~Halton ~~=~~~--R EGION Legislative & Planning Services Department Planning Services July 30, 2018 11 51 Bronte Road Oakville ON L6M 3L1 Lesley Griffiths, Panel Chair Milton Logistics Hub Project Review Panel c/o Canadian Environmental Assessment Agency 160 Elgin St. Ottawa ON K1A OH3 By email: [email protected] CEAR registry 80100 Dear Ms. Griffiths: RE: Halton Municipalities' Comments on CN Responses to Information Request Packages 2 and 3 On behalf of the Halton Municipalities, I am writing to provide the panel with comments regarding CN's responses to the review panel's Information Request Packages 4.1 , 4.2 and 5 (IR-4.1, IR-4.2, and IR-5). The team of technical experts retained by the Halton Municipalities has reviewed the CN responses to the panel's information requests in these three IRs. Based on the expert team's review and advice, the Halton Municipalities make the information requests set out in Attachment #1. We may also advise that we look forward to receiving the information from CN in response to the panel's Information Request Packages 6 and 7. We consider the missing information essential to assessing the sufficiency of information for several CEAA factors of assessment. Sincerely, <Original signed by> Curt Benson, Director, Planning Services & Chief Planning Official On behalf of the Halton Municipalities Attachment Regional Municipality of Halton HEAD OFFICE: 1151 Bronte Rd, Oakville, ON L6M 3Ll 905-825-6000 I Toll free: 1-866-442-5866 halton.ca (: 311 "# 11 1m You(ID HALTON MUNICIPALITIES BRIEF | 1 R EVIEW OF C N R ESPO N SES TO J ULY 2 0 1 8 I N FO R MATIO N R EQUESTS 4 - 5 Halton Municipalities’ Sufficiency Review Regional Municipality of Halton Corporation of the City of Burlington Corporation of the Town of Halton Hills Corporation of the Town of Milton Corporation of the Town of Oakville CEAA Panel Review of the CN Milton Logistics Hub Project CEAA Registry No. 80100 CN Milton Logistics Hub Project Panel Review HALTON MUNICIPALITIES BRIEF Regional Municipality of Halton Chair: Gary Carr CAO: Jane MacCaskill Corporation of the City of Burlington Mayor: Rick Goldring City Manager: James Ridge Corporation of the Town of Halton Hills Mayor: Rick Bonnette CAO: Brent Marshall Corporation of the Town of Milton Mayor: Gordon Krantz CAO: Bill Mann Corporation of the Town of Oakville Mayor: Rob Burton CAO: Ray Green Contact: Regional Municipality of Halton 1151 Bronte Road Oakville, ON L6M 3L1 311 or 905-825-6000 Toll Free 1-866-442-5866 (1-866-4HALTON) TTY 905-827-9833 Fax 905-825-9010 Art Zuidema Commissioner, Legislative & Planning Services <email address removed> Curt Benson Chief Planning Official <email address removed> Milton Logistics Hub Panel Review Questions or comments? Contact: Regional Municipality of Halton 1151 Bronte Road Oakville, ON L6M 3L1 311 or 905-825-6000 Toll Free 1-866-442-5866 (1-866-4HALTON) TTY 905-827-9833 Fax 905-825-9010 Email [email protected] Art Zuidema Commissioner, Legislative & Planning Services <email address removed> Curt Benson Chief Planning Official <email address removed> HALTON REGION – COMMENTS REGARDING SUFFICIENCY OF RESPONSES TO PANEL IR-4.1 IR 4.1 EFFECTS OF PIPELINE RELOCATION AND MITIGATION Panel Request a) Further describe how CN intends to relocate the pipelines on its property. Clarify whether the augers/drill rigs referred to in Appendix E.10 and Appendix C of Appendix E.1 are representative of the drill rigs that would be used for the directional drilling required for pipeline relocation. b) Confirm that no open cuts would be required for pipeline relocation work. c) Clarify whether, when considering Project interactions with valued components, “utilities” referred to the pipeline relocation activities. d) Provide details of the potential environmental effects associated with the pipeline relocations and how CN would mitigate these effects. Valued A.1 Topography and Soil; E.1 Migratory Bird Species Components Rationale A complete answer to (d) was not provided: . Nesting birds, including SAR birds, may be disturbed if intrusive archaeological excavations are conducted in the nesting period from end of March to end of August. As the majority of the pipeline realignment will be in open cut installation within farmland areas, trenches which are typically 3 m deep will be necessary. This will entail significant volumes of temporary earthworks which may become sources for soil erosion. The bedding and cover materials for the pipes may become conduits for perched and groundwater preferential collection and movement. Further Please clarify: Information 1) Whether pipeline relocations will be occurring within the nesting period for birds, from March- Request August. 2) The anticipated length and depth of the open cut installations, as well as how the temporary stockpiling of the cuttings have been accounted for as potential source for soil erosion. 3) Whether the realigned pipeline trenches would be treated with seepage collars, as is standard for utility trenches. IR 4.2 PREDICTIVE LIGHT EFFECTS MODELLING Panel Request a) Provide a rationale for using the Extech EA33 light meter to measure baseline conditions. b) Explain how winter snow cover could have influenced the results of the baseline survey. c) Provide a quantitative assessment of the predicted future glare and sky glow resulting from Project lighting. Compare the results against baseline conditions and relevant guidelines where appropriate. d) Describe the additive effects of light from various sources on receptors (i.e., light trespass, glare, and sky glow). Valued C.3 Ambient night-time levels Components Rationale Important information was not provided, which is necessary to determine baseline conditions and the magnitude of the anticipated impact due to the project: . The Extech EA33 light meter used by CN is problematic for measuring baseline conditions. Though current (baseline) trespass measured through illuminance may be below 0.01 lx, it is premature to declare this as insignificant. The neglected CIE recommendations for luminaire brightness (related to glare) limitations should form part of the rationale for using this meter, including a description of how and whether this meter may measure such impacts. 1 . It is necessary to include increased albedo in the Project and surrounding region, as well as direct upward lighting fraction for all lighting including that in the region. It can be expected that snow reflectance will increase project impacts to a greater extent than impacts from (distant) urban lighting since the urban areas will have (1) less extensive long-term snow coverage, (2) greater structural blocking, and (3) more direct uplight (which is not amplified by snow cover). As well, the response provided regarding sky glow changes appears incorrect – an increase of 0.10 – 0.18 magnitude corresponds to a 10% – 18%, not ~1%. No information is provided concerning uncertainties in baseline assessment based on measurements obtained on only two nights in both 2014 and 2018 (either range or average fires), preventing assessment of the robustness of the baseline measurement and the 2014-2018 trend. Insufficient information is provided concerning the methodology used for future sky brightness assessment. There is no response concerning quantitative luminaire brightness (glare) changes, nor comparison to baseline conditions or relevant guidelines. Further 1) Address the inability of the Extech EA33 light meter to measure current (baseline) conditions, Information and the implications of this deficiency for comparing the Project impacts to the baseline Request condition. The response must also address pertinent CIE recommended limits to luminaire brightness (glare), and how this meter may be used to determine if the Project lighting would exceed these limits. 2) Provide a corrected and adequately documented future sky glow analysis. Provide an adequately documented comparison to baseline illuminance (trespass) and CIE luminaire brightness (glare) recommendations, including assessment of uncertainties in baseline sky brightness measurements performed in this work, and the effect of this uncertainty on predicted fractional increases. 3) Describe the additive effects of light trespass (illuminance), including that arising from the multiple fixtures (emitters) included in the Project as well as other sources such as roadway lighting and other developments. Describe additive effects of glare (luminaire brightness), including that arising from the multiple fixtures (emitters) included in the Project. IR 4.4 LIGHT FROM VEHICULAR TRAFFIC Panel Request a) Provide an assessment of potential off-site effects from on-site vehicular headlights within the terminal and at higher vehicle traffic areas such as trucks turning into and out of the entrance/exit along Britannia Road. The assessment should include such factors as location, topography, glare, and the potential for vehicle travel over raised terminal roadway. Valued C.3 Ambient night-time levels Components Rationale CN has only provided qualitative statements, which do not provide the data necessary to justify their conclusions with regard to the impact of nighttime activities, in particular, the conclusory statement: “the potential effects of a change in lighting from the Project on nearby receptors are expected to be noticeable, but not substantive to a point where the change is likely to be disruptive.” Further, the fractional increase at night would likely be larger than is described. It is important to have a good understanding of the quantity of resulting impacts on lighting so that their magnitude can be determined. Further 1) Please provide a quantitative assessment of the impact of vehicular headlights on off-site Information receptors. This is needed to validate the assertions contained in the CN response. Request 2 IR 4.5 MITIGATION MEASURES FOR LIGHT Panel Request a) Provide additional information about the effectiveness of proposed mitigation measures including different technologies available for light trespass, glare and sky glow, including a graphic representation of the proposed light shielding mitigation for light spill and glare (e.g. showing glare and spill both before and after mitigation).