May 14, 2020 Regarding ERO…

May 14, 2020 Regarding ERO 019-1303
To MNRF-Natural Resources Conservation Policy Branch

Re: Proposal to amend O.Reg.22/97 and the Aggregate Resources of Ontario Provincial Standards under the Aggregate Resources Act ERO#19-1303 (Referred to throughout as “the Proposal”). Support submissions by Gravel Watch Ontario and Burlington Green Environmental Association.

Dear Sir/Madam,
I reside in Ramara Township, Ontario, and live in very close proximity to an active granite blasting quarry operation, in some areas less than 200 m from Lake Couchiching, and looking to expand its operations for a period of time which could extend the life of this quarry for as much as 70 plus years.
I have also had access to Comments submitted to the Environmental Registry by Gravel Watch Ontario (referred to as GWO below), letter dated March 2020 and the Burlington Green Environmental Association, letter dated April 8, 2020 and I completely support their Comment submissions regarding ERO #19-1303.
As a citizen of this great province, I appreciate the opportunity to review these important proposals and documents that affect our health, lifestyle and environment, as well as being given the opportunity to comment on them. I however, strongly concur with Gravel Watch Ontario’s suggestion that our Comments should be part of the official Objection process!
In general terms, I think there is still much more review and consultation on a variety of matters before I would be satisfied with the Proposal being put forward, although I appreciate the efforts the Ministry has completed to date to address previously voiced concerns by various stakeholders.
Other points that I am in agreement with and that have been put forth by GWO and the Burlington Green Environmental Association in their comments, and which I wish to highlight include:
• Data regarding supply and demand of aggregate materials should be controlled by the Ministry and considered on an ongoing basis as applications are made, thus preventing unnecessary destruction of natural resources. The world and the environment are changing as are society’s demands related to construction, road requirements, etc. And the current pandemic has certainly changed the perspective of many companies and individuals to accommodate the ability to work from home, thus greatly reducing commuting and subsequent wear and tear on highways and roads, which have historically created the most significant demand for aggregate product.
• Re: 1.1.1 Water Report - Quality and volume of my precious water supply are my greatest worries, living so close to the quarry. And I strongly agree with GWO’s recommendation that the province needs to improve its approach in studying the impact of aggregate extraction on groundwater resources, in general terms as well as specific geographic locations including my own community. New innovations in science and technology should make today’s studies and testing tools accurate and effective but I have no peace of mind as I read the numerous studies from hydro-geology and blasting experts about the minimization of risk, which is not equivalent to zero risk – but with the purpose of convincing us that a new application as well as current amendments waiting for approval will not effect our wells, lakes, rivers, etc. At a minimum, natural environment reports should be mandatory for all amendment applications related to activity below the water table. The suggestion by the Burlington Green Environmental Association on page 3 of their letter, that no digging below the water table should be allowed at all, is testament to how grave a concern blasting activities are for well and property owners in close proximity. And I certainly would like to comment on 3.3.3, Amendment to Expand Existing Site below Water Table, to personally say that notifying landowners only within 120m of operations is incredibly irresponsible, based on the blasting capabilities and related risks we are currently aware of.
• Re: 1.3.1 - I also agree with the GWO that the current Consultation Timeframe of 45 days is not long enough and 60 days is more reasonable, given such important considerations that need to be addressed. Also, the current 45 day period for the official Objection process is not inclusive or fair. Stakeholders may come and go, priorities change, residents’ awareness of issues and education often takes time – and people should be given sufficient opportunity to make their voices heard, when their health and lifestyle as well as those of other inhabitants of an area who cannot speak for themselves, are at stake.
• 3.1.2 Dust – There is no question that dust is a major threat to any inhabitant’s health, and I frequently see air quality concerns swept under the rug in the Consultant reports I have viewed. I agree with GWO’s recommendation that comprehensive air quality studies leading to successful and measurable dust mitigation and air quality monitoring, need to be properly developed and subsequently required for all sites, both new applications and existing operational ones. In today’s society, with current technology, innovation and such advances in science the world has not seen before, proper testing and mitigation processes should be available. Also concerning dust and other emissions, and with reference to 3.1.4 Recycling activities – I concur again with GWO that new regulations to address these concerns are required, as these distinct operational activities increase.
• With regards to 3.3.2 Expansion into a Road Allowance – for me, living less than 300m from an active quarry, with a large portion of that distance made up of road allowances on both sides of a road separating our community from that quarry, I certainly have to protest that approvals here should only apply when the road runs directly through a quarry.
• The concept of Self-filing and streamlining processes greatly concerns me. I appreciate that there is always room to reduce bureaucracy in most organizations and approval processes can often be arduous, but the idea, for example, that a new quarry entrance or exit can be approved in this manner and without proper community notification or an opportunity for various stakeholders to voice concerns is alarming to say the least.
In summary I feel that we as a community, owe it to future generations to take ownership, envision and effectively manage a key resource sector that can efficiently supply the materials we need without compromising the health of our citizens, wildlife and other inhabitants, and the overall quality of the environment upon which we depend for our long-term survival. This issue has become even more elevated due to the recent Covid-19 pandemic, demonstrating how connected but vulnerable we are globally and how we must be even more proactive and preventative in our planning for the future.
As Burlington Green Environmental Association states: It is time to acknowledge the need for and a commitment to a sustainable future for all, and a shift from the “business as usual” model that is unsustainable to a model that prioritizes action on climate and species preservation, thereby safeguarding the health and well being of our habitats and biosphere, now and for future generations.