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County’s Own Numbers Show ERRC Will Exceed Noise Limits


The Noise Assessment conducted for Simcoe County appears to have used the wrong numbers from their own Traffic Impact Study to calculate noise produced by the ERRC, according to a review by the Friends of Simcoe Forests. With actual truck traffic estimated at well over the counts used in the Noise Assessment, it is unlikely this project will receive provincial approval to operate.

Provincial regulations require developments in rural areas like County forests to remain below 45 dBA during the day and 40 dBA in the evening. Higher levels are permitted in urban or mixed environments, which is why waste management facilities across Ontario are located in industrial zones, not prime agricultural areas like the Freele Forest.

According to the Noise Assessment in the Facility Characteristics Report, “the primary contributor to noise impacts… is inbound and outbound truck traffic”. Calculations at the Freele Forest indicated this facility would produce a noise level of 44.7 dBA at the nearest sensitive receptor, based on an estimate of 123peak hour trips when the facility achieves full production in 2049.

The County appears to be willing to gamble on a third of a decibel cushion in order to build a multi-million dollar facility in a forest, rather than in an industrial location where higher noise levels are allowed. If the final build turns out to be half a decibel higher than their projections, the Province will not grant approval to operate. As most people can’t even perceive a half decibel difference, it wouldn’t take much to push it over the limit.

In fact, County’s own numbers suggest it will be much louder. According to the January 2017 FAQ on the County’s website, “Initial estimates indicate that 150 vehicles would utilize the ERRC daily in 2021 with a maximum of 220 vehicles when the facility reaches its 30-year design capacity in 2049. As outlined in the TIS [Traffic Impact Study], this would equate to between 89 and 148 trips during peak hours at the design capacity.”

The County’s own numbers show there may be more vehicles rumbling through rural neighbourhoods than their noise assessment permits. This is the reason you pick an industrial site for an industrial project. This project would fail in any County forest, so the site selection process was flawed from the very start.

Before another dollar is invested in a project that will ultimately fail to secure provincial approval, Friends of Simcoe Forests urges Council to reconsider its site selection. This project requires an industrial site, not a County forest.

Only Most Expensive ERRC Option Passes Smell Test



All Simcoe County taxpayers will pay through the nose to place waste management facility where it does not belong


SPRINGWATER TOWNSHIP, FEBRUARY 23, 2017 - Friends of Simcoe Forests is calling on Simcoe County Council to reconsider placing its proposed Environmental Resource Recovery Facility (ERRC) in the middle of Freele Forest because it will be too expensive to mitigate the excessive odours produced by this waste management facility.

The Facility Characteristics Report prepared for Simcoe County includes a preliminary Odour Assessment to determine if it is likely this facility will meet provincial environmental requirements. While the report concludes it is possible for the facility to comply if it is “carefully designed and operated”, a closer examination of the report paints a very different picture.

The report considered six different configurations of facilities to calculate the likely level of odour production (see Table 7.1 of the Facility Characteristics Report). A facility that produces more than 1 Odour Unit (OU) at sensitive receptors more than .5% of the time would not comply with provincial requirements. Two configurations significantly exceeded these levels, and a third only passed because it did not include the Organics Processing Facility (OPF) in its calculations.

“We’re puzzled why an option to run the ERRC without an OPF was even considered, since organics processing is half the purpose of the facility,” stated Cindy Mercer of Friends of Simcoe Forests. “To deliberately omit it suggests they’re trying to make it appear there are many possible options that pass standard, and that’s not true.”

Two other configurations appear problematic as well. One only qualifies as a pass by .01%, equivalent to operating less than an hour below standard per year, based on preliminary estimates. Actual measurements could easily exceed this level, and it would be irresponsible to approve construction in the hopes of maintaining that precise reading.

The other problematic option shows the facility operating at a significantly reduced flow rate. No suggestion as to how this low level would be achieved is given; is it by the use of special filtration systems or by operating the facility at a reduced level of production? No details are provided in the report; every other option bases its calculation on a high flow rate.

That leaves just one option that meets provincial standards, and the report wording suggests this will be the most expensive possible facility configuration (see section 7.4 of the Facility Characteristics Report). As the County has yet to produce a financial feasibility study on this facility, there is no way to know what the potential cost of this ERRC might be. Based on the Odour Assessment produced for the County, it seems clear the only option that will satisfy provincial regulations will push this facility to the higher end of any financial estimate.

“The amount of odour filtration required to place this facility in the middle of a forest surrounded by family homes and farms is going to make this a very expensive project,” said Mercer of Friends. “They’ve produced this report that makes it appear they have several options, but the only one that truly works is the most expensive of the bunch.”



Friends of Simcoe Forests Gears Up Fight Against Organics Dump on Horseshoe Valley Road


Newly Incorporated Community Group Prepares to Battle with Simcoe County Council

SPRINGWATER, ON, AUGUST 04 - The Friends of Simcoe Forests are organizing an aggressive campaign to push back against Simcoe County Council’s plan to develop the Freele Tract of the Simcoe County Forests into waste management infrastructure.

Last month, Simcoe Council approved the development of an Organics Processing Facility and Materials Management Facility within the Freele Tract, using a flawed site selection process that favoured turning forestry lands over for industrial use.

Council has a plan and timeline to seek planning approval to move forward with the site, even though site suitability assessments, technology decisions and a solid business case have not been established.

“We are bewildered at Council’s drive to move forward with an organics dump on forestry land, despite failing to demonstrate there is a need for such a facility anywhere in Simcoe County, let alone on land that has been set aside from development,” said Mike Shoreman of the Friends of Simcoe Forests

“This isn’t just about the Freele Tract as Council encouraged the consideration of dozens of forestry tracts across the county, leaving all forestry users and host communities at risk for other poorly thought out, unnecessary infrastructure that is totally incompatible with current land uses,” Shoreman added.

The group has launched a website and organized write in campaigns to decision makers, held public meetings and recently engaged legal counsel and a public affairs firm to assist in preventing this decision from moving forward.

“This issue is extremely important for all county residents. There are many reasons to believe the economics of this project will cost all taxpayers and ratepayers more than the current organics management structure in place, and be far less flexible to future needs than the current arrangement. Council’s decision to rush this decision through without the necessary due diligence is absurd and needs to be halted,” said Bob Wagner, another of the Friends of Simcoe Forests.

Anticipating Council’s un-willingness to change course and agree to work cooperatively with the Friends of Simcoe Forests, the group is planning outreach to elected officials who make up County Council and their constituents, believing that the facts would guide any informed debate against moving forward.

Trees, not Trucks: Fighting to Protect Simcoe County Forests From Industrialization


SPRINGWATER, AUGUST 10, 2016 - Friends of Simcoe County Forests is calling on Simcoe County to stand behind their twenty-year vision for the municipal forests and stop their plan to permanently destroy the Freele Tract. No where in Council's twenty-year forestry management plan 'Simcoe County Forests 2011-2030' is there discussion of taking a tract of County Forest for the purposes of creating waste management infrastructure or to

destroy any section of forest for any other industrial or infrastructure purpose.  Simcoe County Forests has a proud history that dates back more than 100 years. What began as an effort to 'rehabilitate wastelands' in the early 1900's apparently is about to devolve into turning one of these tracts back into a wasteland, as home to Council's unnecessary, multi-million dollar organics facility.

'The policy of putting these lands under forest management has many arguments in its favour. It will pay as a financial investment; assist in insuring a wood supply; protect the headwaters of streams; provide breeding ground for wild game; provide object lessons in forestry; and prevent citizens from developing under conditions which can end only in failure'.[I] - Final Paragraph of E.J. Zavitz, the Provincial Forester's 1909 report titled "Reforestation of Waste Lands in Southern Ontario", which led to the creation and protection of Simcoe County Forests.

Even the County acknowledges this history on their own website where they say the Simcoe County Forests were "established to rehabilitate 'wastelands', these forests provide a multitude of environmental, social, and economic benefits to the County including protection of wildlife habitat and water resources, public education, recreation, scientific research and the production of wood products. "[2]

"Reading this, it appears that Council has decided that 2016 is the year they ought to renege on over a century of proud history and begin the process of returning county forests to literally wastelands, by dumping household waste in them." Said Karen White, a Simcoe County community member. "What is most stunning about this decision to create new wastelands is the fact that there were a number of industrial sites available for consideration

that were rejected for reasons less significant than a more than 100-year track record of doing the right thing." White added.

Friends of Simcoe Forests are calling on County Councillors to stand by their forestry management plan and stop this flawed approval process that has favoured and people have known better to develop for more than 100 years.

[1] Link to Council's 2011-2030 Forestry Plan ( ) (quote on Page 4)

[2] Link to Council's Forestry Page


The Friends of Simcoe· Forests Inc. is a Non-Profit organization consisting of concerned citizens within the region of Simcoe County, Ontario.

Our long term goal is to inform and unite all persons interested in the conservation of our County's forests. We encourage all local residents, visitors and friends of our environment to realize that they have the ability to enjoy the natural flora and fauna of the region, as well as the natural beauties of the forests within Simcoe County. As a group we encourage beautification, preservation, and extension of parks and Green Belts.

Through our mutual love and concern for the county's forests, we strive to make available all known statistical, scientific, horticultural and botanical information that positively impacts the future of our forests.

It is our goal to promote the protection and appreciation of the environment and lands which are there for all of us and future generations to use and enjoy.

Forest No Place for Fire Hazard

Simcoe County’s plan to place an Environmental Resource Recovery Centre in a forest within Springwater Township raises serious safety concerns, according to The Friends of Simcoe Forests. The recently announced relocation of the centre places residents even closer to this “high hazard” building.


An Environmental Resource Recovery Centre is considered a Group F, Division 1 High Hazard Industrial Occupancy building. It is “an industrial occupancy containing sufficient quantities of highly combustible and flammable or explosive materials to constitute a special fire hazard because of their inherent characteristics”. This is the highest level of hazard indicated in the Ontario Building Code Act.


“The Friends have concerns that the County’s protective services are not sufficiently prepared to meet this threat, and will require extra resources that are not considered in the current plan,” said Mary Wagner of Friends of Simcoe Forests. “The County continues to alter their plans for the site and reduce setbacks, moving the proposed building closer to the homes of local residents.”


Fires at waste management facilities are not uncommon. On October 27, there was a fire at the Wasteco Plant in Hamilton. This is a recycling facility similar in nature to the one proposed for Simcoe County. This same facility had another fire in April of this year. This location has had six fires in the last eight years. 


Nor is it a problem isolated to that particular facility. Another waste facility in Edmonton, which had been touted as a “Centre of Excellence”, caught fire in August and prompted an air quality advisory for local residents. Six fire departments had to be called to fight a blaze at the BFI recycling plant here in Springwater Township three years ago.


A fire at a waste recycling facility in Cambridge last October caused millions of dollars of damage. There was a massive fire at an Ajax garbage waste disposal building last month. Three recycling centers in the United States caught fire on the same day last month – in Seattle, Indiana, and California.


“This is a major reason other municipalities place these facilities away from the residential neighbourhoods they serve,” said Stacey Irwin. “Every other municipality we have found builds their recycling facilities on industrial land and not in the middle of flammable forests.” 


By choosing to build this facility among the trees of the Freele Forest, County Council is taking an enormous risk. Fire is a known hazard of recycling facilities – even resting piles of composting organic material can self-combust. This facility endangers the safety and security of homeowners, and is a significant insurance risk for the municipality.

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