AWARE-Ontario.ca
Comment on
Environmental Registry (EBR
011-7914) until
Comment suggestions by the Concerned Citizens of Brant:
Re: EBR Registry Number: 011-7914 –
A great deal of effort has been put into these comments. Please do not
disregard them, do not ignore them. These issues will be required to be
addressed before any new licences are granted in the
My name is <name> & I support this submission by CCOB. I am a
Concerned Citizen Of Brant!
According to the hydrogeological assessment of
the Olszowka property, section 5.2.4 talks about the
temperature of the groundwater and indicates that groundwater above 5 meters is
subjected to 4-12 degree variations however water below 7 meters stays
relatively stable. Removing the 5-7 meters of earth will also expose the
aquifer to within 1 meter or less of the surface and will heat the water table
under the entire operation by as much as 10 degrees. This calculation was not
included when determining potential effects on the natural wetland areas.
This increase in temperature was
noted in the same study that the thermal plume data was based on; “Thermal
Plume Transport from Sand and Gravel Pits – Potential Thermal Impacts on Cool
Water Streams ” (Jeff M. Markle and Robert A. Schincariol, February 2007)
They say this in their abstract: “The
annual temperature amplitude in the pit is 10ºC above up gradient ground water,
and our results show that alternating warm and cool plumes persist in the
aquifer for 11 months and migrate up to 250 m down gradient.”
The
Also important to note is that the “terms of reference” of this study
was the thermal plumes only emanating from the pond and not the overall
increase in temperature created by the pit as it has been utilized for in this
report. The thermal plume study pit was already excavated and so it could not
have allowed for the overall increase of 10 degrees as it was only noted in
their abstract. The temperature readings for the creek used in the study were
already elevated from the effects of the pit itself.
The thermal plume study also said the following in their
recommendations: “This study
demonstrated that aggregate extraction can impact stream temperatures if
sufficient separation distances are not provided, and that these temperature
changes may adversely affect the macroinvertebrate
community and incumbent brook trout populations.
The cumulative effects of several operations within the watershed are still
unknown. Quantifying these effects will require a highly integrated study so
that we may understand the ground water – surface water interaction within the
watershed and the links to the ecology in the context of the stream
environment.”
They themselves are calling for more intensive studies and cumulative impacts studies as well.
None of these recommendations have been followed. There appears not to be any
studies that verify these results. Considering the number of aggregate
extractions in wetland areas, and the ease of monitoring temperature, there is
absolutely no acceptable excuse to not have carried out this “intensive” study.
A cumulative impact study has been requested for quite some time from
many different groups. The opportunity to have this completed by now was there
so the lack of this study is the fault of the industry. Until this issue is
addressed and the actual effects of an aggregate extraction are studied, no new
pits should be approved.
In the
According to “Thermal Plume Transport from Sand and Gravel Pits –
Potential Thermal Impacts on Cool Water Streams ” (Jeff M. Markle
and Robert A. Schincariol, February 2007), thermal plumes extend 250 meters however
120 meters was used. The explanation is based on an “assumed” travel time
of .2m/day. Many assumptions are made to create this calculation and it should
be noted that this data was based on 1 study.
The
According to a publication released by the Canadian Environmental Law
Association – Aggregate Extraction in Ontario: A Strategy for the Future: “In the case of aggregate operations that
extend below the water table, a number of negative hydrological impacts may
occur. During the process of dredging an aggregate pit, gravel that is removed
may be replaced with groundwater and precipitation, and evaporation from
on-site ponds can occur at a faster rate than would occur from the natural land
surface. Levelling out of the groundwater table in
the pit pond can also cause alteration of groundwater flow patterns in
surrounding areas.”
“Lowering of the water table during aggregate extraction may drain
surrounding wetlands that are fed by groundwater discharge.”
Why is it that these hydrogeological studies
have never been re-evaluated after the projects were completed and used to
verify the integrity of their data and predictions? Considering the weight
these studies have been given, you would think that the science that backs them
would be solid however there is no science and the company will not back their
own predictions. Witnesses state that wetlands
are frequently destroyed however this information is ignored. The
verification and feedback system that is used to perfect any science or process
is completely missing. The predictions in the study are therefore invalid.
Until the science has been proven and backed by those presenting it, it should
all be inadmissible to support the case.
“Closed loop
washing system”
“Closed loop” suggests that the wash system is somehow not connected to
the environment however this is far from the truth. The wash ponds are just
holes in the aquifer and the settling ponds are also just big holes. There is
no prevention of the wash water, or any contaminants released through the
washing process, re-entering the environment from many access points including
ponds and stacks of washed materials.
The water loss of 3% due to “industry experience” sounds like a guess.
“Virtual water trade” estimates the actual water loss for many products however
I have been unable to locate any studies on aggregates. Please provide this
data or it must be considered a “guess”. There is no room for guessing in
science and should not be presented as science. I have seen no calculations for
water loss due to water atomization for example. 3%?
A dust mitigation plan includes the application of water to haul routes.
How much water will this use? Will there be any chemicals added to the water?
Will this water be allowed to drain back into the aquifer? Has this been shown
in the water loss calculations?
Last year’s drought showed us that the Provincial government has no
interest in protecting our quantity of water. This can be verified in the
Environmental Commissioner’s report. The GRCA has the science that shows that
the drought conditions will only get worse. They predict a battle over water.
Please consider the “State Of
The
As well, it is said that these lake will increase the volume of water
that an aquifer can hold. That also means that they will displace a lot of
water and potentially lower the water table. Lowering the aquifer will effect the ability of the wetlands to be fed by the aquifer
and reduce baseflow.
This past year, Whiteman’s Creek was already at dangerously low levels
and since these 2 water features feed Whiteman’s Creek, reducing this flow will
directly affect not only Whiteman’s
Creek, but the Grand River
itself. Considering the lack of precipitation this “winter”, we are in for a
far worse summer this year. This should be considered. Since there is over 100
years of licenced extraction already (Gravelwatch) there is no need to proceed in a rush.
Rehabilitated
Conditions Water Balance
There has not been 1 pit rehabilitated by an aggregate company in
The citizens of Brant rehabilitated the Lefarge
pit on
Perhaps a large security deposit on the land should be considered??
This property grows 3 crops of vegetables per year. This is highly productive farmland that should be
protected.
Considering the remaining farmland, if there is found to be a chemical
change in the water, what would the effects be on the crops down-gradient of
the pit? What does increases in iron and manganese do
to a crop? Will the county suddenly need to instal
iron and manganese filters 10-20 years later due to iron and manganese
increases at a cost of 10′s of millions?
A WHPA is less than 1 KM from this pit although there was not any
mention of this in the study. Considering the changes that can occur to
groundwater as a result of an aggregate operation, there should be assurances
that this well will not be affected ANY time in the future. One potential
change is an increase in iron and manganese that seems to occur in post
extraction areas. This would require the installation of a costly filtration
system that will be directly traceable back to the pit by the time it happens.
Policy will also be that the company pays for these costs by the time that
rolls around considering this official notice that that will be policy in the
near future.
Air Quality
study
Silica dust is known to be created in sand and gravel operations. You
cannot deny it. Silica dust is a known
carcinogen and cause of silicosis. This report does not mention any of
this. Nearby residents will be subjected to this dust for at least 10 years. A
study of the health of people living around an aggregate extraction to
determine if there are higher levels of lung diseases should be carried out and
used as proof before any consideration of opening this pit.
According to witnesses – people who live near pits now – they have to
keep their windows closed 24/7 and their houses still fill with dust. One
witness stated that they have to clean their TV screen every other day or they
cannot see the picture. This is not a normal level of dust considering most
people do not have to clean their screens.
The new Brant Business Park
is located North-east of the pit. The very direction of
prevailing winds. The taxpayers have invested over $7 million into this
property and business that build there are investing much more. These companies
will be faced with severe dust issues. BGI uses expensive printing equipment
and high dust levels will cause many issues that will impair their operation.
According to another witness, the dust does travel this far. All of these
workers that populate these businesses will be subjected to increased levels of
silica dust exposure for 8+ hours a day. The study neglects to address these
issues.
This is advertised on the company’s information site:
What are the benefits to our community?
- Increased tax revenues paid directly to the
- St.Marys is also required to pay a fee per tonne extracted to the Ontario Aggregate Resources
Corporation (TOARC). TOARC works on behalf of the Ministry of Natural Resources
and a portion of the TOARC fees are directed to source municipalities.
The truth is, property taxes for a gravel pit are lower and the industry
has even launched an action with MPAC all across
The industry has admitted that the tonnage fee is inadequate to cover
the municipal cost at the
These statements should not be allowed. The statements are deceiving and
untrue.
The Traffic Impact Study concludes it’s executive summary (the only part
90% of the people ever read) by demanding that the taxpayer spend 100′s
of thousands to build infrastructure to support the
So then is assumed to be covered by the taxpayer as demanded by Grant?
It may not fall under the
This report lays out plans to upgrade the roads for the benefit of the
operation and does not include any data on road damage caused by the trucks. It
also does not consider school bus routes or anything regarding safety, noise or
any community related concerns.
The report also heavily suggests the need for a new ramp at the 403
& Bishopsgate. Considering that the need will be
driven by aggregate, this should be paid by the aggregate companies to support
their infrastructure. It is very curious to see that the people who write these
studies seem to be pushing to justify the need for even more development at the
expense of the taxpayer and the benefit of themselves and the industry that
they serve.
The County taxpayers already have enough of a tax burden and the ability
for these corporations to freely dip into our pockets, even when we cannot
afford it, has to stop now. There resources should benefit the people of the
community, not enslave us to millions in debt to cover the costs associated to
these operations. The 11 cent per tonne (probably
rounded to 10 with the elimination of the penny) fee is immoral and should be
$4-5 per tonne. This issue has to be resolved.
The public forums held by these companies are a complete waste of time.
The companies tout them as a huge success despite the fact that the majority of
community participants on these committees also lead the opposition groups.
They never provide any proof to satisfy the community and there is absolutely
no accountability for the actions or statements by these companies. If you say
“trust the science” in the public then you better have that science that you
are referring to. Accountability needs to be addressed.
I call to suspend all new licence applications until all of these issues
are addressed.
These issues seriously need to be addressed. If the “experts” cannot (or
will not) do it, I can put together protocols for scientific methodologies that
would answer these questions. These same questions are being repeated by groups
all over the province. Lets put the science together
and find out the truth. It is the truth we are looking for is it not?
A Concerned Citizen Of Brant
* Notice that the above information has been
gathered through private amateur research for the purpose of allowing the
reader to make an informed and educated decision. However, while the information is believed to
be reliable, accuracy cannot be guaranteed.
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