I am submitting this comment…

I am submitting this comment in support of the concerns identified by planning staff for the Township of Ramara Township regarding the proposed amendment to Environmental Compliance Approval No. 6332-A2GNRY for the NRK Holdings Inc. excess soil processing and transfer site at 7406 Concession Road B-C.
As outlined in the Township’s December 22, 2025 memorandum to Council, the proposed amendments would significantly intensify and expand the existing operation. The requested changes include doubling daily processing capacity, substantially increasing on-site storage, expanding the service area to all of Canada, extending operating hours, and permitting 24-hour emergency acceptance of waste. Collectively, these changes alter the scale, function, and impact profile of the site well beyond what was originally approved.
I share staff’s concern that several elements of the proposal — including the inclusion of a transfer station function and the acceptance of certain untreatable soils — may not be permitted under the current Official Plan and Zoning By-law. Proceeding with a provincial approval while municipal land-use conformity remains unresolved risks creating a regulatory disconnect and undermining local planning authority.
The Township has also appropriately raised concerns regarding haul routes and traffic volumes. Increased daily tonnage and an expanded service area will inevitably result in additional heavy truck traffic on local and regional roads that are not designed for sustained industrial use. This has implications for road safety, infrastructure maintenance, noise, dust, and cumulative community impacts.
I further support staff’s caution regarding environmental protection, particularly groundwater and surface water. The proposed acceptance of less-restricted or untested soils, combined with increased processing and storage volumes, heightens risk and underscores the need for strong, enforceable safeguards — not reliance on monitoring after impacts occur.
Given the scale of the proposed changes, this amendment should not be treated as minor or administrative in nature. It warrants a precautionary approach that fully integrates municipal planning controls, site plan conditions, and clear limits on operational intensity.
I respectfully urge the Ministry of the Environment, Conservation and Parks to carefully consider and give substantial weight to Ramara Township staff’s concerns, and to ensure that any decision on this proposal is aligned with local planning documents, community protection, and environmental stewardship.