Comment
We are writing this objection in response to the notice regarding the application for a
Category 2, Class A (Below the Water Table) License by Giofam Investments to excavate granite
from a proposed quarry located on Part of Lots 18 through 21, Concession 4, and Part Lots 19
and 20, Concession 5, in the geographic Township of Dalton, formerly the County of Victoria,
now in the City of Kawartha Lakes. Please accept the following as some of the reasons for our
objection. A summary of our requests, objections, and comments can be found at the bottom of
this letter.
Unacceptable Impacts on the Water Supply and Water Quality
The only source of drinking and household water in this area is groundwater. All private
wells for homes, neighbouring farms, and businesses rely on it. The proponent has dug
boreholes to monitor well water levels on the quarry site. We understand that wells within 500
metres or, perhaps, 1 kilometre of the quarry will be tested on an annual basis. We insist that all
of the wells that were tested for the Giofam Quarry by Jagger Hims in 2006 be included in the
annual testing process. Jagger Hims went well outside of a 1-kilometre radius in their initial
testing and there must have been a reason for this. Further, if there were any wells that were not
tested in 2006 within a 3-km radius of the proposed quarry, or closer than 2-km to the edge of
the Giofam property, we ask that these wells be included in the annual monitoring process. We
insist that the annual monitoring includes all of the details included in the hydrogeological
report generated from the 2006 testing and that each property owner will receive a copy of their
well monitoring report in a timely manner. Needless to say, the company hired to monitor these
wells must have permission from the landowners in order to perform the testing.
Further, we ask that all property owners involved in the well-monitoring process receive an
acknowledgment that the testing will be done as well as an explanation of what Giofam
Investments is prepared to do if our wells become polluted, contaminated, unfit for human
consumption, or run dry. In other words, we would like to have a contract which outlines these
details. We would not be satisfied with the promise of bottled water. In fact, we would like a
guarantee that Giofam Investments would be responsible for all costs involved in drilling new
wells and that the work is performed in a professional and timely manner. We are very
concerned about the adverse effects and negative impact that blasting, especially below the
water table, will have on our water supply.
Further, we insist that the firm hired for the monitoring will be a firm recommended by the
Ministry of Natural Resources and not necessarily Jagger Hims. Jagger Hims promised, in
writing, that the people involved in the initial testing would receive the results of the chemical
analyses and to my knowledge (and my own personal experience) these reports were not pro-
vided even when dangerous levels of lead, for instance, were discovered. We owned three of the
properties tested at the time and did not even receive one report. Failure to mail the letters may
have been the result of a clerical error but there are also elements of this testing which were not
included in the final report which makes us question the credibility of the entire report. The
property at 655 Monck Road (which we owned at the time of testing) is mentioned in the
Hydrogeological Evaluation but the testing date does not appear in Table A-3, the well is not
included in Table B-3 and the chemical results are not included in the Hydrogeological
Evaluation. Since this particular well is closest to the quarry site it should definitely have been
included in the above-mentioned tables and chemical analyses should also have appeared in the
report. We have to wonder how many other items are missing from the report. We suggest that
the MNR thoroughly review the Hydrogeological Evaluation before issuing a licence. Perhaps,
another full Hydrogeological Evaluation is required.
The mitigation system includes trigger mechanisms which will warn the applicant when
water levels drop but we want guarantees that our wells will remain clean and operational.
The mitigation system includes no details and no contingency should it fail. This state of affairs
leaves our community exposed and is unacceptable.
Water produced from dewatering the open pits will be fed into nearby watercourses which
will then flow into the Cranberry and Head River watersheds. The proponent will be applying
for a permit to take as much as 8.1 million litres of water per day. This is equivalent to the
consumption of approximately 10,000 households (based on Environment Canada’s published
per capita residential consumption in Ontario of 260 litres per day and assuming three persons
per household). Discharging this amount of water into the Cranberry River would double the
flow rate during low flow periods in the summer. Drawing this amount of water from the water
table and then discharging it into the river is likely to affect the many species of wildlife that
live
in the wetlands and the Cranberry River and their habitat.
The new Clean Water Act promises protection for our drinking water right at its source. The
law promises to prevent problems before they happen. If something goes wrong, there is no
Plan B for our drinking water. The proponent has not and cannot offer a viable plan for protec-
tion of our drinking water. We would like the MNR to suggest the construction of a low perme-
able barrier around the quarry site to stop the flow of silica-dust-laden water from flowing into
the surrounding watercourses. A low permeable barrier is part of their mitigation plan
(although they suggest that the barrier would only be on the south part of the site) but we
believe it should be an integral part of their Site Plan from the outset. Further, the applicant
has
told us that they plan to rely on rainwater for the first part of their operation (although they
didn’t specify the length of time). To keep our watersheds at their natural levels it would seem
logical to ask them to continue this practice throughout their operation without taking water
from the nearby watercourses. In other words, the quarry should be self-sufficient and interfere
with our ground water as little as possible. Jason Baldson of Jagger Hims stated at the 16 June
public meeting that the water would not be taken from the Cranberry River. Is there a way we
can hold them to this statement for the life of the quarry operation? He didn’t say exactly where
the water would come from but since the surrounding watercourses, beaver ponds, and
wetlands are off limits I have to assume that they will not be a source of water for the quarry.
Protection of our water must be the first priority and take precedence over a proposed quarry.
And, finally, the current application is for a Below the Water Table licence. We are
requesting that if you do issue a licence that it be for ONLY an Above the Water Table licence.
The province of Ontario must stop issuing below ground water permits to the aggregate
industry.
No Acceptable Haul Routes and Public Safety at Risk
Monck Road is narrow, winding, and has beautiful scenery. It would need significant
widening and asphalt build-up before becoming a haul route. Quarry trucks will leave a trail of
dust, including silica dust, on and beside the roads, on the Head River and on Young’s Lake. The
road is used by the people who live here to get to work, to schools, to and from agricultural
operations, to local businesses, to friends, and to community sports and activities. It is also
used
by emergency vehicles. After leaving the Monck Road the quarry trucks will travel south or
north on Highway 169 and then travel great distances before reaching any 400-series highways.
The province should look at using the existing quarries along the 400 highway in the Parry
Sound area before it starts to excavate granite from virgin operations which need to depend on
secondary arterial roads for transport. Recycling of highway pavement is the norm in Europe.
Ontario should be following this practice as well instead of using up its natural resources at such
an alarming rate.
There is no agreement on who would pay for the capital and ongoing maintenance of the
Monck Road and no plans are in place for bringing the road up to standards before the quarry
operation begins.
At the present time there is no Haul Route agreement. We understand the County of Simcoe
and Ramara Township are opposed to allowing a Quarry-based Haul Route across their portion
of the Monck Road. There are also no viable alternatives at the present time. The mayor of
Ramara Township, Bill Duffy, has suggested a detour around Sebright. This option makes
absolutely no sense because 1) approximately three kilometres of the Monck Road would still be
a haul route (through a heavily populated, recreational area); and 2) the proposed detour would
have a negative impact on a large environmentally sensitive area southwest of Young Lake.
The increased traffic on the Monck Road would cause significant problems for the existing
users. We already have to deal with a lot of tourism traffic in the summer and there have been
numerous fatalities on the Monck Road in the last 5 years – many of them caused by speeding
or passing on curves. There will be health issues from truck emissions, especially if and when
the trucks line up at the quarry gate or in the field beyond the gate. The noise from trucks,
especially the empty ones, is a concern and one not dealt with in the application documents.
Finally, the increased traffic (and the nature of it) will create safety risks for cars, school
buses,
farm vehicles, pedestrians, and cyclists. One accident is too many.
The proposed entrance to the quarry is totally unacceptable. Although it falls within MTO
minimum sight requirements those of us who live in this area know that it will become
another dangerous area on the Monck Road. At the present time making a left- or right-hand
turn from or on to Lake Dalrymple Road is precarious. Nine times out of ten someone is on your
bumper right after you make your turn. It also interferes with a neighbouring farm operation
and will cause major inconvenience to the other property owners who live on the north and
south sides of the intersection.
New Traffic Study Required
The traffic study which was conducted did not include a Friday or a Monday. A new traffic
study needs to be conducted which includes the tourist traffic on Friday afternoons, Saturday,
and Sunday mornings. We suggest this study be undertaken in June, July, or August.
Destruction of the Natural Environment in Our Unspoiled Township
This is a beautiful part of the province. There are forests, meadows, lakes, rivers, streams,
swamps, and unspoiled wilderness. And, because these habitats exist, we have pike, walleye,
bass, and muskie; songbirds, osprey, herons, owls, waterfowl, loggerhead shrike, whippoorwills,
hawks and other raptors; white tailed deer, foxes, coyotes, bears, beavers, minks, and otters; a
wide range of insects; turtles, frogs, 5-lined skinks and salamanders; and other creatures. We
have flora like the tamarack, burl oak and numerous species of wildflowers and mosses. Quar-
ries and the huge open pit mines they create are destructive. They remove everything in the
extraction area – the soil, the plants and the trees, and they change the temperature and
chemistry of the streams. Habitats are permanently lost. Endangered species, species at risk and
their habitats, are present on and around the site. Some were mentioned in the Giofam reports;
some were not. The quarry would impact all of them and how they connect to one another.
Giofam Investments’ application documents tell us they concede these features are present but
they want us to believe that the unproven mitigation system will take care of everything. Bev
Wicks, one of the Aquatic Biologists hired by the applicant, told some people at a private
meeting on 23 May that a 5-lined skink, a Species of Concern, was seen during their study on
one of the rock knobs right where the first excavation is to start. If this is true it speaks
volumes
about the operators’ lack of concern for this species and the environment in general. Although
field studies were undertaken for the application a lot of the findings relied on out-of-date
studies and reports and several suppositions when data was not available.
Protecting the diversity of species here and maintaining natural corridors and connectivity
is very important. The MNR should be doing everything in its power to protect the combination
of natural attributes existing in this area. Blasting, dust, noise, vibrations, lights, fuelling
and
maintenance, and trucking would also negatively affect the environment. The destruction from
an open pit mine would be permanent.
It should be pointed out that local people have seen yellow spotted turtles, which are an
endangered species, on and beside the property. When this was brought to the attention of the
City of Kawartha Lakes Planning Committee at a public meeting held on March 11, 2009 I
witnessed Mr. Giordano and his colleagues laughing so much that their faces turned red; they
abruptly stopped laughing when they noticed that they were being observed. This is not a
laughing matter. We contacted the MNR biologist for our area, Graham Cameron, and his
response included the following paragraph: “Lastly, as the secrecy of spotted turtle populations
is of the utmost importance in preserving the species, I would ask that mention of Cranberry
Lake spotted turtles be limited as much as possible. A well organized team of poachers,
organized criminals, or an avid pet collector have wiped out similar populations in one day of
collecting. I wouldn’t want this to happen at Cranberry Lake.” We understand that Dr. Cameron
visited the site in early June 2009 and it is my sincere hope that he will be equally adamant
about protecting the yellow spotted turtles from annihilation through blasting and the
subsequent destruction of their habitat as he is about protecting them from poachers. This
should be one of the MNR’s top priorities. If the hibernation site or nesting sites of these
turtles,
are destroyed, so is the turtle population.
The proposed site will be the next door neighbour of the Queen Elizabeth II Wildlands
Provincial Park, a park created to fulfil four objectives: protection, heritage appreciation,
recreation, and tourism. None of these objectives will be met if a quarry is permitted right
beside the park, especially since the quarry property will not be fenced. The MNR should be
more concerned with protecting our natural resources rather than with exploiting them.
Acccessory Uses Area Diminishes Scenic Beauty
and Natural Amenity of the Surrounding Area
Although the actual quarry site is not in the public’s view the accessory use area will be in
full sight of the Monck Road – a constant reminder of what we can’t see going on in the
background. The applicant claims that this is for security purposes. We want the complete
facility to be out of our sight and the applicant has more than enough land to move the
accessory uses area away from public view. We object to the location of this accessory area
because trucks will be idling close to adjacent properties and the area will be unsightly thus
having a significant negative impact on our peaceful enjoyment of life. These factors will affect
air quality and create a lot of noise, dust, and pollution. We are also concerned that the location
will create a backlog of trucks on County Road 45. We trust that the Ministry of Natural
Resources and/or the City of Kawartha Lakes will be insistent on the establishment of turning
lanes and road widening where required and that Giofam will be responsible for paying for
these changes.
We suggest that a staging area be developed close to the accessory uses area so that trucks
can pull in off the highway and park well away and out of sight of the highway. We insist that
there will be no congestion or parking on County Road 45. The property owner has 1000 acres
at his disposal. And, as mentioned above, we demand that the entrance be moved to a straighter
stretch of road.
Hours of Operation
The quarry plans to operate Monday to Friday, 7 am to 7 pm and on Saturday mornings. The
hours of operation should be cut back to Monday to Friday, 7 am to 3 pm (in other words, 8
hours per day) and the operation should be closed on Saturdays, Sundays, and holidays. Ideally,
the operator should check the school bus schedules on the haul route and try to limit trucks
when they know the school buses are using the haul route. We realize this is a matter of faith
and trust and at the present time we see no evidence of either virtue in the applicant. If there is
a way to force this issue it would be much appreciated by all concerned.
Blasting Conditions
We understand that the noise and vibration from blasting is amplified if blasts occur on
overcast, cloudy, and/or windy days. At the private meeting on 23 May we asked if blasting
could be scheduled for only sunny, clear days and we were told that to do so would put the
quarry workers at risk and would be economically unfeasible. This is not satisfactory. We insist
that there will be no blasting during poor weather conditions. We have a fairly accurate weather
forecasting system in Ontario and there is no reason for Giofam to blast unless the skies are
clear and there is relatively little wind. The Site Plan should reflect the fact that no blasting
will
occur during poor weather conditions.
Damage to Farm Land
Growing / raising and buying local food is important to all of us. The number of working
farms in our area has diminished considerably in the last 20 years. However, there is an active
farm right beside the proposed quarry and we are all concerned that this and other farms in the
area could be affected by water impacts, dust, noise, and truck traffic on the same road used by
farmers and farming equipment.
The Land is not Zoned for Mineral Extraction under the Official Plan; This
Proposed Use is Incompatible
The land for the proposed quarry is zoned rural, residential, not for mineral extraction by an
industrial company. There are no other quarries in Dalton Township and we do not think the
Official Plan should be changed to allow their existence in our quiet, clean, natural environment.
This application does not meet at least 3 out of 7 requirements of the City of Kawartha Lakes for
changes to the Official Plan. Tranquility is the largest natural resource in Dalton Township and
it is a resource that benefits not only the residents of Dalton Township but the many tourists
who pass through our area. We expect the MNR to protect this natural resource.
Applicants’ Lack of Experience
Through the public and private meetings it has become abundantly clear that Mr. Giordano
lacks experience in the extraction of granite. He has been unable to answer a lot of questions
posed at these meetings pertaining to the ongoing operations of the proposed quarry. For
instance, he doesn’t have any idea how many people will be required to operate this site. This
leaves us wondering if he knows anything about operating a granite quarry. Any examples he
has cited were related to limestone, sand & gravel operations. He has not been able to enlighten
anyone about granite quarry operations. This leaves us wondering if he knows anything about
operating a granite quarry. Does the MNR or any related associations have any tests in place to
determine if applicants are qualified to operate their quarries safely and within the require-
ments of the ARA? If there are any industry programs or courses on mining granite we strongly
recommend that the MNR insist that Mr. Giordano must enrol in as many of these courses as
possible until he can prove that he has the knowledge and the expertise to operate a granite
quarry. Our community cannot afford to suffer the consequences of Mr. Giordano’s on-the-job-
training.
We could go on, and on, and on but I know that some other people are covering areas that
we may have missed. I hope you find the summary below helpful but please refer to the
paragraphs above for more specific details regarding our requests.
Summary of Requests/Objections/Comments
(see individual paragraphs above for detailed requests)
1. Contracts for property owners within 3-km radius for annual well monitoring to include
receipt of annual chemical analyses reports; and in the event of wells in the monitoring
program becoming polluted, contaminated, unfit for human consumption, or running dry
Giofam will cover all costs involved in drilling and connecting new wells in a timely
manner employing a contractor approved by the property owner.
2. A new Hydrogeological Evaluation or a thorough review of the Evaluation presented by
Jagger Hims.
3. Construction of a low permeable barrier around the quarry site.
4. Guarantees that the quarry operator will not draw water from the Cranberry River or the
surrounding watercourses, beaver ponds, and wetlands.
5. Change the licence to an Above the Water Table licence only.
6. Upgrade the section of the Monck Road from the quarry site to Sebright at the operator’s
expense. The upgrade would include major improvements to the existing highway
including widening of the road at the quarry entrance to accommodate a left-turn lane and
an acceleration lane. There are no sound, sensible, alternative haul routes.
7. Assuming that road improvements are brought up to standard for quarry trucks the
proposed entrance must be moved to the eastern portion of the property.
8. A new traffic study is required to include a Friday or a Monday in the tourist season.
9. Endangered species, species at risk and their habitats must be protected. Further studies
are
required and they need to be conducted at the right time of year. The site is surrounded by
beaver ponds and all of the wildlife that beaver ponds support. How can the MNR
guarantee that the beaver ponds and watercourses will not be damaged by this quarry
operation? We would like a full explanation of how this will be accomplished.
10. How will the objectives of the Queen Elizabeth II Wildlands Provincial Park be met? At
the very least the boundary should be fenced.
11. The accessory uses area must be closer to the quarry operation and out of sight of Monck
Road.
12. Under no circumstances can quarry trucks be allowed to park on the Monck Road while
waiting for entrance to the quarry. A staging area should be developed close to the
accessory uses area (away from the road).
13. The quarry should only operate 8 hours per day and not on Saturdays. They should try to
avoid high volume traffic when school buses are using the Monck Road.
14. Blasting should occur only on sunny, clear days.
15. The quarry operator should go out of his way to accommodate the needs of the
neighbouring farm owner. Are there any regulations that the MNR can put into place to
achieve this?
16. It is our hope that the zoning by-law and official plan will not be amended. We know this
is outside the MNR’s purview but have added this point because we see no advantage to
the municipality if the quarry receives a licence. We firmly believe that if the City of
Kawartha Lakes was not wary of having to pay for an OMB hearing that they would not
grant the amendments.
17. The quarry operator should have to prove that he is capable of operating a granite quarry.
We hope that there are provincial requirements for operators and that he will be forced to
expand his knowledge of granite quarry operations. At the present time his knowledge is
insufficient. What can the MNR do to reassure us that the quarry will be operated in a safe
and environmentally friendly manner?
Please deny this quarry licence. Approval of the licence will adversely affect or interfere
with public health and safety, comfort levels, the enjoyment and normal use of our property and
will impair the quality of the natural environment.
Submitted May 16, 2019 10:59 AM
Comment on
Giofam Investments Inc. - Issuance of a licence to remove over 20,000 tonnes of aggregate annually from a pit or a quarry
ERO number
010-6875
Comment ID
29204
Commenting on behalf of
Comment status