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.”

Terms of Reference must be open, transparent, and allow the full participation of the public.

This is only a partial list of issues of particular concern to me. Many details of these issues have not been adequately addressed by the proponent’s consultants and have not been reviewed in great detail by the JART organizations and their consultants, I remain concerned that the review has not adequately addressed my concerns.

Underwater blasting
• I am concerned that blasts detonated adjacent to and below the bottom of the pond, could cause 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. This underwater blasting is not safe and does not protect the ground water recharge area. This has already been shown in Guelph, a nearby operation of this type.

Flyrock
• 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 traveling through the community has not been adequately studied.
• At peek travel times, the trucks from the quarry will stall and totally close Guelph Line, Reid Sideroad, and highway 401 in both directions with their congestion.

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
• this area contains "provincially significant" wetlands. The reason for this significance is because this area is an aquifer recharge area. This development will damage and destroy this feature.
• butternut trees populate this area, and these trees, endangered and threatened will be removed and destroyed through the aggregate extraction. The proponent, has already removed and destroyed some of these trees on this property.
• This parcel of land is also home to Ontario's only native orchid. This orchid, and valuable to the province as the Trillium is a more rare species of native and will disappear by this quarrying.
• The proponent states salamander ponds will be replaced, but it is clear through extensive science and study that salamanders return to the pond where they were born and replacement ponds have never been successful in propagation of salamanders. Certainly, "Jefferson Salamanders" occupy this area. The salamander survey done by GWS was far too short, and not properly guided by weather and temperature factors. Temperatures at this time were still cool, and close to 0 degrees C overnight. Precipitation was virtually nil. "FOG", "OVERCAST", "PARTLY SUNNY", "CLEAR". The only precipitation was Mar 30, 2017. "LIGHT SNOW", "SNOW FLURRIES". Nothing more than light rain, drizzle and fog throughout the period. The ideal time to NOT SEE ANY SALAMANDERS". This was not the ideal time to monitor salamander activity. No doubt, the drought of 2016 affected the salamander populations, and preservation of these wetlands in imperative to a continuation of the species through Climate Change and Global Warming.
• The Natural Environment study shows "only one" snapping turtle and therefore no breeding ability. Obviously, turtles travel and migrate so the existence of only one at that time does not warrant the approval of a licence to destroy the habitat of this endangered species. I will also point out that all on Ontario's turtle species are now at risk or endangered.
• blanding's turtle is also know to exist in this area, but GWS was unable to spot or locate this also endangered species. I suggest that the methodology and ambition to find these species was insufficient and the protocol unsatisfactory.
• Kilbride creek is home to brook trout, and this also endangered species will suffer greatly from this invasion and airborne contaminants settling in the stream.
• The butterfly survey was done during a period of "passing clouds", "partly sunny". Not exactly the right conditions.
• This area includes the "Guelph Junction Woods Environmentally Sensitive Area", and protection of this area is not provided by the submission.
• The road into the site is currently a single lane path, and in order to achieve full production and traffic flow, the road will be widened. This widening of the road will destroy several vital ponds that are home to many endangered and threatened species.

• 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.

I implore 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”.