My concerns, and questions…

ERO number

012-9849

Comment ID

28290

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

My concerns, and questions resulting form a series of email correspondence with Mr. Hagman, (see below) are two fold: Mr. Hagman’s contact information is: Darryl Hagman A/Aggregates Technical Specialist Ministry of Natural Resources and Forestry Aylmer, ON 615 John St. N. N5H 2S8 519-773-4747 darryl.hagman@ontario.ca Firstly, it is my understanding that the MOECC can make comment on these 6 EBR postings only if the MNRF sends a letter attached to the proposals to MOECC, specifically requesting them to do so. The following question is from my email to Mr. Hagman, dated April 10, 2017 “Has the MNRF sent a letter attached to Carmeuse Lime’s 6 EBR posted proposals, specifically requesting that the MOECC review them and provide written comments for the MNRF to use in their decision making process, and if so, may I please have a copy of the letter?”. Despite being informed that the MOECC has received over 80,000 letters of concern about the lack of rehabilitation and proposed after-use of this quarry property, during the ongoing landfill Environmental Assessment process, Mr Hagman provided the following response: “As discussed over the phone, the MOECC has not been requested to provide comments concerning the Carmeuse proposal.” My question specifically to the MNRF is: Given the high level of public interest and concern the community has regarding this quarry site, and the fact the Ministry of Environment and Climate Change has already approved the Terms of Reference (ToR) for Walker Industries’ EA (which the company is currently in the midst of carrying out on the Carmeuse property), will the Ministry send a letter to the MOECC and requesting them to make comments on these 6 EBR postings? It would seem prudent that the MNRF would seek to thoroughly discuss with the MOECC the overlap of the EBR posted proposals with the currently ongoing EA, as it is the MOECC who is leading the EA process and presumably understands the importance of not modifying the site during the EA tests and studies My second concern is that in a March 29, 2017 email from Mr. Hagman, he stated that: “As discussed over the phone, the 3 sites were in operation prior to the Pits and Quarries Control Act (PQCA) coming into effect in 1971. As a result of this, the sites were basically grandfathered in under the PQCA and granted a licence after a site plan was submitted and approved in support of the licence applications. There were no technical reports submitted in support of the licence applications. Regarding the “Grandfathering” argument. There is no clause in the ARA that absolves older licenced sites from having conditions applied. The Ministry can apply conditions to any licence at any time. In this case, the applications for Major Site Plan Amendments and proposals to Vary, Rescind or Amend Conditions of a Licence were initiated by the licencee, Carmeuse Lime. Regardless of the fact that Carmeuse initiated the applications and put forward the proposals, the Ministry may require conditions to be added to the site licenses, may require notes to be added to the site plans, and may require technical documents to be provided that support the applications. They may also, as mentioned earlier, enlist the assistance of the MOECC by specifically attaching a letter requesting comments to the proposals. My concern is, in lieu of the fact that there are zero technical studies available since the quarry was started over 100 years ago and since Carmeuse Lime is a mega quarry, dug into our community’s “Highly Vulnerable Aquifer “ and ground water is the primary source of the County’s agriculture industry and our entire 106,000 population drinking water, I believe it would be in line with the Precautionary Principle for the MNRF to require, at a minimum, the following Technical studies and/or reports. Technical Reports Required for a Category 2, Class “A” Quarry, Below Water Table May Include: - Hydrogeological Level 1 and Level 2 - Natural Environment Level 1 and 2 - Cultural Heritage Resource (Stages 1-3 depending on findings) - Noise Assessment Report - Blast Design Report In conclusion I am requesting that the MNRF send a letter to MOECC requesting their input into this process . Also, I am requesting that the MNRF put conditions on Carmeuse site plans, since they have not had to do them to date, requiring them to do the contemporary studies that they would be required to do if this was an new licence application.