I am writing to support the…

I am writing to support the request that the proposed Reid Road Reservoir Quarry (RRRQ) be subject to Ontario’s Environmental Assessment Act. Further, it is my position that the proposed quarry not be exempt from any environmental assessment (EA) requirements. Indeed, given the environmental concerns and the potential risks to human health the RRRQ poses, it and JDCL should be subject to the most stringent environmental assessment requirements possible.

Further, the development of a comprehensive Terms of Reference for the EA is critical to ensure the process is thorough and that it addresses all of the potential harm caused to: the natural environment, including biodiversity and bird, animal and plant species; air and water quality; and human health. The Terms of Reference need to include MECP’s right to “refuse to give approval to proceed with the undertaking”.

In addition, given the potential risks posed by the proposed quarry and the public interest, defining the Terms of Reference must be open, transparent, and allow for the full participation of the public, including key stakeholders such as the Association of Citizens Together on our Nassagaweya (“ACTIONMilton”).

I am extremely concerned about the impact the proposed quarry will have on the environment and, by extension, on the health of the residents of Milton and Campbellville and on our communities, as well as on the biodiversity and natural heritage features in the area.

Although I recognize there has been some study to date, I do not believe the review conducted by the JART organizations has adequately addressed the serious concerns I have and those concerns identified by ACTIONMilton. I provide a summary of my concerns below.

Water quality and quantity: The supply and protection of clean water is of the utmost importance. I understand James Dick Construction Limited (JDCL) wants to use an underwater blasting technique that it claims to have used successfully at the quarry in Guelph. However, I also understand that JDCL breached the aquitard at the Guelph quarry and, further, that the underwater blasting in Guelph was only under 4 meters of water. In contrast, the underwater blasting proposed at the RRRQ will be under 30 meters of water. It is also my understanding that this underwater blasting technology hasn’t been tried at such a depth anywhere in Ontario. I and my family rely on the Kelso well for our water. I have no interest in being JDCL's "guinea pig" or see them profit and the expense of my health and that of my family and my neighbours and friends.

Given the proposed quarry is positioned over a highly sensitive aquifer which feeds the Kelso well which, in turn, provides drinking water to approximately 20,000 residents in the Town of Milton (including myself and my family), I have very serious concerns about the underwater blasting technology and strongly believe further study is required. I am concerned that the blasts could cause irrecoverable damage to the groundwater that supplies private and municipal wells. Given groundwater flows slowly, residents might not see the impact of the blasting on their wells for several years. Thus, JDCL could deny liability for any future reduction in the quality and/or quantity of water supplying both private and municipal wells.

I understand that JDCL has claimed that “quarrying is a clean operation and water in quarry ponds generally meets drinking water objectives for all chemical parameters.” Firstly, “generally” is not good enough when it comes to drinking water. Secondly, I have to question the accuracy of JDCL’s prediction given their plan to stockpile and reprocess/recycle used asphalt and concrete on-site and within two meters above the water table. Those materials and their processing are another potential source of contamination and, therefore, further study is warranted.

As the Walkerton tragedy illustrates, human error occurs and the consequences can be deadly. It is impossible to say with any certainty that groundwater will not become contaminated by surface water beside the recycling/reprocessing facility.

Risks posed to provincially significant wetlands: The health of wetlands contribute to the health of a watershed and, therefore, to the environment and human health. The importance and value of wetlands, especially provincially significant wetlands, cannot be overstated and include the following:

• groundwater storage and release
• provision of habitat for wildlife species, including species at risk
• ecosystem productivity and biological diversity
• flood damage prevention
• harvestable product provision
• improved water quality
• recreational opportunities

JDCL has not provided sufficient information to demonstrate how it will protect the provincially significant wetlands on and/or adjacent to the site. Even if managing water levels is achievable (and that is not a given), simply managing water levels will not protect this important ecosystem from the incessant dust, blasting, noise and truck traffic the RRRQ will produce. A thorough environmental assessment is necessary to determine the impact of the proposed quarry on the provincially significant wetlands and to determine if licensing the RRRQ quarry would comply with the Provincial Policy Statement.

Air Quality: Quarrying creates fine particulate matter (PM 2.5) which is a known health hazard. Greater exposure increases risk. The risk to public health posed by this invisible dust, particularly beside a major highway with wind gusts created by fast moving vehicles and through expansive open spaces, has not been quantified or studied adequately.

The production and circulation of PM 2.5 as a result of quarrying so close to the communities of Campbellville and Milton raises very serious concerns, not just about human health, but for the health of our water, our watershed and all living creatures who reside here. A thorough environmental assessment is crucial to determine the impact of the proposed quarry on air quality and all of the risks posed by PM 2.5. Note that Milton continues to be one of the fastest growing communities in Canada. We are no longer the small Town we once were and the next three years will see an explosion in residential and commercial development. That is to say that the number of people impacted by the RRRQ is increasing rapidly. If COVID-19 has taught us anything, it is that we need to stop taking our environment for granted, including the air we breath.

Haul routes and uncertainties re flyrock: It is my understanding that the impact of the proposed RRRQ on Highway 401 traffic has not been within the scope of the studies conducted to date. Fully loaded gravel trucks (approximately 16 trucks leaving the site per hour, six days a week for 12 to 13 hours a day), many of which will be entering and exiting Highway 401, will disrupt traffic flow and cause some congestion (and an increase in pollutants) on the 401 highway and on local roads. During times of highway congestion and when traffic is re-routed due to emergencies on Highway 401, gravel trucks will opt to use municipal roads and/or will be diverted on to municipal roads. The impact of gravel trucks idling and travelling through the communities of Milton and Campbellville has not been adequately studied. I support ACTIONMilton’s position that a complete highway corridor management study is required.

Similarly, the potential for flyrock and its impact requires further study. Residential and commercial buildings, Highway 401, and the Canadian Pacific and Guelph Junction rail lines are all within flyrock range. The risk of, and damage from, flyrock events must be assessed. It is my understanding that, because the blasting will take place adjacent to a pond, JDCL has deemed the risk of flyrock to be inconsequential. It is unclear how JDCL arrived at that conclusion.

The Concerned Residents Coalition in Rockwood provided expert evidence that illustrated 500 meters is the appropriate setback for flyrock. Highway 401 is only 50 meters from one of the quarry ponds. Flyrock hitting the 401 could have deadly consequences. Flyrock hitting the Canadian Pacific rail line that runs just south of the proposed site could result in an environmental disaster. There are vertical forces as illustrated by blast mats that lift on detonation of a charge. Such forces are not 100% controllable and flyrock can result. Lastly, there is exposed vertical rock above the pond water level that will not be mitigated by the presence of water. Again, it is unclear how JDCL concluded that the risk of flyrock will be inconsequential. Further study is required.

Noise: In addition to the noise caused by the blasting vibration, there would be incessant noise caused by the extraction and crushing of rock, the acceleration/deceleration of 16 gravel trucks leaving the site each hour 6 days a week, and very likely noise caused by the recycling/reprocessing of concrete and asphalt on-site. Further study of the noise the proposed quarry will create is required.

In conclusion, I am requesting the following:

i) That there be a comprehensive environmental assessment;
ii) That the proposed quarry not be exempt from any environmental assessment requirements;
iii) That the public, including key stakeholders such as ACTIONMilton, be involved in defining the Terms of Reference for the EA.
iv) That the Terms of Reference include MECP’s right to “refuse to give approval to proceed with the undertaking”.