Currently, Nelson’s “best management practices” to control fugitive dust emissions are insufficient. Despite claiming to have 90% of controls in place, dust emissions continue to have negative community impacts far off-site. These emissions are a threat to plant, animal and human health. There is no evidence in the application to confirm the effectiveness (or ineffectiveness) of these so-called dust emission controls. Dust emissions, especially fine particulate dust, must be captured at the generator source, and prevented from migrating off-site.
Based on the Air Quality report submitted by Nelson Aggregate, there are discrepancies with the quality and the accuracy of the modelling that was used to measure emissions. According to this report, the background levels used were based on data that was already available from the previous submission from more than 10 years ago. This data is outdated, and furthermore, significantly, it is not taken from the actual location of the proposed industrial complex. In addition, these data models are based on a rate of 2mm tonnes/yr. Given that the intensity of Nelson's production can vary seasonally—resulting in higher emissions during some months and balancing out the total allowable emissions during less-active months—this type of monitoring is not accurate and allows for sporadic, unsafe, high levels of emissions. It opens the window for Nelson to engage in more intense periods of mining, resulting in higher concentrated emissions, leading to increased, concentrated, negative impacts on the environment and on the health of all individuals impacted by these more intense periods of mining activity.
Additionally, the modelling does not include emissions generated by off-site truck transportation, on-site machinery, and other unmonitored processes that contribute to the total emissions produced and reported. All emissions must be monitored and recorded; reporting exceedances to authorities.
There is no accounting for CO2 emissions. Taking into consideration that gasoline/diesel-fuelled transportation is one of the biggest emitters of greenhouse gases in Canada, CO2 emissions must be included in the report. Furthermore, CO2 emissions from other activities, such as asphalt production and blasting, must also be included in the assessment process in order to render a more accurate estimate of CO2 emission levels. The City of Burlington has declared that the city be carbon neutral by 2050. In order to achieve this critical goal, these types of CO2 emissions (from all trucks, blasting, processing, asphalt production, stripping overburden, etc.) must be taken into account when assessing this application.