I wish to support the…

ERO number

019-0556

Comment ID

36001

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I wish to support the submission by the Skeleton Lake Cottagers Organization as copied below. I have grave concerns that the impacts of aggregate extraction will have extremely negative impacts on the pristine quality and beauty of Skeleton Lake. My family have been cottagers on this lake since 1930 and rented from Simolean Beach Lodge for about 4 summers in the 1920s.

Kathi Poupard
kathipoupard@gmail.com

November 4, 2019
Sent via email to: aggregates@ontario.ca
Andrew MacDonald
Natural Resources Conservation Policy Branch 300 Water Street
Peterborough, ON
K9J 8M5
David R. Donnelly, MES LLB david@donnellylaw.ca
Re: Bill 132, Better for People, Smarter for Business Act, 2019
Dear Mr. MacDonald,
Donnelly Law (“we” or “the Firm”) represents the Skeleton Lake Cottagers Organization (“SLCO”), an incorporated group of residents concerned about quarry activity in the Township of Muskoka Lakes.
The Skeleton Lake Cottagers Organization is concerned about the process the province is following for the proposed amendments to the Aggregate Resources Act (“ARA”) and associated regulations for the following reasons:
(i) there are no specific details that allow SLCO to understand and comment on changes to the ARA that may impact its members. Many members of SLCO have properties on Skeleton Lake and their enjoyment of the lake could be negatively affected by activities related to aggregates extraction;
(ii) the time frame for comments on this Environmental Registry of Ontario posting is short; and
(iii) there are no details as to when members of the public will be given another opportunity to comment or the length of time that will be provided to respond to specific changes to the ARA or the associated regulations.

SLCO requests that:
(i) the wording “within the water table” be clarified (e.g. below the water table, above the water table);
(ii) when the Province proposes specific amendments to both the ARA and the associated regulations, the comment period be a minimum of 90 days to enable a determination of the impacts on SLCO and its members; and
(iii)
the issue of the preferred haul route is a very serious
consideration in the Township of Muskoka Lakes due to the
potentially high volume of truck traffic associated with aggregate
operations, interactions with local traffic, tourists and school
busses, as well as the potential for road damage due to the heavy
usage. Based on previous applications in the Township,
implementation of a preferred haul route often requires new road
network improvements (e.g. enhanced intersection control,
turning lanes, etc.), road improvements (e.g. reconstruction of a
road segment) and land acquisitions. (road widenings). It would
be highly prejudicial to local municipalities if they are prevented
going forward from imposing conditions on aggregate producers
and that any future haul route agreements can be voluntary only.
SLCO supports changes to the ARA and regulations related to:
(i) strengthening the protection of water resources for extraction within the water table as part of a more robust application process for existing operations;
(ii) increasing public engagement for applications that may impact water resources;
(iii) enhancing reporting on rehabilitation; and,
(iv) reviewing the notification and consultation requirements for new
applications.
SLCO supports the Township of Muskoka Lake’s decision to deny the
Lippa Planning Act applications for a 200,000 t/annum pit and quarry for up to 80 years of extraction (16,000,000 tonnes total) (the “Application”). On June 16, 2017, Muskoka Lakes Council unanimously voted to deny Mr. Lippa’s Application. On June 26, 2017, the Township of Huntsville voted to support

the decision of Muskoka Lakes. The MNRF is reviewing the associated Aggregate Resources Act application.
Of great concern to SLCO is the potential impact of a new quarry on water quality, natural heritage features, traffic safety, and noise and dust. In addition, SLCO is concerned about the impacts of the quarry on a potentially significant cultural heritage landscape (Skeleton Lake watershed).
Please do not hesitate to contact me at 416-572-0464, or by email at david@donnellylaw.ca, cc’ing alexandra@donnellylaw.ca and morgan@donnellylaw.ca should you have any questions or comments concerning this correspondence.
Yours Truly,
David R. Donnelly
Cc: Client