Environmental Registry of…

Environmental Registry of Ontario

Reference: Proposed Gravel Pit 1894-1922 Witmer Road, Petersburg
Jackson Harvest Farms Ltd.
Comments on reports submitted with application at public meeting January 13 2020.

Water
1. Issue: removal of natural capital (filtration)
Impact: increased risk of contamination of groundwater
2. Issue: wash ponds
Impact: water use and possible groundwater contamination
3. Issue: request for a permit to draw water for wash ponds and dust mitigation (?)
Impact: reduce dilution capabilities of current aquifer and reduce the availability of water
to private and possibly municipal wells
4. Issue:extraction close to water table
Impact: potentially breaking through to the water table and the filtration surface water as
it travels to aquifer
5. Issue: asphalt recycling
Impacts: introduction of potential contaminants
6. Issue: altering catchment area of wetland
Impact: possible implications to the function of the provincially significant wetland that
seems to filter the surface water of nitrates
7. Issue: cumulative impacts not addresses
Impact: when all licensed pits are up and running, the cumulative impacts could greatly
impact water quality and quantity.
Expert opinion of Hydrogeological Report
● Lack of protective aquitard demonstrated
● Lack of certainty of water flow demonstrated
● Lack of testing to determine water table
● Lack of consideration for impacts to private wells
● Concern with impacts of wash ponds not addressed
● Lack of monitoring program proposed

Dust and Noise
1. Issue: homes (sensitive receptors) surrounding proposed pit within the 120m set back
Impact: physical and mental health implications (particularly for young and old)
2. Issue: hours of operation, weekends and nights
Impact: disruption of sleep and degradation of life in an established community

Road
1. Issue: township road with minimum sight lines, no shoulders, guard rails, and hidden
driveways
Impact: safety of all who use Witmer Road
2. Issue: traffic impact to current recreational and agricultural road use
Impact: loss of the recreational enjoyment of Witmer Road (and other roads as this acts
as a connection to Sandhills), safety of residents, and farmers
External Review to come from Township (our expectation is that consideration of recycling
traffic, appropriate operational days, and size of trucks has been reviewed)
3. Issue: dangerous left hand turn required at intersection of Bleams Road and Witmer
Road
Impact: increased safety risk at intersection

Agricultural Impact and Rehabilitation
1. Issue: failure to consider local agricultural operations
Impact:
2. Issue: questionable rehabilitation back to farmland in Wellhead Protection Area and
Regional Recharge Area.
Impact: an abandoned pit, loss of prime farmland and/or contaminated groundwater from
future agricultural activity with natural capital removed

Other things to Consider
● Wilmot is a cohesive and vibrant community providing the Region (and beyond) with a
reliable source of food and water
● Climate Emergency targets
● Impacts of climate change

Geotechnical Investigation
Although the MTE report was thorough in what they did., the report is grossly inadequate in assessing the entire road or any of the surrounding roads.
Transportation Impact Study
The Transportation Impact Study does not address any of the following "IMPACTS".
School bus safety. What is the impact of all these trucks n the safety of our children.
What is the impact on emergency services. The road has no shoulders, you could not pull over even if you wanted to..
There are a number of dangerous blind hills on Witmer Road. This has not been addressed in the report. What is the impact on adjacent properly owners safety.
Witmer Road and Queen Street is a blind intersection. Impact on safety? There have been fatalities at this corner.
Witmer road is heavily used by cyclist in the summer. A resident stated there are more bicycles than cars that use the road. Impact on enjoyment? Impact on safety? Impact on recreational use? Would the proposed zone change affect the Wilmot Township multi-use trail system plan?
Impact on farm equipment and waste management trucks not addressed.
Wilmot Official Plan requires a transportation impact study indicating how the proposed operation will address any potential impacts on Township roads, Regional roads and provincial highways.
The study does not address the impact of the cumulative additional traffic on other local roads. I would expect a minimum of 10 km surrounds be assessed in their impact study.
What is the impact on properties in the area.
The study does not address the impact of the additional traffic on local residents.
Rehabilitation - over 1 million cubic meters of fill. To bring in that much fill. It would take 115,250 in additional truck traffic, that is not accounted for in the report.
The findings and conclusions of this study that no operational improvement be made - are highly questionable. May be they should get their numbers right with all the factors I have mentioned.
Other Questions
From The Source Protection Atlas the elevation of the pond is 355.0 meters, the same as the pit floor.
In the Hydrology Report the measured water level in one of the monitoring wells is 355.59 meters, 2 feet above the the pit floor elevation.