an appendix to the EA document. From the addendum to the STIA (Appendix F2): “It is our opinion that the model results are close enough to one another that we can conclude there will be no noticeable impact to sediment transport conditions at the mouth of the Maitland River as a result of implementing the twin-slip alternative.”

Seasonal residents of Maitland Inlet Marina are most interested in how the Wharf Expansion project and the day-to-day operations of the harbour will strive to minimize any negative impact their operation has

Goderich Port Management Corporation will investigate complaints and will make changes in operations to minimize disruption and ensure compliance.


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upon their neighbours. If not handled appropriately, seasonal residents will relocated which will have a negative economic impact upon marina operates and the local retail community.

Public #4

For the past number of years restriction to public access at the Goderich Harbour and Lake Front has continued to escalate. The proposed Wharf Expansion will make Lake access as the public currently enjoys it impossible. Roland Howe has indicated that vehicle access will not be permitted, the public road will be closed and that maybe they will build pedestrian access. Pedestrian access is impractical for many of the current users. Many have mobility constraints and vehicle access is the only way they will be able to enjoy the waterfront as they currently do. Already, recent “improvements” on the South Pier have made it impossible for individuals with mobility issues to enjoy the lake as they used to. In fact, from a wheelchair you cannot even see the lake over the concrete wall anymore, not to mention fishing. Mr. Alcock has prepared drawings that would provide public access to the lake for fishing, recreation and enjoyment purposes that would not negatively impact the project. He was told during a public presentation “Well that’s not going to happen”. They appear in the EA documents as black blobs that are illegible.

Public access is within the mandate of the Town of Goderich. The Town has consulted with interest groups and a plan has been developed which balances public access with the public safety within the industrial port area.

A response letter will be prepared by the study team and sent to the commenting party. The Ministry is satisfied that discussion on development of a plan for public access and public safety is on-going.


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The current plans for the Harbour Wharf Expansion propose to further restrict access to the North Pier and rock river wall. Both of these locations are popular fishing and recreational locations that the public have enjoyed since their construction decades ago. Rowland Howe of the Goderich Port Management Corporation stated that access to the “Dolphins” (concrete structures that are used for manoeuvring ships) located at the west end of the north pier will be maintained. Access to this location is proposed along the north side of the harbour channel between the loading boom and the location that ships moor to be loaded. He also stated that this access will only be available while there are no ships in port. The times available for access especially with the proposed production increase will be very limited since boats already arrive nearly every day during the shipping season. As recently as last year the public enjoyed vehicle access to the Dolphins and rock river wall. This will cease under the current expansion proposal. To date recreational harbour users have not been consulted with changes to access and the impact of construction at the harbour. It was a “requirement for the Canada Company was to guarantee public access to the port” nearly 200 years ago. Transport Canada preserved public access while the harbour was in their control. Furthermore, the original purchase agreement in 1999 from her Majesty the Queen in the Right of Canada (Transport Canada) included the requirement to maintain public access to the harbour.


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The Goderich Harbour Wharf Expansion offers opportunities to mitigate these restrictions to social and recreation activities. None of the 3 proposed Alternative will utilize the unprotected north (rock river wall) and the west side (existing break wall) of the harbour expansion for loading or unloading vessels. The rock river wall is currently used extensively for fishing and recreation. Land access to the existing break wall would provide increased opportunity for recreation and fishing. Furthermore the existing break wall would be an ideal location to create fish habitat as part of the mitigation measures required to compensate for lost fish habitat. Both the rock wall and break wall extend beyond the expansion which further offers opportunities for recreational users if they have access. The proposed use of the Wharf harbour Expansion is the storage of bulk materials. The proposal indicated that there will be no buildings or permanent structures constructed on the land. The limits of the bulk storage of salt and other materials are setback from the river mouth and lake to prevent the material from entering the natural environment as shown in the EA documentation. The public access area could be located along the north and west edge of the expansion where materials will not be stored. A drawing attached to the letter showed possible public access without restricting storage capacity. This access area would provide public access and industrial access to various parts of the expansion, including vehicle access to the north side and west side for recreation use. Included with the public access should be sufficient parking along the river wall and a park like public access point at each end of the existing break wall with sufficient parking and accessibility to accommodate recreational users with limited mobility. Locating these access points in the


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corners of the expansion should minimize the impact to industrial users, while providing an area for recreational use. A stakeholder group of recreational users should provide input to changes in the immediate harbour area and work with the Goderich Port Management Corporation to preserve the social and recreational use of the harbour that has existed for over 200 years. The recreational users have shared the harbour and the surrounding lands with industrial users for that entire time. There is room for all harbour users to exist in the Goderich Harbour. The Harbour Wharf Expansion provides extended opportunities for that relationship to continue. Mutual respect, proper road design and a minimal amount of infrastructure can help assure that.


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Table 3: Aboriginal Community Comments Reviewer Comment Received Proponent’s Response Status

Historic Saugeen Métis (HSM)

Historic Saugeen Métis Council is satisfied with Darryl M. Robins Consulting Inc. reviews of the Environmental Assessment (EA) and the Sediment Transport Impact Analysis (STIA) (provided on March 24, 2014 and April 7, 2014 respectively) for the Goderich Harbour Wharf Expansion Project completed on behalf of Historic Saugeen Métis. Based on these reviews, Historic Saugeen Métis proposes the following recommendations:

• Request an opportunity to review the stormwater management report/design when complete;

• Request an opportunity to review the “For Tender Drawings” to ensure that sediment control measures are in place to minimize the risk of sediment entering Lake Huron;

• Request an opportunity to review and consult on the proposed construction methods to minimize the sedimentation to Lake Huron;

• Request to be notified on the status of all approvals including, but not limited to, the Ministry Of the Environment’s (MOE) Environmental Compliance Approvals, the Maitland Valley Conservation Authority’s Permit for Development, Interference with Wetlands and Alterations to Shorelines and Watercourse Regulations, and Transport Canada’s approvals (Navigable Water Protection Act);

• Request that the Historic Saugeen Métis be notified of any archaeological findings during construction; and

• Request that Historic Saugeen Métis be regularly informed of the project’s progress and details to confirm that the construction details of the wharf expansion do not differ from the twin-slip option parameters evaluated in the STIA and the EA.

The proponent will continue to consult with the Historic Saugeen Métis during the detail design phase of the project and will circulate to Historic Saugeen Métis:

• a copy of the stormwater management design when complete;

• a copy of the construction tender drawings;

• a copy of the Environmental Management Plan, including erosion and sediment control plans;

• a copy of all environmental approvals secured for the project including but not limited to MOE’s Environmental Compliance Approvals, the Maitland Valley Conservation Authority’s Permit for Development, Interference with Wetlands and Alterations to Shorelines and Watercourse Regulations, and Transport Canada’s approvals (Navigable Water Protection Act);

Historic Saugeen Métis will be notified of any archaeological finds during construction. Historic Saugeen Métis will regularly be informed of the project’s progress and details to confirm that the construction details of the wharf expansion do not differ from the twin-slip option parameters evaluated in the STIA and the EA. The proponent will prepare a response letter confirming commitments to continued engagement during detailed design.

The Ministry is satisfied the proponent has committed to further consultation with Historic Saugeen Métis.


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Walpole Island First Nation

Walpole Island First Nation has participated in the consultation process for the Goderich Harbour Expansion project for over two years. The Goderich Port Management Corporation along with their consultants, LGL Limited, has been very receptive in including concerns and feedback from Walpole Island First Nation while contemplating this project. Walpole Island First Nation’s main concern has been with the fisheries compensation plan. Goderich Port Management Corporation worked with Walpole Island First Nation to develop a compensation project at Swan Lake marsh in cooperation with the Walpole Island Land Trust. Walpole Island enclosed a letter of support from Chief Burton Kewayosh for the compensation plan that includes the Swan Lake marsh along with proposals to increase sturgeon habitat in the Huron-Erie corridor. Walpole Island First Nation looks forward to continuing the mutually beneficial relationship with Goderich Port Management Corporation for many years to come.

Comment noted. N/A

Saugeen Ojibway Nation

Saugeen Ojibway Nation has participated in the consultation process for the Goderich Harbour Expansion project since 2012, and entered into an agreement with Goderich Port Management Corporation in May 2013 guaranteeing Saugeen Ojibway Nation that their expert advisors would have an opportunity to review the technical reports prepared in support of the EA. As a result of review by Saugeen Ojibway Nation’s experts, the proponent, Goderich Port Management Corporation, made modifications to the project. Saugeen Ojibway Nation subsequently entered into a supplementary agreement with Goderich Port Management Corporation that guaranteed that Goderich Port Management Corporation will fund a stable isotope study. This study will assist Goderich Port Management Corporation and Saugeen Ojibway Nation in tracking (and, if necessary, later addressing) any harmful impacts on fish. Saugeen Ojibway Nation’s expert advisors have reviewed the EA Report, and indicated that the restoration efforts and reef creation plans proposed are all appropriate mitigation plans for the project. There are small details which require additional resolution,

The proponent will continue to engage with Saugeen Ojibway Nation, particularly with respect to fish compensation plans, monitoring and Saugeen Ojibway Nation’s proposed stable isotope study.

The Ministry is satisfied the proponent has committed to further consultation with Saugeen Ojibway Nation.


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regarding the proposed monitoring and fish compensation, but Saugeen Ojibway Nation trusts these small details can be addressed in the monitoring process. Saugeen Ojibway Nation indicated they are satisfied, following their review, that a robust and appropriate environmental assessment process for the project is reflected in the EA Report.

MAKING A SUBMISSION? A five-week public review period ending July 25, 2014 will follow publication of this Review. During this time, any interested parties can make submissions about the proposed undertaking, the environmental assessment or this Review. Should you wish to make a submission, please send it to:

Director Environmental Approvals Branch

Ministry of the Environment 2 St. Clair Avenue West, Floor 12A

Toronto, Ontario M4V 1L5 Fax: (416) 314-8452

Re: Goderich Port Management Corporation Proposed Harbour Wharf

Expansion Environmental Assessment Report Attention: Andrew Evers, Project Officer

Telephone: 416-314-7213 Email: [email protected]

Under the Freedom of Information and Protection of Privacy Act and the Environmental Assessment Act, unless otherwise stated in the submission, any personal information such as name, address, telephone number and property location included in all submissions become part of the public record files for this matter and can be released if requested.

ministry review of the goderich harbour wharf expansion

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