I am writing on behalf of…

I am writing on behalf of the Mill Creek Stewards, a small community association whose mission is to protect the Mill Creek Watershed; a watershed that encompasses almost half of our Township of Puslinch. In line with that protective mission, our Association wishes to comment on this amendment for an expansion to the Mill Creek Pit’s excavation limits under License # 5738: owned by the University of Guelph and operated by Dufferin Aggregate, a division of CRH. PLC.
We object to this (supposedly final) extension (fourth in a series so far) primarily because the owner/University publicly committed (in media at the time the original license was approved) to not extracting all the aggregate. The University President stated, “We’re not out to get every shovelful”. This application’s accompanying letter however states the opposite, “the proposed site plan amendment seeks to recover the remaining reserves at the Mill Creek Pit”. With previous excavation expansion applications, we could not claim the owner was actually “getting every shovelful” but in the case of this application, the owner quite clearly makes the point for us. The original Land Tribunal made clear that the University’s public commitments, were significant factors in their approval of this license.
With respect to the letter’s statement, we believe it is also relevant to point out there are still aggregate reserves remaining within setbacks between the Mill Creek Pit and neighbouring pits and the license owner has in the last year been found non-compliant by the Ministry of Natural Resources with respect to the transport of setback-overburden off-site (License Condition #34) from one of these setbacks. We believe this is relevant because in our opinion, the only reason for taking this overburden from the east setback between the Mill Creek South Pit and the neighbouring Lanci Pit (CBM Ltd.) is in anticipation of a further excavation expansion between the two pits.

Excavation extensions are just the tip of the iceberg however, when it comes to the owner/University’s noncompliance with their public commitments and the original site plans approved by the provincial Land Tribunal back in 1990 including: Mill Creek contamination, groundwater flow reversals, no environmentally friendly excavation research facility, no land remaining for 26 residential lots, and no rehabilitation demonstration on-site laboratory. We believe these facts are relevant to this application because in our opinion, this application is the last straw, the last kick in the community and Land Tribunal’s teeth; an application that says yes we may have promised the Land Tribunal and the community everything from limited extraction to wildlife preserve, creek/wetland protection to residential homes and nature centre to on-site teaching laboratory but we couldn’t care less. And it just so happens we want this last bit of aggregate too (if it is the last), even though it required demolishing a two hundred year-old barn (despite an ongoing University supported Save our Barns campaign) and even though it rules out the last potential for the University’s originally indicated positive community legacy i.e., a nature centre in the original site plans.

The Mill Creek Stewards are asking that this application be denied because in accordance with the Provincial Planning Statement 2024, 4.5 Mineral Aggregate Resources. (2) the license holder was required to ensure “extraction shall be undertaken in a manner which minimizes social, economic and environmental impacts.” That acceptable manner of extraction was defined by the original Land Tribunal with its original site conditions and by the owner/University with its public commitments. This application on its own but especially given the overall site’s operation, in failing to meet those original conditions and commitments, also fails to meet that acceptable manner, instead cumulatively increasing social, economic and environmental impact with respect to that manner of extraction.
Respectfully submitted.