November 3, 2019 Re: ERO…

ERO number

019-0556

Comment ID

35907

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

November 3, 2019
Re: ERO NOTICE #019-0556 – PROPOSED CHANGES TO THE AGGREGATE RESOURCES ACT AND ONTARIO REGULATION 244/97

Citizens Against Melrose Quarry (CAMQ) is a community not-for-profit organization in rural eastern Ontario (Tyendinaga Township, Hastings County). We promote responsible, equitable, and sustainable resource use. Primarily zoned agricultural and rural residential, our community relies entirely on groundwater to meet domestic, commercial and agricultural needs. There is no municipal water supply in Tyendinaga Township. The aquifer that residents rely upon is classed as highly vulnerable.
Our group supports comments regarding this proposed set of amendments to the Aggregate Resources Act from the Canadian Environmental Law Association (CELA) and from Gravel Watch Ontario.

We are constituents of Mr. Daryl Kramp’s riding and we come from all walks of life. For many years, we have been concerned about the impacts and oversight of quarrying on our community. It is our observation that non-compliances can go unnoticed from time to time – as in the case of a local quarry operator who continued to operate below the water table from 2005 until 2011 after being denied a 2005 Permit to Take Water (PTTW) application. The Ministry of Natural Resources (MNR) did not become aware of the circumstances until 2011. It is our feeling that information does not always flow effectively between ministries that share oversight for different aspects of an operation. As such, this ‘siloed’ oversight is particularly worrisome for our community as the operator now seeks to open a second quarry (Melrose) adjacent to the current Long’s Quarry. This matter has been referred to LPAT (MM180027-Tyendinaga).

Our observations lead us to respond to the following elements in your proposal details at https://ero.ontario.ca/notice/019-0556:

• “Strengthen protection of water resources by creating a more robust application process”: we recommend that Aggregate Licenses be time limited and tied to the Permit to Take Water (PTTW). This would afford improved communication between ministries responsible for quarrying and environmental protection, and it would create an opportunity to monitor and protect rural water supplies. It is essential that the application process consider the impacts of aggregate extraction both within and below the water table on communities that have no municipal drinking water supply;

• “Streamlining compliance reporting requirements, while maintaining the annual requirement”: it is our position that annual compliance reporting must also be tied to a combined aggregate/Permit To Take Water (PTTW) renewal to allow for continued communication between ministries.

We thank you for the opportunity to submit our comments.
Sincerely,

Sue Munro
Chair, Citizens Against Melrose Quarry
www.citizensagainstmelrosequarry.com
camq2013@gmail.com

cc. daryl.kramp@pc.ola.org