Comments on ERO #025-0663 …

Comments on ERO #025-0663 (Update to comment 154863
RE: 2004295 Ontario - Changes to the site plan for a pit or quarry

The Ontario Headwaters Institute, a charity that promotes watershed security, defined as healthy and resilient watersheds that protect regional ecological integrity, social well-being, and economic vitality, strongly advocates that the Ministry of Natural Resources reject the proposed destruction of a rehabilitated pit, described in this post on the ERO as a pond, and its proposed conversion to agriculture.

We offer the following for your consideration:

1. The pond that is the object of this proposal is a rehabilitated pit. Its current functions include the provision of surface waters that have become home to many aquatic species with no apparent negative impacts on local wells nor farms. The pond and its immediate surroundings represent a success in terms of restoring natural habitat, with wide biodiversity, including long-lost bird life, and is much appreciated by its neighbours. It would be both a stunning loss should MNR (the Ministry of Natural Resources) now renege on its past approval of the rehabilitation plan for this pit and would send a message that the Ministry cannot deliver, and perhaps should not be trusted to deliver, long-term rehabilitation, as required under the Aggregate Resources Act.

2. Approvals that might be issued by MNR, other provincial agencies, and the Town of Caledon to fill in this extensively aquatic landscape would, in our opinion, violate s 4.2.1 of the Provincial Planning Statement, which stipulates in part that “Planning authorities shall protect, improve or restore the quality and quantity of water by:
a. using the watershed as the ecologically meaningful scale for integrated and long-term planning, which can be a foundation for considering cumulative impacts of development; and,
b. minimizing potential negative impacts, including cross-jurisdictional and
cross watershed impacts”.

Indeed, the current pond is now part of local hydrologic and hydraulic form and function, and should be protected. Further, it is hard to imagine a greater threat to both public and environmental health than importing excess soil from construction sites.

Notwithstanding the prospect that future studies might mitigate some concerns, we consider that approving this proposal as it stands to be a real threat to the integrity of MNR’s commitment to aggregate pit rehabilitation and to be in violation of the Provincial Planning Statement. As such, the proposal should be denied.