Re: EBR Registry # 010-6875 …

Re: EBR Registry # 010-6875 I am writing this objection letter in response to the notice regarding the application for a Category 2, Class A (Below the Water Table) License by Giofam Investments Inc. (the gProponenth) to mine granite from a deposit 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 (the gSiteh). I have found the process with respect to responding to this application confusing. The Notice sent out by the Proponent makes no mention of the Environmental Bill of Rights (gEBRh) and says the deadline for comments is July 10, 2009 whereas the EBR registry lists a deadline of July 23, 2009. I believe that the deadline for comments under the Aggregate Resources Act (gARAh) should be the same as the EBR registry in order to avoid this confusion. In addition, the proponents should be required to more clearly explain the process in their Notices and public presentations so that the public are properly informed. Please accept the following as the reasons for my objection: œ the Site is known to be the habitat of several threatened and endangered species and other Species at Risk under the Ontario Endangered Species Act; œ the Site is in an environmentally sensitive area containing diverse wetlands, flora and fauna contiguous with similar systems in the neighbouring Queen Elizabeth II Wildlands Provincial Park; œ based on a peer review by Hunter and Associates conducted on behalf of the Dalton Wildlands Defence League, of the various reports commissioned by the Proponent, there are a significant number of issues yet to be addressed; œ the impact of the production of silica dust and rock fines poses a threat to the environment and the health of people and other species in the area; and œ a quarry operation with the associated noise and traffic is incompatible with the recreational, residential and farming uses of the area. Threatened and Endangered Species The Proponentfs Natural Environment Level 1 and 2 Assessments are incomplete and do not convey adequate knowledge about the local ecosystem. For example, the Site is locally known to contain several species of turtles but these are not mentioned. In addition, the site visits were conducted during times when observation of these species is difficult. This report does mention an observation of a five lined skink, a species of Special Concern. These skinks live in the granite and both they and their habitat would be exterminated by quarrying operations. The Site contains wetlands that are contiguous with Provincially Significant Wetlands (PSW) and I believe would qualify as PSW itself. The proposed quarry access road goes through wetlands and I have not noted any consideration of the environmental impacts of this road by the Proponent. I understand that the Proponent is currently preparing a Species at Risk study. Why was this not completed and made available to the public prior to the commencement of the comment period on the quarry application? Also, if there are no threatened or endangered species observed during this study, will this lead to a conclusion that the quarry site is not habitat of these species despite sightings in the past and despite the site being in the known range of threatened species? The granting of quarry licences when there is no current evidence found of threatened and endangered species may be an incentive for unscrupulous land-owners to gsterilizeh their properties to ensure it is free of Species at Risk. I have no reason to believe that this site has had evidence of Species at Risk removed. Environmental Sensitivity The Site contains numerous diverse wetland features that would be erased from the landscape by a quarry operation. These features are a continuation of similar wetland systems contained in the neighbouring Queen Elizabeth II Wildlands Provincial Park and along the Cranberry River. The Park is a protected area and while the Site is on private land, it seems unnecessary to rezone rural lands that are compatible with the protected habitat. There is no shortage of granite on the Canadian Shield and I believe there are many more suitable sites for extraction that are less environmentally sensitive. The proposed quarry is so close to the Queen Elizabeth II Wildlands Provincial Park that it will affect the ecological integrity of the area. Hydrogeological Effects The Proponent carried out an extensive Hydrogeological Evaluation and this was peer reviewed by Hunter and Associates. This peer review notes that gone significant bedrock fracture on the margin or in the floor of the quarry excavation is all that it will take to change the predictions of the hydrogeology reporth. Furthermore there are several indications that further hydrogeological work is required. The layman is given the impression that the effects of the quarry on the water table are difficult to predict. As a couple of Hydrogeologists have said to me, the amount of water flowing into the open pits wonft be known until the pits are opened up. The volume of water proposed to be pumped from the quarry and released into the Cranberry River through Watercourse 1, is sure to have a negative impact on the adjacent landownerfs property. Watercourse 1 is presently a very small stream- a large part of it is only a foot wide and six inches deep. The Proponent estimates that the mine life of this operation is approximately 130 years. It seems that such an extended period of removal of water from the watershed will have dramatic effects on surrounding bodies of water, wetlands and wells used as a source of drinking water. To compound the issue, it doesnft appear that the province is collecting data on water being drawn from ground and surface water by quarrying operations. Surely quarrying operations in areas such as the Site should be limited to being above the water table. Silica Dust and Rock Fines Silica is a major component of granite (comprising 20% to 100%) and is a hazardous substance. The public documentation relating to the quarry does not appear to address the hazards associated with producing silica. The dust abatement procedures appear to be the same as would be applied with production of a more inert dust. I would have thought that a hazardous substance would require more stringent abatement procedures and I also would have thought it appropriate to conduct baseline air quality studies and to outline to the community ongoing air quality testing plans. I object to having a hazardous substance produced in our vicinity particularly with inadequate controls. The Proponentfs Geology and Resource Assessment states that the crushing and screening operations may result in the production of up to 40% fines. Hunter and Associates state in their report that a volume of 40% fines would take up an area equivalent to the volume of rock being mined. There doesnft appear to be adequate storage on the licensed area for all this fine material. Furthermore, the water in the area is naturally acidic and metals in the exposed rock, particularly the fines, could potentially be leached and subsequently released into the environment. A whole rock analysis does not appear to have been done nor has the environmental impact of the fines been fully considered. Noise and Traffic Issues We have a cottage at Cranberry Lake which is a few kilometres from the Site. We enjoy the quiet solitude of the area and the fact that we live with a low impact on this pristine, diverse and environmentally sensitive area. Due to the nature of the topography, sound travels fairly long distances. For example, we regularly hear trucks on County Road 45 that are using air brakes or have modified mufflers. I object to the threat posed by the quarry to having continued quiet enjoyment of our recreational property. County Road 45 is a winding, undulating road with most traffic concentrated on and around weekends. There currently is not a lot of truck traffic and turning this road into a haulage route with a quarry truck hauling every three minutes is objectionable to those living on and using the road.