Letter of Objection to…

Letter of Objection to Strada amended permit to take water

Strada Aggregates Inc.
Permit to take water
ERO number 025-1082
Amendment to Permit to Take Water No. 3210-AKRL9C for aggregate washing purposes. Water will be taken from one pond.

Water takings are anticipated to have the highest potential of causing unacceptable environmental impactor interference. The proposed water taking qualifies as a Category 3 permit.

Oct 24, 2025

Dear Ministry of the Environment, Conservation and Parks (MECP)

We live nearby the proposed site and wish to express our opposition to the approval of the amended permit to take water.

NDACT had previously made a Community Engagement Letter [CEA] agreement that it would not oppose the application unless the science showed the quarry would cause unreasonable adverse environmental effects. To the surprise of NDACT Strada did not wait for the independent peer review to be completed before submitting its application for the quarry.

Strada displayed at the public presentation that there was "substantial input by NDACT into the pre-application planning process for Hydrogeology, Noise, Air and Blasting". It doesn't seem that the hydrogeologist agrees to this claim as noted in The Creemore Echo titled "Peer reviewer claims NDACT breached [CEA] agreement" March 21, 2025

At a recent Township of Melancthon meeting I learned that the town has not given a response to either the aggregates or permit to take water. There was discussion that Strada had previously put in writing that that they would never go below the water table but now they are doing the exact opposite of what they promised. I learned for the first time that theres a peer review currently underway and the Township would be asking for extensions on the application deadlines to await peer reviews before making an official comment.

I learned that historically there was extensive local opposition to a proposed Mega-quarry in Melancthon. In the house of commons it was called an "environmental disaster". A local MP had then called for an environmental assessment. (2)

I have not seen a public notification of the Nov 1, 2025 deadline for public comment on the permit to take water (PTTW). The Township of Melancthon notes, "there is some confusion from the public regarding the process for submitting comments on the Strada Aggregate Resources Act (ARA) Application." Yet, it does not specifically mention the ERO application by Strada for the amended permit to take water. (4)

St. Marys is a separate concrete company that would likely be involved in making road asphalt. In a recent decision On March 14, 2025 the Town of Caledon won an appeal to the Ontario Land Tribunal upheld the ICBL that "a need for new aggregates not demonstrated." Details are available on the Forks of the Credit Preservation Group. (5)

I believe there is ongoing disagreement about hydrogeological studies being completed. A permit for a below the water table quarry should require detailed hydrogeological studies to assess the impact on surrounding water resources (wells, streams, wetlands).

The existing above ground quarry is in an area designated for water protection (WHPA designation: Aquifer Vulnerability and Wellhead Protection Area)

Sensitive aquifer area located on the Dundalk Dome (highest point in Southern Ontario and the headwaters for several major rivers including the Grand, Notawasaga, Boyne, and Pine Rivers). There are significant concerns regarding groundwater source protection.

Prime Agricultural Area, highlighting its historical and ongoing importance for farming

Highly Vulnerable Aquifer: The land sits atop a highly sensitive and important groundwater resource, which is considered highly vulnerable to contamination. This hydrogeological sensitivity is the basis of the opposition and the requirement for extensive technical studies.

Environmental impact (interference)

Groundwater Quantity and Flow
Constant dewatering creates a "cone of depression" that lowers the water table, potentially leading to drying up of nearby wells, springs, and wetlands.
Dewatering can reverse the natural groundwater flow
We fear the loss of surface water features that rely on groundwater connection such as the wetland located adjacent to our property

Aquifer Integrity and Quality
There is a risk of breaching hydrological barriers between different aquifers, which can cause water from different layers (including potentially lower quality water) to mix.
Direct access to the aquifer removes the natural filtration layer of soil and subsoil, increasing the aquifer's vulnerability to surface contaminates eg fuel/oil spills from equipment).

Ecosystem Impacts
The lowering of the water table can cause surface water bodies and wetlands (like fens) to lose their water source and dry up, destroying sensitive ecosystems.
The creation of a deep permanent quarry lake (upon closure) changes the thermal characteristics of the area, which can harm adjacent cold-water streams

Permanent Hydrological Change
When the quarry ceases operation, the pit fills with water, creating a permanent, deep, open-water body (a quarry lake).
The quarry lake remains a constant hydraulic connection with the surrounding groundwater, potentially acting as a drain that permanently alters the natural groundwater flow patterns
The deep, open-water body heats up more than the groundwater it replaces, which can negatively affect any adjacent cold-water streams or habitats by increasing their temperature.

Water Pollution
Even with controls if Acid Mine Drainage (AMD) / ARD is present the reaction can continue for decades or centuries after mining has stopped!
Heavy metals of concern include Arsenic (As), Cadmium (Cd), Chromium (Cr) (especially the highly toxic hexavalent chromium, Cr(VI)), Copper (Cu), Lead (Pb), Mercury (Hg), Nickel (Ni), Zinc (Zn)
Below the water table can also cause water alkalinity from carbonate rock (like limestone or dolomite)
Dewatering can create large amounts of fine sediment and particulate matter (turbidity & suspended solids)
There are rumours that a mine can remain open indefinitely for a low annual fee avoiding the need for an eventual mine closure.
Even with retention ponds, increased suspended solids can be carried into nearby streams, smothering aquatic habitats and discolouring the water

Possible Future Intention(s)
I believe that there is a future intention for St. Marys to use the aggregate to produce asphalt. St. Marys has indicated a similar intention to produce asphalt in the recent Ontario Land Tribunal with Caledon, Ontario. I believe this poses additional risks due to the binder (bitumen) and vehicle traffic. A known environmental concern with asphalt is leaching from the bituminous binder (which contains polycyclic aromatic hydrocarbons or PAHs). Heavy vehicle traffic can lead to pollutants including oils, heavy metals and tire wear washing off the road surface.

"The manufacturing of asphalt, particularly Hot Mix Asphalt (HMA), which involves heating and mixing aggregate with asphalt cement (bitumen), creates several types of environmental pollution, primarily affecting air and, secondarily, potentially water and soil."

Current demonstrated disregard and dismissal by Strada towards nearby residents

The individuals who live close to the existing gravel pit are now experiencing issues with sediment in their well water. I believe they had allowed Strada to do testing / monitoring but Strada found they are at no fault for the difficulties these families are experiencing.

I believe that if Strada is granted a permit to take water (PTTW) they will similarly deny responsibility / accountability for existing and yet to be realized adverse environmental effects. These effect are in many regards are long-lasting and irreversible.

There is no future actionable proposed remedies should the below-water-table aggregate licence eventually lead to issues that will be faced by local residents.

I attended the public presentation by Strada and I was misinformed by "the experts" on a few things:
I was told that "sedimentation and time" in pools would remove any heavy metals present AND "water extracted from the quarry floor would always remain in a fully-closed-system". After doing a little research this doesn't seem to be accurate.

I believe the construct of various studies is subject to a high degree of "confirmation biases" Examples are truck traffic studies were not done past Hwy 124 and 17 SideRd, traffic when it reaches Shelburne I was told is, "not part of the traffic study". I am also told that blasting and siren noise was not included in the sound modelling done. Although I'm not a scientist or expert I believe similar deficiencies in the design of the studies and interpretation of the results doesn't give me any confidence.
I have not met anyone in support of the below-water-table quarry OR the expanded application to take water (PTTW).

The existing quarry approval was submitted in spite of an incomplete environmental assessment despite of an indication Strada would wait for the Science.
The town was misinformed that there was no intentions to go below the water table AND is awaiting its own peer review before sharing its position on the application(s).
There is an upcoming meeting with the NDACT hydrogeologist on Nov 4, 2025. Unfortunately this discussion will occur after the deadline for public comment on the ERO website

I would like to submit these concerns / objections to the MECP approval of a permit to take water (PTTW)