As a long-term resident of…

As a long-term resident of Puslinch, I strongly support the Township's ERO# 019-7312 submission that challenges granting an Environmental Compliance Approval (ECA) to any company that is operating illegally: in this case operating illegally for over nine years on the property under consideration (Front Part Lot 8, Concession 3, Puslinch) in a manner apparently non-compliant with both the Planning Act (PA) and the Aggregate Resources Act (ARA).

Jurisdictionally, 2374868 Ont. Ltd., appears to claim ARA jurisdiction when challenged under the PA and PA jurisdiction when challenged under the ARA, relying on staffing limitation at the local municipal level and limited communication between the Ministry of Natural Resources and Forestry (MNRF) and the Ministry of Municipal Affairs and Housing (MMAH) for its continued operation.

Now they are involving a third Ministry, your Ministry of the Environment (MOE) and its Environmental Protection Act (EPA) in a situation that clearly requires as a pre-requisite;
- clarification with respect to the land's status under either the ARA or the PA i.e., is the landholder (Capital Paving) surrendering the aggregate license on this portion of the land or not, and then
- having clarified the land's position, first resolving the glaring issue of non-compliance with respectively the Planning Act 6.5.4 (small scale commercial operations), the Ontario Building Codes Act 8.1 (building and demolishing permits) and/or the ARA 13, 37.2.4, 48.1 (site plan amendments/ rehabilitation).

For relevant backgrounding, I would note that this company:
- applied back in 2021for a similar ECA using the location's Cambridge postal address and therefore Puslinch Township was not notified of the application. Fortunately a resident notified them and an objection was made by the Township, at which time the applicant withdrew their application.
- earlier this year (2023) applied for a zoning change to bring their self-admittedly illegally operating company into compliance with the Planning Act but without first surrendering the aggregate license on the relevant land. When Township commissioned peer review studies brought into question the company's supporting environmental studies, the company chose to appeal the Township's delayed zoning decision, to the Ontario Land Tribunal.
- is operating on a single property owned by Capital Paving, which incorporates Greenlands, Core Greenlands and a Wellhead Protection Overlay.

In light of the foregoing information, we would ask that this application be deferred until such time as the land's status and the company's operating status are clarified. Many thanks for your consideration.