RE: Proposed Aggregate…

RE: Proposed Aggregate Extraction at 1894-1922 Witmer Road, Wilmot
Jackson Harvest Farms Ltd.
ERO number 019-1094
Ministry reference number
95-2019-187

I have some serious concerns regarding Rick Esbaugh's aggregate operation across the street from my home. I have two small children and I care about their well-being along with the well-being and safety in my community from safe drinking water to road safety and the protection of our environment.

These comments are intended to demonstrate my concerns regarding the aggregate operation noted above. As a member of the community that will be negatively impacted by this undertaking I would like to identify my concerns.

I am opposed to the Hallman Pit by Jackson Harvest Farms Ltd. for the following reasons:

● I am worried about the safety of our community. I drive by Mr. Esbaugh's TriCity locations everyday and I see the speed at which trucks enter and exit, the wide turns and also the volume of traffic. I worry about my children's safety as they wait for the bus on the shoulder of the road, as the trick or treat, collect the mail and cross the street. How will it be insured that an unfortunate accident will not occur with the increased volume of dozens of trucks an hour?

● I am concerned about our water safety and environment. We live in a protected water area under the Source Water Protected Area and Clean Water Act. Because of the Source water protected area, we must restrict water usage on our own properties and have our septic tanks inspected regularly. When we have to do to such lengths to protect and conserve water, why should Mr. Esbaugh's Jackson Harvest Farms operation risk our water safety and protected water area? Waterloo region is focussing on protecting groundwater and source water. How will you insure that our water not be contaminated and lost like the wells in Baden and Elmira have been?

● I am concerned that Jackson Harvest Farms request for rezoning and gravel pit will undermine the Township of Wilmot, along with government agencies, declaration of a climate emergency. The Township of Wilmot and the Region of Waterloo have both declared a climate emergency. Wilmot Township has stated that they will reduce Greenhouse Gas Emissions by 25% by 2027. The rezoning of this pit and then work that will take place will not help the region meet this target.

At the Public Meeting at Wilmot Township, Catherine Fife was quoted in her concern that an aggregate operation can change their plans after the proposed plans and accepted and the rezoning and project moves forward. Is the Region and the Ministry of Environment prepared to let this project start knowing that the proposed plans would change and be altered further putting into jeopardy the environmental concerns.

● I am concerned that aggregate extraction and related activities (permit to draw water, wash ponds, asphalt and concrete recycling) will inevitably affect the quality and quantity of my water as this pit lies in a regional recharge area and a wellhead protected area according to the Source (Water) Protection Plan. There are wetlands that are attached to the Jackson Harvest farm property and the adjoining property. The GRCA has noted increased rainfall and flooding as well as unseasonal changing weather patterns. I am concerned about the depths and the same ground levels proposed in the pits which will inevitably come in contact with these wetlands. When there is flooding and increased rainfall, what risk does this pose for the wetlands that will come into contact with the materials of the gravel pit and contamination and how can this be protected? I am also worried about the wasponds and how the nitrates will be washed away and no longer be filtered out by the loss of the gravel and filtration proivded by this.

● I am concerned about environmental issues related to the wetland and woodland on the property and surrounding. I am concerned about the rehabilitation plan and question the loss of prime agricultural land. The location and surrounding area of the Hallman pit represents the regional recharge area for Waterloo region. Waterloo region “is unique in Ontario in that it is the largest urban municipality to rely almost exclusively on groundwater supplies for its drinking-water.” (Regional Official Plan) Wilmot is also the location of several other gravel pits. What effect will an additional gravel pit have on our regional recharge area? With the region continuing to grow and expand, it is important that we protect our water sources and the vital recharging areas for “Waterloo Region’s continued long-term reliance on groundwater” as stated in the Regional Official Plan.

This is a matter of two resources: water and aggregate. The water in this location is already protected and the application is seeking to extract a resource on top of a protected resource. This shoiuld not be permitted.

● I am concerned about the safety risks related to the haul route on a township road (with limited line of sight, no shoulders, guard rails, hidden driveways, school bus route) and connected regional roads along with dangerous intersections.

● I do not feel that the home owners will be properly compensated for their loss of property value and quality of life and safety because of the operation of such a gravel pit in close proximity to a long-standing community. I am concerned that Wilmot residents’ taxes will have to cover road repairs and lost value in property. I am concerned about the hours of operation, the proposed night work, the additional dust and noise and what impact this will have on my children’s development and our well-being.

● I am concerned about my families' well-being, health and mental health. We chose to live in this residential country community for the peace and tranquility. I fear this will be lost.
Mr. Esbaugh cannot prove beyond a reasonable doubt that he will have no negative impact on our water, environment, roads, mental health, community or on GreenHouse Gas Emissions. The approval of this rezoning has great stakes and is not worth the risks in my opinion. The cumulative impacts of this rezoning must be considered.

● I am concerned about the location. We live in a residential community in Shingletown of about 50 homes. It would not be appropriate for Westmount Golf Course to be turned into an aggregate production nor would it be appropriate for traffic in this kind of volume and production be in Rockway Gardens in Kitchener. How is my community any different? There are homes within a 120 meters of this pit. New homes would not be permitted to be built so close to a gravel pit, I don’t understand why the opposite be possible.

This decision cannot be made lightly as your decision on this rezoning in a Source Water protected area will be precedent setting. To date, there has not been a gravel pit approved for rezoning in a Source Water protected area. This precedent decision comes with great responsibility and could open the potential of other protected areas to also be negatively impacted and exploited. Please do not be rushed in your decision. I would also like to know what the Grand River Conservation Authority’s peer review of the water study is before this project moves forward. What consultation has Wilmot Region done on climate change and how they should move forward with the climate emergency declaration with the GRCA?

Thank you for taking the time to address these concerns as I consider this a serious threat to our community and our lifestyles.

Respectfully submitted,