Subject: ERO #019-2876, …

Subject: ERO #019-2876, “Project-specific proposal to designate and exempt the proposed Reid Road Reservoir Quarry (“Quarry”) in Campbellville/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 A.C.T.I.O.N. Milton.

I am providing 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 troubled that the review has not adequately addressed all my concerns.

JDCL has applied to extract 990,000 tonnes of aggregate by underwater blasting from the proposed Campbellville Reid Road Quarry. It will be on top of the highly sensitive aquifer that provides water to Milton, Campbellville and surrounding residents. Blasting could open pathways that allow surface toxins to contaminate groundwater and affect water levels which supply the Kelso wells and local residential wells. This quarry will severely impact well water levels, significantly impact wetlands, habitats of endangered and threatened species, and woodlands at the site of which will be permanently destroyed. JDCL has already breached the Guelph aquitard protecting the aquifer at the DoLime Quarry.

"Underwater Blasting" is a disaster just waiting to happen

I am concerned that blasts detonated adjacent to and below the bottom of the pond will 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 quantify of water supplying both private and municipal wells.

"Flyrock"

The potential for flyrock on Hwy. 401 does not seem to have been studied adequately. My understanding is that because the blasts take 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.
JDCL stated that flyrock will not occur because it is not allowed. This is condescending at best and reinforces the need for additional study.

Flying rock from blasting can cause property damage, personal injury or even death and can travel up to 1km. It can be the size of a small microwave oven. Hwy 401 is only 100 meters from the blast areas, as are other Campbellville roads.

The Blast Impact Assessment failed to consider the worst-case scenarios of potential seismic vibrations and overpressure impacts on nearby sensitive receptors (like homes, businesses and Hwy 401).

"Traffic/Road Safety"

Main Traffic Issue is: the risk of clogging access to our Emergency Response Centre (Campbellville Fire Station).

The impact on Hwy. 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.

Hwy. 401 ramps are currently operating at capacity. Trucks travel on any road designated for truck traffic. Traffic Impact Study states that maintaining the existing form of traffic control (a stop sign) is forecast to result in high levels of delay on the off-ramp approaches on Hwy 401. The west bound off ramp is often congested with current traffic levels. If the Hwy 401 is backed up either direction, which it often is, you can expect the trucks will find other routes which will include Guelph Line and our rural roads which are NOT designed to handle gravel trucks.

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. This issue needs serious analysis.

Another SERIOUS consideration is how are the EMS vehicles going to get through the queue of trucks with only 5 feet between east and westbound trucks? And what about the school buses and local residences that live on or adjacent to Reid Side Road?

We measured Reid Side Road and came up with a width of 22 feet (11 feet for the westbound lane and 11 feet for the eastbound lane. A standard gravel truck width is 8.5 feet but usually needs a minimum 10 feet clearance (for mirrors, I guess). If my math still works, that leaves 5 feet between trucks going westbound into the quarry and trucks coming eastbound to pick-up the 401 on Reid Side Road.

"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. These "silent killers" can travel 7.5km in 45 minutes with 10 km/hr winds.

"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"

JDCL plans to fill one pond and create an asphalt and concrete re-processing operation. Their application indicates they intend to bring used asphalt on to the site, stock pile it and recycle it. No limit on how long the re-processing operation will be active, possibly indefinitely.

Permitting the stockpiling of used asphalt and concrete on the site and the reprocessing of them is a source of definite contamination, which I understand has not been adequately studied.

"Damages"

If there is damage to homes or businesses, or loss/contamination of water, the property owner has the burden and cost of proving it was caused by the quarry. JDCL is merely required to self-assess its operation and file a Licensees Compliance Assessment Report. There is no accountability.

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. This quarry poses significant risk to the community.

I implore the MECP to support the Premier in his assertion that this quarry will be stopped “one way or another”.