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Mr. Brydon, I would like to include my comments to the document prepared by Cameron Baughen which I had previously emailed you.

Please read the memo (document). It makes a very positive view of selecting Summerland for the RDOS Regional Compost Site. I have made the following summary and comments regarding the memo:

1. The Summerland site does not require re-zoning and is in an area of a number of gravel extraction operations and is the site of the Municipal solid waste and compost facilities.

Comment: Although the Marron Valley Site would not require re-zoning as it is part of the PIB, the land surrounding the site is zoned ALR and some is being used for growing hay and grazing cattle. It seems somewhat hypocritical for the RDOS to sidetrack the intent of the ALR regulations by utilizing land that physical should be part of the ALR and using it as if it was zoned M4 - Resource Industrial Zone. The better use of this land would be agricultural which would make for better neighbours. The Marron Valley site is not currently disturbed by industrial operations.

2. At the Summerland site, the RDOS will make lease payments on the property to the District of Summerland at a rate based on a fair market assessment and the District of Summerland would be the recipients of a tax rate that the facility will be assessed.

Comment: At Marron Valley all RDOS lease money accrues to a single individual untaxable by the RDOS and there will be no taxation of the facility by the RDOS. The lease and tax money at Summerland could be used for upgrading Prairie Valley Road or for building a partial by-pass.

3. No additional buffers are required at the Summerland site by the Province and placing a composting site within the present buffer area may be the highest and best use of the land.

Comment: The Marron Valley site is located in an area, but not in, the ALR and the best use should be consistent with the intent of ALR zoning. This area is also environmentally fragile which slopes down to Marron Lake and a popular Meadowlark Festival Event. An archaeological impact assessment has not been conducted and it is likely that many artifacts will be found.

4. At the Summerland site, improving the current composting process will increase the value of compost for local growers and reduce the cost for shipping for local growers.

Comment: Compost produced by the Marron Valley site would increase the transportation costs for local growers of the Summerland area.

5. An operational compost site in Summerland will produce credits applicable under the Climate Action Revenue Incentive Program which would allow local governments to meet obligations under the BC Climate Action Charter and help fund the compost site which would allow for lower tipping fees which will save Summerland money.

Comment: At Marron Valley, no credits applicable under the Climate Action Revenue Incentive Program will be generated for Summerland or the RDOS.

6. Approximately 3 full time jobs and several part time jobs are expected. Workers would be needed for heavy equipment, scale house operation and office work.

Comment: At the Summerland site, employees will likely be Summerland residents.

7. At the Summerland site, odour modelling indicates that no homes would be within the mapped 5 odour unit limit. Also the wastewater treatment sludge from the present windrow composting at the Summerland landfill would be treated at the Regional facility for reduced odour at the present site.

Comment: Odour modeling has indicated that 31 homes may be affected by odour at Marron Valley. Going ahead with the Marron Valley site with prior knowledge that property values already have been adversely affected may leave the RDOS vulnerable to a lawsuit in an amount equal to the loss in property values plus legal fees. Tax payers of the RDOS do not want another situation like the 1997 Blackwell Stores lawsuit which resulted in a bill of $5.2 million to Naramata residents.

8. A maximum of 20-25 vehicles a day could access the site to deposit materials, although most days there would be fewer. The vehicles would be properly sealed and monitored and would not release an odour until they are unloaded within a building with odour control.

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