Regarding: ERO #019-2876, …

Regarding: ERO #019-2876, “Project-specific proposal to designate and exempt the proposed Reid Road Reservoir Quarry (“Quarry”) in Milton under the Environmental Assessment Act.”

As a citizen concerned about the impact on the health and safety of the proposed Quarry on the community, the development of a comprehensive Terms of Reference is imperative to properly direct the assessment. Defining the Terms of Reference must be open, transparent, and allow the full participation of the public, as well as key stakeholders including ACTION Milton.

Below, I provide a list of issues of particular concern to me. Although many details of these issues have been addressed by the proponent’s consultants and have been reviewed in great detail by the JART organizations and their consultants, I remain concerned that the review has not adequately addressed all my concerns.

Underwater blasting below the water table
In the absence of evidence of the successful and impact-free application of underwater blasting, the EA needs to thoroughly assess at least two concerns arising from this method:
• I am concerned that blasting underwater is a technique that has not been demonstrated in Canada to be free of significant negative impacts to surface water and groundwater. Residues from explosives inevitably enter the water flowing through the pit into downstream surface waters as well as into the groundwater aquifer. This has the potential of causing irrecoverable damage to the groundwater supplying private and municipal wells. The groundwater flows slowly meaning that we might not see the impact of the blasting on our wells for several years making it easier for the proponent to deny liability for any future reduction in the quality and/or quantity of water supplying both private and municipal wells.
• Blasting below the water table, whether in a water filled or a dewatered pit, is problematic in itself. The path created between the surface and the groundwater aquifer is a conduit for surface contamination to enter what would otherwise be a relatively pristine water flow, which will also impact downstream wells.

Flyrock
In spite of being widely regarded in the industry as the most dangerous aspect of blasting, the risk of flyrock is virtually ignored by aggregate producers and their consultants in Ontario. The only protection to the public and property is the application of safe setbacks between blast sites and sensitive receptors, an issue which is well addressed by "good practice" setback models developed by the US Bureau of Mines and the Australian engineering firm, Terrock. Therefore, the EA needs to thoroughly assess this risk:
• The potential for flyrock on the 401 does not seem to have been studied adequately. Our understanding is that because the blast takes place adjacent to a pond, risk of flyrock is deemed to be inconsequential. This does not make sense. There are vertical forces as seen when blast mats lift on detonation of a charge; these forces are not 100% controllable and flyrock can be the result. As well, there is exposed vertical rock above the pond water level which is not at all mitigated by the presence of the water.
• The proponent stated that flyrock will not occur because it is not allowed. This is condescending at best and reinforces the need for additional study.

Traffic/Road Safety
• The impact on 401 traffic was not part of the scope of studies done to-date. This is unacceptable. Big fully loaded gravel trucks entering and leaving the 401 will disrupt traffic flow on the 401. A full highway corridor management study needs to be conducted.
• During times of highway congestion, it seems obvious that the gravel trucks will travel on municipal roads. The impact of these trucks travelling through the community has not been adequately studied.

Air Quality
• Fine particulate matter (PM2.5) is a known hazard and greater exposure increases risk. This risk to public health of the additive impact of this invisible dust has not been quantified or studied adequately.

Natural Environment
• It is difficult for me to understand how the value of the site’s Provincially Significant Wetlands is being protected. Simply managing water level (if indeed that is achievable) will not protect against the incessant dust, blasting, noise and truck traffic on this important ecosystem.

• The Province states that the value of wetlands includes:
o groundwater storage and release
o provision of habitat for wildlife species, including species at risk
o ecosystem productivity and biological diversity
o flood damage prevention
o harvestable product provision
o improved water quality
o recreational opportunities

• A study needs to be undertaken to determine whether the licensing of this quarry would be consistent with the stated value of these important wetlands which are rated as being Provincially Significant.

Noise
• Along with the blasting vibration, noise would be incessant from the extraction and crushing of rock and the acceleration/deceleration of gravel trucks 6 days per week.

Recycling/Reprocessing Asphalt & Concrete
• Permitting the stockpiling of used asphalt and concrete on the site and the reprocessing of them is a source of potential contamination which I understand has not been adequately studied.

Definition of Environment
• Additional areas of concern which were not raised as part of the study include the “social, economic and cultural conditions that influence the life of humans or a community”
• As noted in the ERO posting, over 1000 letters of objection were received by the MNRF. If the EA is conducted, each of these letters needs to be reviewed by the MECP to gain further insight into and to address both the technical and overall societal concerns of the community.

It simply does not make sense to license a quarry so close to the community, adjacent to Provincially Significant Wetlands and beside a 400-series highway.

While I appreciate the work that has been done to-date by the local governments, I remain concerned that there are gaps in the studies which present significant risk to the community.

As a final comment, I believe that the findings of this EA need to be considered broadly by the Province in the context of other similar aggregate extraction operations or applications. It would be negligent of government, in my view, to determine through an unbiased, scientific assessment of, for example below water table blasting or flyrock risk mitigation, that such practices need to be prohibited unless it can be demonstrated that no unacceptable impacts will occur, without then applying the same findings to other similar situations. The burden of proof of the safety of the practice must be on the proponent. Current practice in Ontario, through the ARA, PPS and LPAT places the burden of proof of negative impacts on those who would oppose such applications. The Precautionary Principle needs to be embraced by the EA and the Province.

Therefore, I call upon the MECP to include the public in defining a broad Terms of Reference to review the potential impact of this quarry and to exercise the right to “refuse to give approval to proceed with the undertaking”. In other words, support the Premier in his assertion that this quarry will be stopped “one way or another”.