The proposed site is…

ERO number

013-1325

Comment ID

27278

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed site is farmland. This proposal would contribute to the erosion on Ontario farmland and Canada's food security. Stop aggregate extraction from trumping all other land uses #FoodAndWaterFirst ------------------------------------------------- Strada Aggregates Inc., Township of Melancthon, County of Dufferin Part of West Half of Lots 12 and 14, Concession 3 O.S., Geographic Township of Melancthon. This site is located west of the community of Horning’s Mills and straddles (to the north and south) Aggregate Resources Act (ARA) Licence # 129167. Instrument Type: Issuance of a Class A licence to remove more than 20,000 tonnes of aggregate annually from a pit or a quarry - ARA s. 7 (2) (a) ------------------------------------------------- There are already 4 pits in the immediate area for a combined total of 184 ha/453 acres. The proposed site is farmland and forest. - What are the cumulative impacts of all four sites? Air quality? Water quantity and quality? Noise? Local residential housing prices? - Where is the rehabilitation promised the community? Why does the finish line keep getting pushed back? - The aggregate industry has already acknowledged that land is worth less when they finish with it, having applied to lower the classification of spent pits and requesting retroactive tax refunds accordingly. As former Clearview Township Councillor and owner of The New Farm, Brent Preston said, “Aggregate sells for an average of $8 a tonne in Ontario. The salad mix I produce on my farm sells wholesale for $18,000 a tonne. I can produce salad in perpetuity. You can only mine a tonne of gravel once.” The land is more valuable as perpetual farmland. ------------------------------------------------- I am an Ontario Resident and Taxpayer. I ask that the Government of Ontario and the Ministry of Natural Resources & Forestry: 1. Make conservation of aggregate, a non-renewable resource, a priority over approval of new extraction sites. Conservation can occur through aggregate recycling and use of alternative materials. All three levels of government need to be encouraged to use recycled product. 2. Reserve virgin aggregate, a non-renewable resource, for use within Canada. 3. Prohibit aggregate extraction below the water table without a full Environmental Assessment and full understanding of the impact on all areas, near and far. 4. Prohibit aggregate extraction below the water table in drinking water source areas. Ontarians need source water protection. 5. Develop a process and guidelines for identifying and designating new Specialty Crop Areas to safeguard unique agricultural land resources. Prohibit aggregate extraction in Specialty Crop Areas. 6. Conduct a thorough study of all existing aggregate reserves in Ontario. We cannot know what we need until we know what we have. 7. Develop an “Aggregate Master Plan” and disallow new aggregate mining licenses within environmentally protected spaces until the “Aggregate Master Plan” has been fully approved by the people and the province. Align the “Aggregate Master Plan” with existing environmental protection legislation including the Greenbelt, the Niagara Escarpment Plan and the Oak Ridges Moraine. 8. Provide an assessment of the cumulative affects (dust, noise, air quality, traffic emissions; effects on water) of the “Aggregate Master Plan” on Ontario residents by district. 9. Require that new aggregate proposals demonstrate need for additional resource extraction in meeting the demands of the Ontario market. 10. Mandate that an Environmental Assessment occur for all new or expanding aggregate operations. 11. Realign the cost of virgin aggregate to reflect reality. Economically, aggregate is a low-priced, heavy-weight commodity that takes the bulk of its cost from transportation. Today, however, the price of virgin aggregate must include the activism necessary by residents to fight for their best interest despite the elected and public institutions designed to represent and protect the public interest. As well, the cost must encompass the environmental cost on residents. In other words the market cost for virgin aggregate is unrealistically cheap. Create a management system that works for residents and price the product accordingly. This is called full cost accounting. 12. Implement “social licencing” where operators must earn the right to continue extraction through responsible operation, and timely and progressive rehabilitation. 13. Include an end to the aggregate licence, a “sunset clause”. Legally, all contracts require a termination point. Give communities a light at the end of the tunnel. Operators have a tendency to keep a near exhausted site active enough to avoid rehabilitation due to the expense. Or, they extend the life of the operation by accepting commercial fill – the more contaminated/suspect the fill the higher the fee earned. 14. Help to protect Ontario’s food security by prohibiting aggregate extraction on prime class 1, 2, 3 and 4 farm lands. Ontario’s legislation does not take today’s values of minimal environmental impact on water, food land and living space into account in a comprehensive and integrated fashion. Ontarians need food land protection. Until such time as my above-noted concerns are addressed and whereas there is no Aggregate Master plan, I object to the establishment of this new aggregate resource.