The effect on the area,…

Numéro du REO

011-8511

Identifiant (ID) du commentaire

28360

Commentaire fait au nom

Individual

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Commentaire

The effect on the area, should this quarry mining operation be permitted, would be overwhelmingly negative. Several of the core concerns could not be remediated, only prevented, hence the quarry mine proposal should not be approved. (I was formerly a geologist and having reviewed the proposal I will refer to this proposed quarry more accurately as a quarry mine.) Our home is situated on the 5th Line Nassagaweya, less than one kilometer SE of the proposed quarry mine. Our property has been owned and inhabited by our family since 1966. Our log house is a heritage homestead built from trees cleared off the property in 1880. Our family has cared for this farm with the greatest respect for its history, for the environmental importance of its wetlands, and for our neighbours in this bucolic region of Ontario. To open an unnecessary quarry mine in this vicinity would be poor planning for reasons that span environmental concerns through to the jeopardization of the long term development of our community. We are opposed to the proposal and we ask that the application be rejected at every level of government. Immediately below we have outlined our direct objections. In addition, as members of the Concerned Residents Coalition (CRC) we endorse the organizations list of concerns. You will find them below. Water: We have spectacular pristine drinking water and lots of it. We had a new well drilled two years ago in association with a number of other upgrades we did to our home as part of our retirement plans. The proposed quarry is less than a kilometer away and it would go deeper than our well into the aquifer from which we draw water. The quarry mine would have a negative impact on the quality and quantity of our water supply, a permanent negative impact on this essential resource. The standard of living for all those of us with personal wells who live close to the proposed quarry mine would be irreparably damaged. Compensation would be at best cold comfort. Water Pollution: This quarry would disrupt an important aquifer and so it should not be allowed on that basis alone. I began my career as a geologist and we learned early on that opening an aquifer with a quarry is like removing the lid from a sealed jar. The water is immediately exposed to contamination from everything from rain water to industrial spills. As with a container of milk, once opened it only lasts a few days regardless of the expiry date. The expiry date for our aquifer with respect to contamination would be reduced from hundreds of years to a few years or less. This should not be allowed to happen for the benefit of everyone, the people in the immediate area of Rockwood and those in Guelph whose water supply in part originates in this aquifer. There is no remediation, only prevention. Water Flow: The quarry mining operation would have an impact on the volume of water flow to our well and there is a high risk that it may be altered permanently, even lost completely. Blasting is done to fracture the bedrock and how the rock factures is unpredictable. It too frequently produces unintended consequences that can radically alter the course of groundwater flow. Wells have gone dry overnight due to quarry mining. You can’t fix this once it happens. The risk of damaging our aquifer is too high and affects too many people to allow quarry mining in this area. There is no remediation, only prevention. Heritage Loss: Our 1880 heritage log homestead sits on its original rubble stone foundation. The foundation is one of the finest examples of its type; it and the house have survived the test of time. However, rubble foundations will crumble from regular seismic activity like the kind it would have to endure from mine blasting in the proposed quarry. The stonework either rests on or within a foot or two of bedrock. The shock wave from each blast would hit the foundation with near full impact. It would crumble in time. This wonderful example of traditional building technique would be lost and replacing the foundation would be very expensive. There is no true remediation, only prevention. Community Development: Quarries have a negative impact on communities. Few people choose to live near them so those who can, move elsewhere. It becomes difficult to sell property for those who must move so property values stagnate or decline. Presently Rockwood and the surrounding area is a growing balanced community of families and individuals who have chosen the area for its rural lifestyle. The quarry mine would have an immediate negative impact on the community and would destroy the long term positive development of the area. There is no remediation, only prevention. The following are the CRC reasons for this objection. We support them: Hydrogeology: The proposed gravel pit and quarry is in an area that has been identified as an area of high susceptibility for groundwater contamination and earlier studies have indicated that because of this susceptibility for contamination, certain land uses should not be permitted. The proposed gravel pit and quarry will increase the potential for groundwater contamination and therefore it is doubtful that any further consideration should be given to allowing a gravel pit and quarry at the proposed location. The applicant’s hydrogeological study has not adequately demonstrated that the proposed location for the gravel pit and quarry is an acceptable location. Burnside’s peer review of the applicant’s hydrogeology study on behalf of the Township (dated January 11, 2013 and attached to the Township of Guelph Eramosa Planning Report #1) identified numerous concerns with that hydrogeological study. I share all of Burnside’s concerns and these concerns must be satisfactorily addressed before further consideration of the proposed gravel pit and quarry can occur. In particular the lack of monitoring wells in the proposed extraction areas is a major deficiency with respect to the applicant’s hydrogeology study, and in this regard, it should be noted that the usual requirement is for two years of water monitoring data prior to giving consideration to a mineral aggregate extraction proposal. Without the information from monitoring wells in the areas of extraction, the bedrock extraction may result in the connection of horizontal fractures that are currently separated by zones of relatively impermeable bedrock which could, in turn, result in changes in water quantity and quality that could impact down gradient features and domestic wells. The applicant’s hydrogeology report also does not provide sufficient information to enable a reliable prediction of draw down which means, again, that the impacts of the proposed gravel pit and quarry are not sufficiently known. Furthermore, the applicant’s hydrogeology report does not adequately demonstrate the feasibility of the hydraulic barrier which is proposed to protect the northwest wetland, especially in conditions that will involve blasting. Noise: The applicant’s noise study has not been done properly in that it presumes that compliance with the Ministry of the Environments noise level limits will mean that noise impacts will be minimized. To demonstrate that noise impacts will be minimized the applicant’s noise study must compare pre development noise levels with post development noise levels and must demonstrate that the difference in the two noise levels is small enough to be acceptable. Visual Impact: Visual impact of the proposed gravel pit and quarry has not been studied to date and it needs to be if social impacts are to be known and minimized. I am particularly concerned about the height of berms and stockpiles and the changes in the vicinity of the entrance to the gravel pit and quarry and the visual impacts associated with these operational aspects. Cultural Heritage Resources: There are three kinds of Cultural Heritage Resources, archaeological, built and cultural heritage landscapes. Thus far, the applicant has only studied archeological. Built resources and cultural heritage landscapes still need to be examined. There are what appear to be significant built heritage resources located near the proposed location for the gravel pit and quarry and potential for vibration damage to these buildings is a concern, as are other impacts on these cultural heritage resources. Impact on Property Values: Studies have shown that mineral aggregate extraction operations have a negative impact on property values. This negative impact is directly felt by property owners, but as assessment values drop as well, the negative impacts are felt by the municipality, and the other ratepayers in the municipality, because taxes have to be increased to offset the negative effects on property values of the extraction operation. To date this aspect of the proposed gravel pit and quarry has not been studied by the applicant and it needs to be so that the impacts of the proposed gravel pit and quarry can truly be accounted for and an informed decision can be made as to whether the proposed gravel pit and quarry should proceed. Dust and Air Quality: The applicant’s air quality study does not make recommendations, but the applicant’s report from his planning consultant does make recommendations relating to air quality. It is not clear where these recommendations by the planning consultant come from or whether he is qualified in making the recommendations. In any event, the recommended best management plan for dust needs to be developed and evaluated now, prior to any consideration of the gravel pit and quarry, so that potential impacts can be identified and proposed mitigation can be evaluated to ensure that social and health impacts are minimized. The best management plan must, among other matters, provide for adequate monitoring to determine if predicted levels of dust are being achieved and if those levels are being exceeded, than the best management plan must indicate what consequences will result. Traffic: I share all the concerns expressed in Burnside’s peer review on behalf of the Township, of the applicant’s traffic study. The Burnside peer review identifies numerous deficiencies with regards to the applicant’s traffic study that must be satisfactorily addressed before further consideration of the proposed gravel pit and quarry can occur. These deficiencies include under estimation of traffic volumes due to seasonal variations, under estimation of trip generation from the gravel pit and quarry, and lack of analysis of the requirements for turning lanes and other mitigation measures at Highway 7/6th line and Highway 7/5th line. Natural Environment: I again share all the concerns expressed in Burnside’s peer review on behalf of the Township, of the applicant’s natural environment study. The Burnside peer review identifies numerous deficiencies with regards to the applicant’s natural environment study that must be satisfactorily addressed before further consideration of the proposed gravel pit and quarry can occur. Development and site alteration adjacent to a Provincially Significant Wetland cannot occur unless it can be demonstrated that no negative effects will result and the applicant has not met this test. Similarly, development and site alteration within and adjacent to Significant Wildlife Habitats is not permitted unless it can be demonstrated that no negative effects will result and, again, the applicant has not met this test. Other Mitigation: Keeping in mind that the first mitigation strategy that needs to be considered is avoidance, which means avoiding impacts by not having the gravel pit and quarry at this location at all, in the event that the proposed gravel pit and quarry does proceed, the following additional mitigation needs to be implemented: 1. The proposed hours of operation do not minimize social impacts and need to be reduced; 2. Although the applicant indicated at the Public Information Session/Public Meeting held on March 25, 2013, that the lifespan of the gravel pit/quarry would be 20 years, there is no note on the site plans which would guarantee this lifespan would not be exceeded. In order to minimize social impacts, this guarantee needs to be provided for; 3. The Aggregate Resource Act Site Plans must also identify adequate measures for monitoring noise to determine whether required noise level limits are being complied with and if they are not, what consequences will result; 4. The spills containment in regards to refueling on the proposed site is inadequate and needs to be improved; and 5. In order to help ensure that the operation is implemented in accordance with the zoning provisions and Aggregate Resource Act Site Plan notes, provision should also be made for a Public Liaison Committee. As is outlined above, there are numerous and serious information deficiencies associated with this proposal for a gravel pit and quarry. It should be noted that if the applicant submits additional information to address these information deficiencies new and additional issues may be identified. Furthermore, the ARA licence application process is flawed in that so little time is provided for public review of a proposed mineral aggregate extraction operation prior to the deadline for filing letters of objection. A residents coalition (the Concerned Residents Coalition) has formed to assist in the public review process. As this public review process continues, new and additional issues may, again, be identified.