Send this letter to:

Denise Blackwell, CRD Board Vice-Chair (dblackwell@crd.bc.ca)
Susan Brice, Director (sbrice@crd.bc.ca)
Barbara Desjardins, Director (bdesjardins@crd.bc.ca)
Fred Haynes, Director (fhaynes@crd.bc.ca)
Lisa Helps, Director (lhelps@crd.bc.ca)
Mike Hicks, Director (directorjdf@crd.bc.ca)
Gary Holman, Director (gholman@crd.bc.ca)
Dave Howe, Director (directorsgi@crd.bc.ca)
Ben Isitt, Director (bisitt@crd.bc.ca)
Jeremy Loveday, Director (jloveday@crd.bc.ca)
Rob Martin, Director (rmartin@crd.bc.ca)
Cliff McNeil-Smith, Director (cmcneilsmit@crd.bc.ca)
Rebecca Mersereau, Director (rmersereau@crd.bc.ca)
Kevin Murdoch, Director (kmurdoch@crd.bc.ca)
Geoff Orr, Director (gorr@crd.bc.ca)
Colin Plant, CRD Board Chair (crdchair@crd.bc.ca)
John Ranns, Director (johnranns@crd.bc.ca)
David Screech, Director (dscreech@crd.bc.ca)
Lanny Seaton, Director (lseaton@crd.bc.ca)
Maja Tait, Director (mtait@crd.bc.ca)
Ned Taylor, Director (ntaylor@crd.bc.ca)
Ken Williams (kwilliams@crd.bc.ca)
Ryan Windsor (rwinsdow@crd.bc.ca)
Geoff Young, Director (gyoung@crd.bc.ca)

Subject: Environmental assessment for Hartland 2100 design concept      

Dear CRD Board of Directors,

I am writing on behalf of the Mount Work Coalition (the “MWC”), a group of concerned and engaged citizens who are keenly following the development of the CRD’s new solid waste management plan (the “Plan”).

I am writing in particular about Strategy #15 of the draft Plan: “Enhance Hartland Disposal Capacity.”[1] In reviewing public documentation related to this strategy, we have become concerned that no reference has yet been made to the possibility that an environmental assessment may be required before the expansion contemplated by the strategy—what has been referred to as the Hartland 2100 Design Concept (the “Design Concept”)[2]—could lawfully proceed.

Pursuant to the Reviewable Projects Regulation, BC Reg 243/2019 (the “Regulation”), an environmental assessment is required for a modification to a solid waste management facility (i.e. a landfill) where that modification either increases the design capacity of the facility by 30% or more or results in the facility having a design capacity of ≥ 250,000 tonnes/year. While the exact increase in design capacity that the Design Concept would result in has not been made publicly available, the projected increase in lifespan of the Hartland Landfill from 70 years to 127 years under the Design Concept[3]—an approximately 55% increase—suggests that the threshold set down in the Regulation will be surpassed.

While the CRD has not yet indicated whether it will be conducting an environmental assessment in relation to the Design Concept, we are concerned that the lack of transparency around this matter could undermine the legitimacy of both the public involvement process for the Plan and the Plan itself. In other words, if an environmental assessment will be required for the Design Concept, MWC sees it as critical that the public be informed that important information related to the social, environmental, economic, and climate change-related impacts of the Design Concept and the Plan will not be publicly available until the time in which an environmental assessment is conducted, including, conceivably, after the Plan is approved.

Accordingly, we request the following:

1. that the CRD provide MWC with its assessment of the applicability of the Reviewable Projects Regulation and Environmental Assessment Act (BC) to the expansion of the Hartland Landfill, including information regarding the current design capacity of Hartland Landfill, the projected design capacity under the Design Concept, and, if relevant, the projected cost of conducting an environmental assessment; and
2. that the CRD make all information provided to MWC under the above publicly available as part of the second phase of its community consultation process for the Plan.

Given the stage that the CRD is at with respect to finalizing the Plan, we urge the CRD to fulfill this request as efficiency as possible.

Sincerely,

[YOUR NAME HERE]

[1] Proposed Strategies and Actions: https://www.crd.bc.ca/docs/default-source/solid-waste-management-plan-2019/strategies.pdf?sfvrsn=8af064cb_14.

[2] Hartland 2100 Design Concept: http://crd.ca.legistar.com/gateway.aspx?M=F&ID=5a60d1ce-2c35-4746-acf6-759d5ba22a0c.pdf.

[3] See page 20 of Morrison Hershfield’s Technical Memorandum dated September 20, 2013: https://www.crd.bc.ca/docs/default-source/recycling-waste-pdf/iswrmp-stage2technicalmemo-residualwastemanagement.pdf?sfvrsn=3b86fca_2.