Tyandaga Environmental…

ERO number

019-4801

Comment ID

59616

Commenting on behalf of

Tyandaga Environmental Coalition Inc.

Comment status

Comment approved More about comment statuses

Comment

Tyandaga Environmental Coalition Inc. "TEC" (www.tecburlington.com ) was established in September 2015 by a group of residents in Burlington seeking to advance policies and practices that protect against environmental and public health degradation. This was initiated with matters related to the quarry holding ARA License 5500.
We are one of a number of groups in the Region of Halton as well as many others across the province that are dealing with the numerous issues related to pits and quarries licensing and the detrimental impacts throughout the quarrying operations and thereafter.

We re-iterate what many citizens, and community and environmental groups express when it comes to the reuse of excess soil at pits and quarries.

These proposed regulations represent significant threats to communities, ecosystems, farmland, surface- and groundwater due to the lack of appropriate soil testing before dumping in pits containing groundwater. They could also mean increased truck traffic, noise, and reduced air quality due to the movement of this soil thus extending the impacts on the community longer.

• Municipalities require funds to develop, monitor and enforce excess soil regulations and bylaws. The financial burden should be at the expense of the companies profiting from soil dumping, not a cost to municipal taxpayers.
• Pits often have groundwater present in excavation sites. Placing soil into or near a water-table has the potential for disastrous results for the surrounding community. Drinking water as well as farmlands and forests may be contaminated with these soils.
• Dumping of excess soil into pits may pose new and long-lasting threats to ground and surface water. There are concerns about the cumulative impact of these contaminants as well as the long-term effects on the ecological functioning of the landscape. Evolving science may intensify these concerns. No controlled scientific testing of the impact of dumping potentially contaminated excess soils in pits and quarries has been completed by the Ministry
• There should be municipal oversight and approval of the importation of soil for rehabilitation through site alteration and/or commercial fill. Municipal by-laws provide for consideration of local impacts. Restore trust with the public by providing an exemption to ARA Sec 66 to allow Municipal bylaws to enforce standards on incoming fill/soil when a license is in force.
• There should be no self-filing of site plan amendments by industry, licence- and approval-holders.
• Over or under 10,000 cubic metres of excess soil should require oversight by a team of Qualified Persons. The proposal itself states that “record-keeping and oversight by a Qualified Person provides reassurance that suitable quality soil is used to facilitate rehabilitation post-extraction in pits and quarries”. As currently written in regulation 406/19, under 10 000 cubic metre does not require external oversight
We urge that the NDMNRF and other inter-related provincial departments to consider what many across our province are requesting when it comes to re-use of excess soil.