February 11, 2014 RE - EBR…

February 11, 2014 RE - EBR Registry Number 012-0903 We would appreciate very much if you would consider the following comments regarding the application for this gravel pit: Notes re Saugeen Conservation Letters January 2014 Jan. 10, 2014 – SVCA to Cuesta Planning This letter notes that “the pit application and the supplemental reports, including the Level 1 Hydrogeological Study....” etc. were reviewed and “The SVCA has no objection to the proposed Category 1, Class “A” Pit Licence.” Jan. 13, 2014 – SVCA to Cuesta Planning As above letter In these instances, we have concerns that using flawed reports will also result in flawed conclusions. The SVCA is using reports sent that are not sufficiently detailed so as to make an informed decision. There are many other reports that have been done (e.g. Drinking Water Source Protection Act - Assessment - http://www.waterprotection.ca/plan/p-reports.htm) which show the Saugeen Valley Source Protection Area Assessment Report – http://www.waterprotection.ca/AR/svspa-ar.htm (approved as at November 28, 2011). The complete report (524 pages) can be found at http://www.waterprotection.ca/AR/SVSPA/SVSPA_Approved_AR_Complete_Text.pdf Township of Chatsworth - see 4.2.3, p. 239 of report This assessment report shows many maps for the area of Chatsworth including susceptibility to contaminants, etc. as well as much more detailed information regarding the entire Saugeen Conservation Area, broken down into pertinent areas. They note “The susceptibility of groundwater aquifers for this municipality is mapped in 4.3.M1...” Maps are #’s 4.3.M1 – 4.3.M9 Links to the maps are at the link noted above, but are shown below as well: Chatsworth: MAP43M1_MUNI_ISI_CHATSWORTH MAP43M2_MUNI_HVA_SGRA_CHATSWORTH MAP43M3_MUNI_HVA_VUL_CHATSWORTH MAP43M4_MUNI_SGRA_VUL_CHATSWORTH MAP43M5_MUNI_HVA_SGRA_IMPERV_CHATSWORTH MAP43M6_MUNI_HVA_MANAGED_CHATSWORTH MAP43M7_MUNI_HVA_NUTR_UNITS_CHATSWORTH MAP43M8_MUNI_SGRA_MANAGED_CHATSWORTH MAP43M9_MUNI_SGRA_NUTR_UNITS_CHATSWORTH Jan. 10, 2014 – SVCA to County of Grey and Township of Chatsworth This letter notes “Authority staff has conducted a recent site inspection of the property.....” The Authority is of the opinion that the proposed applications appear to conform to the relevant natural hazard and natural heritage policies....” “The woodlands located in the northeast corner of the subject property could be considered a significant natural heritage feature.” “...the proposed limit of extraction will be more than 50 metres from the areas that have been identified in the Official Plan as significant woodlands, and 20 metres from the woodland on the northeast corner of the subject property. Numerous technical reports..... these reports have concluded that there will be no negative impact on the woodlands. The conclusions of the report are acceptable......” Jan. 13, 2014 – SVCA to County of Grey and Township of Chatsworth As above letter Please excuse my skepticism, but if memory serves, the week of January 6-10th was a particularly bad weather week with roads closed and everything covered in massive amounts of snow. “A recent site inspection of the property” does not mean much if everything is covered and staff is unable to walk anywhere on the property. If observation from behind the wheel of a truck constitutes “site inspection”, we don’t feel that is an adequate site inspection. Again, as to “numerous technical reports”, the SVCA seems to be relying on technical reports that are superficial at best. Regarding the Official Plan and identification of “significant woodlands”, if the Official Plan can be amended, then the identification of the woodlands could be amended as well. This would then necessitate an alteration of the technical report as it now stands to reflect the 50 metre setback from significant woodlands including the proponent’s woodland. ******************** Notes re Ministry of the Environment Letter February 3, 2014 To Cuesta – February 3, 2014 As noted in the comments previously mentioned above, the MOE also seems to be accepting the reports as presented by the proponent of this gravel pit. They have qualified their comments as “based on the information provided”, “reasonable to expect”, “general opinion”, “not anticipated”, etc. However, it is noted that the Ministry is requesting further investigation regarding shallow “unlicensed” domestic water supplies. Water used for watering livestock would not appear to be mentioned, yet our understanding is that the spring on the property was used to water stock in the past. Have known of other instances in Ontario where water was diverted to stock tanks, but don’t believe this is mentioned in their report. If the water becomes contaminated and your livestock are affected, should this not also be a concern? Does the Ministry of the Environment not take into account Air Quality as well? No mention of that in their letter that can see. Another report that does not appear to be mentioned in the proponent's report (unless have missed it), is found at - http://www.grey.ca/media/files/Final_Report.pdf Entitled Grey and Bruce Counties Groundwater Study Final Report – July 2003, prepared by Waterloo Hydrogeologic, Inc. WHI Project # 3020337 (264 pages) They go into considerable detail and technical jargon (including karst, etc.) which is not reflected in the reports presented by the proponent of this pit. ****************************** Thank you for taking our comments into consideration,