Concerned Citizens of Ramara…

Concerned Citizens of Ramara (CCR) is submitting this comment regarding the proposed amendment to Environmental Compliance Approval (ECA) No. 6332-A2GNRY for the NRK Holdings Inc. excess soil processing and transfer facility located at 7406 Concession Road B-C in Ramara Township.
CCR represents residents who are concerned about land-use compatibility, environmental protection, infrastructure capacity, and cumulative community impacts associated with industrial-scale development in rural Ramara. Based on our review of the proposal and the December 22, 2025 staff memorandum from Ramara Township, we share and support the concerns raised by municipal staff.
Scale and Intensification
The proposed amendment would:
Double daily processing capacity from 3,000 to 6,000 tonnes
Increase on-site storage capacity from 67,000 tonnes to 110,880 tonnes
Expand the service area from Ontario to all of Canada
Extend daily operating hours and permit 24/7 emergency acceptance
Taken together, these changes represent a substantial intensification and functional expansion of the operation. This is not a minor or administrative amendment; it materially alters the scale, reach, and impact profile of the facility beyond what was originally approved.
Land-Use Compatibility and Municipal Planning
Ramara Township staff have identified that aspects of the proposal — including the inclusion of a transfer station function and acceptance of certain untreatable soils — may not be permitted under the current Official Plan and Zoning By-law, and that the site remains subject to Site Plan Control and an existing site plan agreement.
CCR is concerned that advancing a provincial approval in advance of resolving these municipal planning inconsistencies risks undermining local land-use authority and creating regulatory misalignment. Environmental approvals should not proceed in isolation from municipal planning frameworks that are intended to protect communities and ensure compatibility.
Traffic, Haul Routes, and Infrastructure
The proposed increase in daily tonnage and expanded service area will inevitably result in increased heavy truck traffic on local and regional roads. Ramara is a predominantly rural municipality with road infrastructure that is not designed for sustained industrial traffic volumes.
CCR supports staff’s concern that increased truck traffic raises issues related to:
Road safety
Accelerated road degradation and maintenance costs
Noise, dust, and vibration impacts
Cumulative impacts on rural residents and settlement areas
Environmental Protection and Risk
While the soil proposed for acceptance is described as non-hazardous, the scale of processing, storage, and handling contemplated by this amendment heightens environmental risk. The proposal includes acceptance of less-restricted or untested soil streams and revisions to contaminant limits.
CCR is concerned that reliance on monitoring alone is insufficient. Strong, enforceable safeguards must be in place to protect groundwater and surface water, particularly given the Township’s reliance on local water resources. Risk should be prevented, not merely documented after impacts occur.
Process and Precaution
The public comment period for this proposal occurs over the holiday season and concludes on January 15, 2026. Given the scale of the proposed changes and the concerns raised by municipal staff, CCR urges the Ministry to apply a precautionary approach, ensuring that:
Municipal planning conformity is resolved
Community and infrastructure impacts are fully assessed
Environmental protections are clear, enforceable, and robust
Conclusion
Concerned Citizens of Ramara respectfully requests that the Ministry of the Environment, Conservation and Parks give substantial weight to Ramara Township staff’s concerns and recognize that this proposal constitutes a major operational expansion with community-wide implications.
At minimum, this proposal requires careful scrutiny, coordination with municipal planning authority, and strong conditions. It should not proceed as a routine amendment.