This is a LETTER OF…

This is a LETTER OF OBJECTION to the gravel pit and quarry which has been proposed at Part Lot 1, Concession 6, Geographic Township of Eramosa, now in the Township of Guelph-Eramosa. The reasons for this objection are as follows: 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 identified numerous concerns with that hydrogeological study. I share 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, the negative impacts are also 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 to make 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 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. If a light is to be installed because the Township has given into the pressure placed on them from the community, they would be responsible for the cost of the traffic lights. Regardless of how one views the insertion of traffic lights at the intersections, the Sixth Line and the Fifth Line along Highway 7, the taxpayer will ultimately end up paying for the installation @ an expected cost of $300,000+. Natural Environment I again share 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.