Caledon, ON January 5, 2008…

Caledon, ON

January 5, 2008

Graham Bros. – Proposal for Site Plan Amendment

EBR Registry No.: 010-2404

Graham Bros. Aggregates Inc. has indicated that the maximum disturbed area limitations as prescribed in their 2003 licenses cannot be reasonably achieved.  Accordingly, they have applied for a site plan amendment on the basis that adequate quality of aggregate from Phase A requires blending with courser materials from Concession 1 and thus, more working area will be required.  Additionally, the operator has been unable to rehabilitate sufficient areas in Concession 2 to compensate for newly disturbed areas to be developed in Concession 1 without exceeding maximum allowable limits.  Is this proposed amendment justified and, are there other relevant factors that merit consideration? 

The narrow, rectangular shape and relatively small size of the Concession 1 licensed area is obviously more restrictive for operations than Concession 2.  One would assume that Graham Bros. was aware of this when their original license was agreed upon.  They have decades of experience and access to the best consultants in the industry.  Are we to believe that the difficulties and limitations of working this smaller pit have only become apparent in the past one or two years?

If and when Graham Bros. establishes a new well water source for the wash plant in Concession 1, it should require considerably less space than the existing Concession 2 wash area which relies on two large source ponds on the surface.  Has this reduction in space requirement been considered in the application for amendment?

The proposal for a site plan amendment also includes a modified definition of “rehabilitated areas” which may well exacerbate existing dust problems in the immediate area.  The newly proposed definition includes the statement that “Active roads and pond areas that have been rehabilitated on both sides will be considered as rehabilitated.”    Active roads are a significant source of dust.  To consider such roads as rehabilitated areas undermines a key intent of progressive rehabilitation.  That is, dust control will be compromised in such a scenario.

The site plan amendment also includes a provision to maintain the existing wash plant in its present location for considerably longer than the original license permitted.  Unfortunately for our family, the noise generated by this plant is more audible and aggravating than any other source.  This is due to the prevailing wind, local topography and the nature of the sound.  Moreover, the noise problem is compounded by the complete absence of acoustic shielding measures adjacent to this processing plant.  Our family has patiently lived with this wash plant noise for ten years and has been looking forward to its relocation to a quieter area in Concession 1.  An amendment to the site plan would certainly extend this existing problem for many more years to come.

In an ideal world, neighbours adjacent to a licensed pit should be able to rely on the operator to ensure that the pit activities are in compliance with all licensing requirements.  Regretablly for the neighbours of this pit, repeated failures to meet noise limitations have been an ongoing problem.  Consequently, we have had to exercise added vigilance in trying to minimize the noise problems emanating from these pits.

Graham Bros. is a very large company with significant resources and experience.  Naturally, they are anxious to conduct their operations in the most efficient and profitable manner possible.  When the resources from these two gravel pits (Concessions 1 and 2) are ultimately depleted, they will have generated tens of millions of dollars in revenues for the company.  Will a denial of this proposal for an amendment mean that extraction of the remaining aggregate will not be economically viable or will it simply mean that the operations may be less efficient and profitable than originally anticipated?

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