Comment
Please accept these comments as applying to the 6 concurrent EBR postings that are inter-related: 012-9852, 012-9850, 012-9849, 012-9848, 012-9845, 012-9843. Our Ontario based non-profit organization, Transition to Less Waste (TTLW), promotes environmentally sustainable decision making, and wise land use planning. TTLW opposes the 6 proposals represented by the above EBR numbers. In addition, we are requesting that the MNRF extend the comment periods for the 6 concurrent EBR postings to a minimum of 90 days in order to give the public a more reasonable time period to review and comment on applicable materials. The MNRF has been reminded on multiple occasions by the Environmental Commissioner and Attorney General (among others) to provide more thorough EBR postings, and opportunities for meaningful public comment. In this case, we feel the very sparse EBR postings and minimal comment periods are absolutely insufficient. Many of our members have encountered problems with the EBR comment submission system since the onset of the 30-day comment period (system errors). As an organization, we have also been unable to access any materials via email or the EBR for review of these proposals beyond a very basic, crude, inaccurate drawing of the quarry site, and a short letter from the proponent. These minimal materials are not posted to the EBR, although to do so would be a simple matter, and instead, had to be sought out through our municipality. The EBR postings contain no site plans, no technical documents of any sort, and no detailed schematics of the proposed changes. There is also no independent or ministry-provided analysis of how the changes on this complex site may impact drinking water, air quality, or future proposed land uses for the property. In addition, we are perplexed as to why the MNRF insists on reviewing the proposed changes as if there was not a currently ongoing environmental assessment for a massive landfill occurring on this property. It is not in the public's best interest for there to be a lack of communication between the two ministries that share the majority of the responsibility for protecting the public from being impacted by activities carried out on this quarry site. That means the Ministry of Natural Resources and Forestry and Ministry of the Environment and Climate Change must work closely on this matter. This of course means that either the environmental assessment must be cancelled, or the quarry company must be informed that the agreement they have to allow this landfill EA to be carried out means that proposals for major site plan amendments will not be accepted at this time. We are aware that Carmeuse Lime operates one of the largest open-pit limestone quarries in Ontario at this site, and that negative impacts attributed to quarry and manufacturing activities on the site have been reported to be the cause of decades of adverse effects. As this large industrial property is adjacent to residential homes, walking trails, parks, daycares, schools and other community facilities, it requires close attention and wise land use planning decisions to be made by the MNRF and MOECC. How will these proposed changes impact local water quality? Our approximately 106,000 community members in Oxford County are all 100% ground-water dependent for drinking water, water for household and farm use, and water for commercial businesses. How will the soil quality and sustainability of the land in the area be impacted by these proposed changes? TTLW is a member of Food & Water First, and we advocate for protection of Oxford's prime agricultural area and lands. Will the proposals have an impact on air quality? Will changes to the haul entrances on the property make driving in the area more dangerous for people who use County Road 6? Will the air quality be further impacted by movement of fill and proposed alterations that may alter stockpiling on the property? Will there be an addition to the 93 metric tonnes of road dust Carmeuse self-reported as adding to local roads in 2014? Will the quality of life of people who live near or travel in the area of the quarry be impacted? Will school buses travelling down County Road 6 or Beachville Road, be at increased risk? Will the taxpayers of Oxford County be on the hook for costs associated with a tunnel built under a County road? Has the MNRF considered historical non-compliance issues, and problems controlling water and dust on the site, in relation to these proposals? There is no information available to the public on the above matters, which may impact the environment, and potentially cause adverse effects. In conclusion: TTLW is asking that the MNRF extend the public comment period to a minimum of 90 days. We are letting the MNRF know we find the extremely limited amount of information and lack of of materials provided for review of these proposals to be inadequate. We are questioning why ministries with co-responsibility for overseeing a large industrial property are not communicating properly, and we are asking that you register our organization's opposition to the 6 proposals. Thank you.
Submitted May 6, 2019 2:15 PM
Comment on
Carmeuse Lime (Canada) Limited - Changes to the site plan for a pit or quarry
ERO number
012-9850
Comment ID
28259
Commenting on behalf of
Comment status