MP Frank Valeriote’s Letter

July 25th, 2011


June 30, 2011

Mr. Craig Laing

Aggregate Inspector, Ministry of Natural Resources

Regional Operations Division

Southern Region

Midhurst District

2284 Nursery Road

Midhurst, ON L0L 1X0

Dear Mr. Laing

Re: Proposed Aggregate Quarry-Township of Melancthon Township

I am writing to you as a result of grave expressions of concern by many constituents in Guelph respecting the proposed development by 3191574 Nova Scotia Company hereafter known as the “Highland Companies” of an aggregate quarry in Melancthon Township. The proposed development has been the subject of considerable debate and discussion among the residents of Guelph. Upon reviewing the proposal, letters addressed to me from people inside and outside of my riding, various reports and documents and listening to innumerable concerned residents in my riding, I share their apprehension and alarm.

Included among the many reports and documents I have read are:

1) Correspondence from Carl Slater, Manager, Technical Support Section, MOE, West Central region dated April 26, 2011 addressed to you

2) Memorandum dated April 15, 2011 from Vincent Bulman, Hydrogeologist, Water Resource Unit, MOE addressed to Barbara Slattery

3) Correspondence from John Werring, of the David Suzuki foundation dated April 29, 2011 addressed to you

4) A Committee Report from the City of Guelph to the Planning and Building, Engineering and Environment Committee dated June 20, 2011

5) A submission from North Dufferin Agricultural and Community Task Force

6) Correspondence from Fred Natolochny, Resources Planning Grand River Conservation Authority dated April 26, 2011 together with attached memorandum addressed to you

7) Various correspondence including that from Norah Chaloner, Dr. Karen Balcom and Bill Hill, Mayor of the Township of Melancthon

Briefly stated and in my respectful opinion the analysis and/or the observations outlined in the aforementioned documents create such a compelling case against the granting of a licence to the Highland Companies that it would seem almost a foregone conclusion that the Highland Companies application would be soundly rejected in either its current or any other form.

Having said that, I believe it worthwhile to highlight for you only some (but by no means all) of the observations expressed in the aforementioned documents which in many cases are shared by the authors of the documents.

The opinions and conclusions found in two separate Ministry of the Environment submissions describe multiple deficiencies of the Highland Companies application and include the inadequate description of drill cores, discrepancies between the text and the observations/data, conclusions made in the text of the Highland’s application not supported by either data or citations and the absence of convincing proof for the integrity of the ground water recharge system. In the absence of proper analysis by the Highland Companies, the Grand River Conservation Authority (GRCA) response indicated that “as impacts could extend upgradient without mitigation, impacts to ground water could extend into the Grand River Watershed”.

The memorandum from the GRCA sets out that “the quarry must be dewatered at a rate possibly exceeding 600,000,000 litres a day perpetually, which would seem challenging”.

As noted by Dr. Balcom this is equivalent to one quarter of the drinking water used by the Ontarians each day with no independent studies “of how this water might be contaminated by exposure to the blasting and mining process or of the long and short term effects of this massive draining and refilling of the aquifer”. As well, while the applicant refers to a similar system in operation at the Milton quarry in a setting similar to the proposed Melancthon quarry the GRCA found no such similar quarry. Instead they found only a proposal for a Milton quarry expansion which, if GRCA’s observation is correct, places Highland Companies comparison both disconcerting and misleading to say the least.

Among its many observations the GRCA also draws attention to the fact that Highland Companies conceptual evaluation of the ground water management system is “highly simplified” given that existing conditions would otherwise demand a management system that would be “exceptionally complex, extremely costly and challenging”.

The David Suzuki Foundation expressed deep concern about the proposed quarry opining that “the technical report and the impact assessment are rudimentary” and incomplete in its assessment of the impact on fish habitats and species at risk. The Foundation also challenges conclusions made by Highland Companies respecting the development’s impact on natural heritage systems, ground water and surface water features as well as the impact on wild life habitat associated with the changing agricultural landscape.

While the committee report from the City of Guelph notes that the proposed quarry falls “outside of the Speed River subwater shed” and notwithstanding that Guelph’s water supply aquifer is separated from the quarry by several subwater sheds it does note that the proposed quarry impacts the “Amabel” rock formation which is the same rock formation, extending from the Bruce Peninsula in the north to the Niagara Peninsula in the south, that Guelph uses for its water supply aquifer. The Committee therefore strongly supports the need for thorough reviews by regulatory agencies “to ensure that adverse impacts on Municipal water supply systems and on the environment are eliminated or minimized”.

Proper emphasis has also been placed through various submissions on the negative impact of traffic projected to be 3600 into trucks and 3600 trucks out of the proposed site each day, the generation of noise and dust and the degradation of agricultural land adjacent to the project of significant importance, but a consequence often overlooked. Both Norah Chaloner and the North Dufferin Agricultural and Community Task Force rightly pointed out, the generation of harmful greenhouse gases from both the trucks and, the enormous amount of energy used for the constant dewatering of the quarry. Compelling are the letters written by the Township of Melancthon on behalf of the Township residents who are overwhelmingly opposed to the project and its negative impact on farm land and the aquifers in and around the site, including the Guelph-Amabel Aquifer.

The enormity of the project alone which is described by Dr. Balcom as unprecedented, almost intuitively allows one to conclude that the quarry will have a degrading impact on our ground water supply, environment, natural habitat, agricultural land and the very way of life for those in and around Melancthon Township.

I therefore sincerely hope that you will recognize the significance and weight of the opinions found in the reports submitted to you and deny the issuance of a licence to Highland Companies for the development of the aggregate quarry in Melancthon Township.

I thank you in advance for your consideration of this matter and welcome any questions or comments that you may have.


Frank Valeriote

Member of Parliament


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