Sanjay Coelho Ministry of…

Sanjay Coelho
Ministry of the Environment, Conservation and Parks – Environmental Policy Branch
40 St. Clair Avenue West, Floor 10
Toronto, Ontario M4V 1M2

Re: Community comment concerning aggregate issues within the Proposed Land Use
Compatibility Guidelines, Ministry of the Environment, Conservation and Parks (MECP)
Environmental Registry of Ontario Number 019-2785

Dear Mr. Coelho,

It is my understanding that the Ministry is proposing updates to the Land Use Compatibility Guideline which would remove the burden of proof from (for example) a quarry to demonstrate why it should be approved, and instead place the onus (and expense) on the municipality to demonstrate why it should not.

My comment asks that if this burden of proof must fall to the municipality, then they should not be forced to pay to undertake the requisite studies for these applications. This could be financially catastrophic to a small municipality such as mine, in that it would clearly be easier and cheaper for the township to approve ill-advised development simply to save taxpayer dollars. Additionally, while much is discussed about protecting Sensitive Land Use from noise, dust, etc., there is an implicit grandfather aspect to automatically approve a major facility if it is near an already-approved major facility; i.e. prioritizing aggregate over our community. In our case, this would make it easier for Fowler to have the proposed new quarry approved.

I am a supporter of Ramara Legacy Alliance (RLA), a local group of concerned residents, working
on behalf of, and in cooperation with the residents of Ramara Township, Ontario. This
community cares about the health and safety of local residents, sustaining the environment,
and protecting wildlife. Many families have roots here dating back more than 100 years, and
our community continues to grow and thrive in harmony with the local environment.

For the last three years, RLA and the Township of Ramara have been battling the expansion of
the Fleming Quarry, which is located approximately 80 metres from the nearest residence and
200 meters from the shores of Lake Couchiching, a designated waterfront. Fowler Construction
Inc. (Fowler) purchased the property to the north of their current quarry operation, and in 2018
applied to re-zone this land from Rural to Mineral Aggregate Extraction in order to create a
second quarry. At the same time, Fowler has applied to the MNRF for amendments to its
existing quarry, to be able to blast a further 15 metres deeper and 22 metres wider, exposing
the community to even greater health and safety risks. If approved, the Fleming Quarry’s
lifetime will be extended by an additional 75 years.

I am strongly opposed to the proposed changes concerning aggregate issues within the Land
Use Compatibility Guidelines. Drawing from a submission made on June 21st, 2021 to Ramara
Council by noted planner Mark Dorfman (a full copy of Mr. Dorfman’s submission to Ramara
Council has been submitted to your office), the province’s objectives in adopting these changes
are in clear conflict with the need to protect the health, safety, and well-being of local residents
from the risks posed by aggregate operations. Here is a direct quote from Mr. Dorfman’s
submission, which I fully endorse, and am also attaching as a separate file:

In Ramara's experience, this direction is not acceptable and this municipality
has already made the planning decision when identifying Mineral Aggregate
Resource Areas, that aggregate operations are not appropriate within 1,000 metres
of existing and planned residential areas. The Township of Ramara strongly disagrees
with the provincial direction that existing and expanding aggregate operations are
not required to consider land use compatibility and may locate within 1,000 metres
of existing and planned residential areas that are sensitive land uses.

I am not opposed to aggregate pits and quarries. However, we owe it to future generations to
take the time and care now to envision and effectively manage an aggregate resource sector
that continues to supply the materials required by the Province of Ontario without
compromising the health of local communities and the quality of the environment.
I wholeheartedly agree with the Township of Ramara’s submission and support their
recommendations, including their final point:

The Township of Ramara recommends the Ministry of the Environment, Conservation
and Parks (MECP) should modify the proposed Guideline to include land use
compatibility provisions to adequately protect the environment beyond quarry sites
from the possible adverse impacts of fly rock during blasting operations.
I appreciate the opportunity to comment on this file and look forward to further consultations.

Thank you for your consideration.