The proposal to extract…

The proposal to extract aggregate by underwater blasting from the proposed Campbellville Reid Road Quarry has potentially catastrophic effects on the surrounding area's air quality, ground water quality, traffic flow and has the potential to damage or destroy important habitats on and around the Niagara escarpment.
The Niagara escarpment is home to many unique species and is recognized by UNESCO as a unique environment worth recognition and protection, with habitats that include wetlands, woodlands, limestone alvar pavements, conifer swamps and many others. These habitats collectively boast the highest level of species diversity among Canadian biosphere reserves, including more than 300 bird species, 55 mammals, 36 reptiles and amphibians, 90 fish and 100 varieties of special interest flora. Therefore, a high level of careful consideration should be given to any projects which could detrimentally impact the area’s plant, animal and human populations. The impact to the Niagara escarpment and other surrounding areas would be especially embarrassing to the government due to its UNESCO status and could make international news if the area is detrimentally affected by an activity that was not thoroughly assessed for its potential for damage.

JDCL's own experts state that extraction above 350,000 tones/year could impact water levels for Milton and surrounding areas, provincially significant wetlands, the habitats of endangered and threatened species, and significant woodlands at the site, all of which could be permanently affected. In 2008, City of Guelph staff discovered that JDCL’s quarrying had reached the aquitard—the dense layer of rock that protected their drinking water through their work on the DoLime Quarry. JDCL’s practices could threaten the health and well being of tens of thousands of citizens in the surrounding area who rely on the local aquifer for drinking water and who would have no other source of drinking water should the aquifer be contaminated with surface toxins. Contamination of groundwater will affect water levels which supply the Kelso wells and local residential wells.

Operations at the Quarry will negatively impact the air quality of the surrounding area. Blasting, crushing, pulverizing, truck emissions all create dust particles less than 2.5 microns. Health Canada warns there is no safe level of increased PM 2.5 exposure & yearly over 9500 people die from the results of exposure. These particles can travel tens of kilometres over short periods when caught in the winds. Air pollutants such as these are especially dangerous for the elderly and young children and the Milton area has recently seen a large influx of young families as well as being home to many elderly families who have lived here for decades. Particulates such as DPM, B(a)P and benzene which can be produced in these types of activities are responsible for causing serious health issues such as cancer, respiratory problems, premature death. The Ontario Environmental Protection Act, 14 (1) Subject to subsection (2) it states that “but despite any other provision of this Act or the regulations, a person shall not discharge a contaminant or cause or permit the discharge of a contaminant into the natural environment, if the discharge causes or may cause an adverse effect.” 2005, c. 12, s. 1 (5). This part of the act should be taken into consideration when assessing JDCL’s application. JDCL has also not taken into account the baseline PM 2.5 exposure which already exists along the 401 corridor and their activity will add to an area already exposed to particulates due to traffic activity.

Overall, JDCL has not accounted for all minerals potentially released through their activity and they provided conservative assumptions for crystalline silica, DPM, B(a)P, benzene and other proposed recycling materials. At 10micrograms/m3 there are already 85 premature deaths recorded in Oakville each year due to PM2.5 particulate from quarry activity.

Seismic vibrations should also be a consideration when approving JDCL’s submission for blasting. The Blast Impact Assessment performed failed to consider the worst-case scenarios of potential seismic vibrations and overpressure impacts on nearby sensitive receptors (like homes, businesses and Hwy 401).

Flying rock from blasting can cause property damage, personal injury or even death and can travel up to 1km. Other countries require a 400 to 500 meter blasting exclusion zone. Hwy 401 is only 100 meters from certain of the blast areas, (as are other Campbellville roads).

The Quarry will operate 13 hours a day, 6 days a week, carrying 32 quarry truck trips during the peak. Additionally, there will also be truck traffic that ships recycled materials in and out for the asphalt reprocessing operation and quarry service vehicles and employee vehicles. This traffic is an increased risk to pedestrians, school children, cyclists, local traffic and commuters.

Highway 401 is frequently stalled due to high traffic in the area. The Traffic Impact Study states that maintaining the existing form of traffic control to the 401 is forecast to result in high levels of delay on the off-ramp approaches on Hwy 401. The west bound off ramp is often congested with current traffic levels which will force the trucks to find other routes which will include Guelph Line and many other rural roads. This will damage quiet local roads not built for heavy truck traffic as well as significantly increase noise which will put further a further tax burden on the local municipality for additional road repairs.

JDCL plans to fill one pond and create an asphalt and concrete re-processing operation. JDCL’s application indicates they intend to bring used asphalt on to the site, stock pile it and recycle it. There is no limit on how long the re-processing operation will be active and these ponds, if not maintained correctly, could further pollute and damage the environment and local water sources.

JDCL has not performed sufficient studies to ensure they would not cause the kinds of aforementioned damage and if there is damage to homes or businesses, or loss/contamination of water, the property owner has the burden and cost of proving it was caused by the Quarry. JDCL is merely required to self-assess its operation and file a Licensees Compliance Assessment Report. A detailed and thorough environmental assessment should be performed that include speciating “mineral dusts”, estimating uncertain emissions, dust control, impact of recycling operations, dispersion modelling that includes baseline air quality and a full Health Impact Assessment on contaminants including PM2.5.

Considering the serious impact this project will have to the regional population as well as the UNESCO recognized natural environment, I submit that a much deeper assessment is needed to ensure that the proposed project will have no negative impact.