Rose Copland Aggregate…

Rose Copland Aggregate Technical Specialist Ministry of Natural Resources and Forestry Regional Operations Division, Southern Region Peterborough District 300 Water Street Floor 1, Robinson Place South Tower Peterborough ON K9J 8M5 Re: Instrument Proposal Notice - Issuance of a Class A licence to remove more than 20,000 tonnes of aggregate annually from a pit or a quarry - ARA s. 7 (2) (a) (EBR Registry # 013-1624). Dear Ms. Copland: The North Pigeon Lake Association (NPLA) represents approximately 100 members in the Municipality of Trent Lakes and the City of Kawartha Lakes. NPLA supports actions that preserve and promote the welfare of the shoreline and the waters of north Pigeon Lake, its catchment area, and more broadly across Ontario. We also promote good government, including sound environmental stewardship. NPLA is concerned about the above application’s social and environmental impacts: There are already over a dozen Class A licenced aggregate operations in our catchment area. Current transportation infrastructure was not designed to handle the additional traffic from all these operations. Prior to approving an additional aggregate licence in this area, a Cumulative Impact Study of aggregate operations related traffic should be undertaken. The Municipality of Trent Lakes, through its Official Plan (O.P. Section 5.10.5 q vi), requires a dust control study for aggregate operations. To our knowledge, no dust control study associated with this application has been undertaken. NPLA requests that the Ministry not consider approval of this licence application until an appropriate dust control study has been completed. NPLA has reviewed the Natural Environment Level 1 and 2 Technical Reports for the project (http://www.trentlakes.ca/wp-content/uploads/2017/03/Final-Natural-Enviroment-Report-6-15-17.pdf) While the recommended mitigation activities seem reasonable given the nature of the proposed operation, we have some outstanding concerns regarding species at risk that have been identified on the site, as well as the broader environmental impacts of the large number of aggregate operations in the area. The Natural Environment Technical Reports identified the presence of several species at risk and habitat for several others, and therefore indicate that the proponents will be applying for “Overall Benefit” Permits under the Endangered Species Act. It is not clear from the Overall Benefit Permit application procedure (Endangered Species Act Submission Standards for Activity Review and 17(2)(c) Overall Benefit Permits) whether a permit is issued prior to, or after, an aggregate licence is issued. Since it makes no sense to approve the aggregate operation if overall benefits for species at risk cannot be achieved, NPLA requests that the Ministry not consider approval of this licence application until an Environmental Registry Notice for the Overall Benefit Permit has been posted for public comment and a subsequent Decision Notice posted. As mentioned above, there are already over a dozen Class A licenced aggregate operations in our catchment area. Mitigating the impacts of these operations on a case by case basis ignores the cumulative impacts at the broader landscape scale. Species at risk have been identified during Natural Environment Surveys for each of the adjacent aggregate licence applications in the area; it will be difficult to mitigate the cumulative impact of these operations on species at risk, let alone achieve an “overall benefit” to the species. In addition, we understand that a globally significant alvar is adjacent to the proposed operation, and may extend onto the site. Prior to approving an additional aggregate licences in the area, we believe that a Cumulative Environmental Impact Study of aggregate operations related to habitat fragmentation and species at risk should be undertaken. Thank you for the opportunity to comment. Board of Directors North Pigeon Lake Association General Delivery Bobcaygeon, Ontario K0M 1A0