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.
Submitted May 6, 2019 2:58 PM
Comment on
Carmeuse Lime (Canada) Limited - Changes to the conditions of a licence to operate a pit or quarry
ERO number
012-9843
Comment ID
28340
Commenting on behalf of
Comment status