Nowhere else in Ontario would a temporary cement plant be permitted by a public school. Please ask Minister Murray (firstname.lastname@example.org) and Premier Wynne (email@example.com) to revoke the Renewable Energy Approval for turbines on Amherst Island.
August 2016 letter to Minister Murray
Dear Minister Murray,
I am the mother of two daughters (ages 7 and 10) who attend Amherst Island Public School. I was a Participant in the Environmental Review Tribunal (ERT) regarding the above issue.
The panel dismissed my concerns regarding the siting of the cement batch plant, and my belief that the safety of children in their school environment will be compromised.I am formally requesting that you reverse the ERT decision based on my belief that the placement of the concrete batching plant and all associated construction activity for this project directly adjacent to the school will result in harm to children.
My appeal to you is based on the following three points:
1. The cumulative impacts on children of all the construction activities that this project introduces have not been adequately considered, in particular the impacts to Amherst Island Public School.- The evidence presented by the Approval Holder at the ERT broke down the project into detailed, individual activities, whose negative impacts are deemed to be negligible.But the ERT omitted to consider any examination of collective impacts to children.- Because each activity was looked at in isolation and not with an integrated approach, the potential harm of the project’s cumulative impacts has been overlooked.
It remains my opinion that the Director of Environmental Approvals did not adequately consider the cumulative nature of the concrete batch plant and activities and the impacts to the health and safety of students. Given that the concrete batching plant and associated construction for this project will occur less than 1 km from our elementary school, it actually appears that the single group who stands to experience the most negative effects from this project will likely be the children attending Amherst Island Public School.
2. It is unclear who is responsible for safety associated with this project.
It is still unclear who is responsible for safety and oversight in relation to the school environment. During the ERT, I learned that there would be extensive construction traffic from this project passing by our school, in addition to a concrete batching plant in proximity to the school that would not be allowed by our municipality if not for the Green Energy Act.
3. The “Burden of Proof” required by the ERT can only be accomplished by exposing children to unacceptable risk.
The UN Convention on the Rights of Children is clear: Governments have a responsibility to protect children. The best interest of the child shall be a primary consideration in government decisions.
I believe that by approving the project, the Director has authorized the Developer to introduce plausible harm to children.- The ERT found that during my submissions, I had not met “the test” of serious harm to human health. In the case of Amherst Island, to provide undeniable “proof” that the health of children will be impacted by the project would mean allowing the project to move forward as approved, and then assessing outcomes to children after months of exposure.
In Canada, in 2016, we do not permit such trials on children. However, that is threshold of the “legal test” that must be attained in order to successfully defend my children.
We must be reasonable, and consider the Precautionary Principle, which states that when risk of harm is scientifically plausible, actions should be taken to avoid or diminish the harm, and these actions are interventions that are undertaken before harm occurs.
Amherst Island is close to 16 Km long. Why did the Director not ask the Approval Holder to find a different location for the cement plant? Why weren’t these concerns noted in the ERT decision?
Minister Murray, if this project is allowed to move forward as approved, without adequate assessment of the cumulative impacts to the Amherst Island school environment, then our children become the test to see if the decisions of the Director were right or were wrong.
All children deserve better. In order to support the health, safety and welfare of children attending a public school in Ontario, I would respectfully request that you reverse the ERT decision in relation to the placement of the concrete batch plant for this project, and amend the conditions related to the concrete batch plant.
In the words of Dalton McGuinty “It’s never too late to do the right thing”.
Amherst Island Public School. No place for a cement mixing plant.