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010-6875

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29226

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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.