Dear Chief Hernen:
A number of our members have brought to our attention proposed training exercises slated to take place at 76 Hunts Road in Chaffey ward. As taxpayers and residents under your protection we recognize both the value of realistic live fire training for firefighters and the lure of frugal opportunities for such training, however, we have some serious concerns arising from our previous experience several years ago at 77 Cottage Lane.
Our concerns can be roughly subdivided into two main areas: impact on local residents and impact on the environment. With regards to the former, three serious incidents arose from the Cottage Lane experience. The first was during the preparatory phase, when heavy equipment was negotiating the narrow dead-end private road to prepare the site for the evolution. A resident at 115 Cottage Lane simultaneously suffered a stroke, and the ambulance was unable to pass the equipment, forcing the attendants to abandon their vehicle on the road and continue in on foot, causing delays in treatment and transport.
The second and third occurred during the actual burn phase, when flying brands burned holes in a boat cover at 87 Cottage Lane and smoke hugging the ground triggered an asthma attack in a resident at 21 Cottage Lane. These properties are at a considerably greater distance than the adjoining properties of the subject lands. The home at 70 Hunts road is located a mere 59 feet from the proposed burn and the home at 110 Hunts Road is only 56 feet away. The proposed burn is overhung by mature trees and surrounded by vegetation, providing a potentially huge fire load should flying brands inadvertently extend beyond the intended confines. Frankly, the site does not conform to the Town of Huntsville's own burning by-law, which requires a minimum separation of 100 meters and bans the burning of construction materials and were it not for section 3.2 would preclude this exercise. The site does not comply with the Outdoor Fires regulation under the Forest Fires Prevention Act.
Therefore, we would appreciate the opportunity to review your proposed deployment and location of apparatus, schedule of exercises, and contingency plans at your earliest convenience. In addition, we ask that area residents be provided in advance with an expedited reimbursement process for damages suffered as a result of these planned exercises.
We are also concerned about the environmental impact. The subject property is waterfront, located on Palette Lake. The property is very low, with the sand base barely above the high water mark. Some portions near the water's edge might even be considered "wetlands" in the sense that they are a virtual bog during high water events. Palette Lake is a small headwater lake with an unusual shape and a very low average flushing rate. The unusual shape probably restricts flushing rates even further in the pocket on which the subject lands are located. It is home to a variety of fish species, including rainbow trout, bass and perch.
As you know, household fires generally produce a wide variety of deleterious substances ranging, literally from A (arsenic) to Z (zinc). That can be mitigated somewhat by removing the contents, but the building materials themselves can and will contribute to the resultant soup. This particular building dates from the mid 1950's and has seen various renovations over the years. One can typically expect multiple layers of materials, as walls are repainted and floors recovered. For example, the nice new steel roof may well be concealing multiple layers of asphalt shingles. . . Particular concerns associated with building materials from that era include asbestos (appears in roof shingles, dry wall, attic insulation, ceiling tiles, joint compounds and electrical wires), lead (appears in soldered joints, paints, electrical wiring), mercury (lighting, flooring, electrical devices, piping, paints) and dioxin (paints, floor coverings, glues and sealants, piping, wiring). These toxic substances are both released into the air and contained within the runoff from the associated fire streams.
In an emergency, fire departments are granted great latitude by the MOE from normal spill reporting requirements. However, as a planned training exercise, such releases constitute a class IV spill under the Environmental Protection Act. We would appreciate the opportunity to review your application for a Director's Consent for the planned release.
Similarly, as this undertaking will likely result in the deposit of a deleterious substance in water frequented by fish, and therefore is subject to the Fisheries Act, we would appreciate the opportunity to review your application to the Minister outlining the plans, procedures, evaluations and other information related to the impact on the lake generally and the fish habitat in particular.
It should be noted that our concerns are related to the live fire evolutions only. We believe that the opportunity to teach and practice non-fire evolutions in a realistic but safe environment is invaluable. Search and rescue drills in the unfamiliar terrain utilizing blacked-out facepieces and/or simulated smoke, self-rescue training such as breeching, bailing and entanglement drills, ventilation practice and so forth consume scarce tax dollars that can be saved by utilizing an existing donated structure.Â
Sincerely,
Dwayne Verhey, Secretary, LWRA