Comment
If you have received other comments from me, please ignore them. There is something wrong with your
website today. Thank you.
I am 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 my objection. A
summary of my comments, requests, and objections 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. I understand that wells within 500
metres or, perhaps, 1 kilometre of the quarry will be tested on an annual basis. I 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, I ask that these wells be included in the annual monitoring process. I 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, my neighbours and I 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, I insist that the firm hired for the monitoring will be a firm recommended by the
Ministry of Natural Resources or the Ministry of the Environment 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 provided 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 data 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.
I know the water was tested because my husband escorted the technicians to the property and they
performed the test while he was watching. 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. I have to wonder how many other items are missing from the
report. I suggest that the Ministry of the Environment 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 protection of our
drinking water. I would like the MNR to suggest the construction of a low permeable 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. I am 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. I 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. I 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. Quarries 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.” I 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 and the Ministry
of the Environment, in fact, all levels of government, should be more concerned with protecting our
natural resources rather than with exploiting them.
ACCESSORY 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. I 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. I am also concerned that the location will create a backlog of trucks on County Road
45. I 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.
I 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. I 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, I 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. I realize this is a matter of faith and trust and at the
present time I 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
I 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. I 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. Dalton Township should remain an undesignated quarry township.
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. I expect
the MNR and the Ministry of the Environment to protect this natural resource.
APPLIACANTS' 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 me
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. 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 requirements
of the ARA? If there are any industry programs or courses on mining granite I 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.
I could go on, and on, and on but I know that some other people are covering areas that
I may have missed. I hope you find the summary below helpful but please refer to the
paragraphs above for more specific details regarding my comments and requests.
SUMMARY OF COMMENTS/REQUESTS/OBJECTIONS
(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 object to 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. In fact, the clean, pure environment we now
enjoy in Dalton Township will be gone forever.
Submitted May 16, 2019 11:06 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
29226
Commenting on behalf of
Comment status