ESPANOLA—Ernest Dodge, owner of H. Dodge Haulage Ltd., is sounding the alarm over what we call a ‘fundamentally illogical’ decision by the Ministry of the Environment, Conservation and Parks (MECP) that threatens waste services for 10 municipalities and six First Nation communities in Northern Ontario, many on Manitoulin Island.
With Ontario projected to have only 12 years of landfill capacity left, the Dodge landfill has the potential to serve the region for the next 60 years. But Mr. Dodge warns that if MECP does not reconsider, he may be forced to fulfill his current contracts and then shut down the site, leaving municipalities and first nations with fewer and costlier waste options.
Mr. Dodge explained his landfill financial assurance obligation, money set aside for future closure of the landfill, was recently increased by 70 percent by MECP. This hike is based not on site conditions, but on MECP’s use of the non-residential construction price index (NR-CPI) which reflects costs of urban building projects like condominiums, plumbing, electrical trades, steel and concrete, none of which are part of landfill closure.
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“Our site shouldn’t be included in this, all we have on our site is earth works,” said Mr. Dodge. He pointed out everything is in place at the Espanola site for expansion.
“MECP reviewers locked in a once-in-a-century COVID era spike as though it were the new normal,” Mr. Dodge said. “They applied Toronto and Ottawa high-rise construction costs to a small-town landfill in Espanola. That’s not environmental protection, that’s bureaucratic box-ticking. A landfill isn’t a condo tower, and MECP should know the difference.”
“We already have a landfill financial assurance obligation of $1.2 million, but this is being increased by 70 percent with this change,” Mr. Dodge told The Expositor, pointing out another landfill owner in Ottawa has gone from $8 to $20 million.
Mr. Dodge explained, “because (MECP) use the landfill financial assurance obligation, they check locations like ours every three years for closure and post-closure activities. They do this by going back 10 years on residential construction NR-CPI, and now that it’s my year and go back three years it is part of the COVID years, so I am paying a significant increase.”
“I am not trying to not pay our financial assurance, but just since the COVID increase, which includes our site being included with other high-rise construction costs in southern Ontario, something we shouldn’t be included in,” said Mr. Dodge. “And they (MECP) gave me three weeks to pay this.”
Mr. Dodge, in a letter to the Honourable Todd J. McCarthy, minister of MECP dated October 8, wrote, “I am writing out of deep frustration with the MECP and its recent decision to increase my landfill’s financial assurance requirement by 70 percent. This landfill’s service area is Manitoulin, Algoma, Sudbury, and Greater Sudbury and presently serves 10 municipalities and six First Nation communities and has the potential to provide secure waste management for the next 60 years. At a time when the rest of Ontario has only 12 years of landfill capacity left, MECP’s decision is reckless and short-sighted.”
“The increase has nothing to do with my site or its closure requirements,” continued Mr. Dodge. “It comes entirely from MECP’s blind reliance on the non-residential construction price index (NR-CPI) and their failure to use common sense when applying it. The NR-CPI reflects the costs of urban building project-trades people, plumbers, electricians, steel, windows, concrete, none of which are part of landfill closure activities.”
“Yet not one MECP reviewer, in all the financial assurance packages they handle, seems willing to acknowledge this obvious mismatch. Instead, they have locked in a COVID-era anomaly, a once-in-century economic shock-as though it were a permanent cost trend. The result is an absurd 70 percent jump in my assurance requirement that will stay in place until 2045,” continues the letter.
Mr. Dodge wrote, “This policy is not only financially destructive, it is fundamentally illogical. It punishes responsible operators who already maintain closure reserves beyond what is required; it ignores regional reality, applying inflated Toronto/Ottawa numbers to small northern communities like Espanola; it jeopardizes essential landfill capacity that municipalities and first nations rely on, all because reviewers refuse to question a flawed formula.”
“If MECP insists on enforcing this misguided approach, I will be forced to fulfill my current obligations and then consider shutting down the landfill,” wrote Mr. Dodge. “That would remove a vital regional service at a time when Ontario can least afford it. I am asking for your support in holding MECP’s reviewers accountable. Their approach lacks fairness, lacks regional understanding, and most of all lacks common sense. It is not environmental protection; it is bureaucratic box-ticking that puts communities at risk. A landfill isn’t a condo tower, and MECP should know the difference.”
Currently, H. Dodge Haulage Ltd. has contracts with Central Manitoulin, Gore Bay and Gordon-Barrie Island, Burpee and Mills, Wiikwemkoong Unceded Territory, and works with Aundeck Omni Kaning and Whitefish River First Nation.
“We have yearly contracts so in two-three months for those communities we have a contract with this could end, so all the municipalities and first nations are in jeopardy if the province doesn’t reconsider,” said Mr. Dodge.
