Halton Region October 21, 2009 PPWC Meeting Nelson Aggregate - - PDF document

1

Halton Region

October 21, 2009 PPWC Meeting Nelson Aggregate License Application

Thank you Mr. Chair and Committee Members My name is Roger Goulet; I’m the Executive Director of PERL PERL – Protecting Escarpment Rural Land, is a not-for-profit, incorporated, volunteer citizen’s organization based in Burlington. Protecting Escarpment Rural Land (“PERL”) has worked for years with the public, and public agencies to protect Halton’s Niagara Escarpment, the environment and promote sustainability. More specifically, helping to develop the science needed for making the right decision on the Nelson Aggregate new quarry license application. We represent the community in the cause of retiring the 57 year old (started in1952) Nelson Aggregate Burlington quarry on the Niagara Escarpment, before it does any more environmental and societal damage. PERL made a number of submissions and presentations to the JART – Joint Agency Review Team. PERL supports the conclusions of the JART report. We support the Conservation Halton staff; the Halton Regional staff; and the City of Burlington staff; all are recommending ‘DENIAL’ on the Nelson Aggregate application. Further, we commend the Conservation Halton Board for “unanimously” voting to recommend ‘DENIAL’ on the Nelson Aggregate application. The many JART technical experts and its peer reviewers thoroughly studied the Nelson Aggregate reports and data over the last 5 years. JART found very serious problems with this complex and incomplete application, as did Conservation Halton staff; Halton Regional staff; and City of Burlington staff. The science is in…the Mount Nemo plateau is the wrong place for another quarry. This Nelson Aggregate new quarry application can not be allowed to go forward. In the past 120 years, there have been at least 3 quarries on Mount Nemo - 4 if you include the old Kerncliff

• quarry. (Current Nelson/King, old Mt. Nemo, Millar Crescent, Kerncliff)

The Mount Nemo plateau has given all it can give. Another open-pit mine at its heart risks an ecological collapse. It is at its ecological tipping point. The City of Burlington, before the Joint Board, raised a Motion outlining some of the areas where the Nelson Aggregate application is incomplete. PERL, along with the Halton Region, Conservation Halton, Niagara Escarpment Commission, Lake Ontario Waterkeeper and the Coalition on the Niagara Escarpment, all support the Burlington Motion. There are 8 Parties, 12 Participants, and 6 Presenters at the Joint Board, all opposing the Nelson Aggregate application. When Nelson Aggregate decided to prematurely trigger the ARA process in May 2006, thus by-passing the local governments and agencies, --- the community sent in hundreds of objection letters.

2

The Nelson Aggregate proposal is in conflict with the Halton Region’s Strategic Plan, Theme # 2 on ‘Protect and Enhance our Natural Environment’ – Goals 1 thru 6 The Nelson Aggregate proposal is in direct conflict with the Ontario Provincial Policy Statement and provincial standards on the protection of significant wetlands, woodlands, tributaries, source water, and species at risk. If the Nelson Aggregate license is granted, the rehabilitation of the existing 57 year old quarry will again be

• delayed. Despite a requirement for ‘progressive rehabilitation’, Nelson Aggregate has only rehabilitated 44%
• f the existing quarry in last half century of operations. That’s Unacceptable!

Furthermore, it will be decades, year 2072, before the proposed lakes fill with water, if they fill at all;… fully 120 years since opening the quarry. This is a permanent use, not an “interim use”. This type of abuse must stop! The existing quarry must be closed within the next few years, at the end of its projected reserves, and fully rehabilitated as required by law. The dewatering of the Mount Nemo aquifer resulting from quarry operations currently accounts for an estimated 40% of the available water taken (permit to take water) from this important source water area. One single company…Nelson Aggregate, is by far the largest water user on the Mount Nemo plateau; yet they propose to discharge even more of this precious, ancient, life-giving water; …to be lost forever. This threatens the whole watershed, a prime headwater area…our wells, our wetlands, dozens of streams and tributaries, and our woodlands and our wildlife. Consider if you would the effects on…Bronte Creek, Grindstone Creek, Tuck, Shoreacres, Appleby, Mount Nemo, Willoughby and Lowville Creek Systems, and a dozen others; --- and even Lake Medad would be negatively impacted. PERL’s hydrogeology experts have carefully reviewed the Nelson Aggregate studies and reports, and have found ‘major’ problems and discrepancies with the proponent’s proposal…namely:

• 1. The potential for major groundwater decline; and impact on wetlands and wells
• 2. Potential major groundwater reduction to the Medad Valley, an Environmentally Significant Area
• 3. Inadequate water budget analysis
• 4. Inadequate groundwater flow monitoring
• 5. Inadequate study and characterization of Karst features
• 6. Major discrepancies between earlier and recent reports and testing concerning soil conductivity and

wetland protection

The proposed “well water guarantees” do not cover the currently affected wells, having been impacted by the dewatering of the existing quarry over the last half century, which has caused documented cases of…drying

• f wells, and contamination of drinking water.

The contingency (in AMP) use of a Groundwater Recharge Injection System (GRS) is not proven technology, nor proven safe from potential groundwater contamination. The draft Adaptive Management Plan is not enforceable as is, because it is not an integral part of the Nelson Aggregate Site Plan; it is simply a separate draft document. Limestone mineral deposits are amongst the most abundant material on the earth, having formed hundreds of millions of years ago as sediment at the bottom of seas. There are less environmentally sensitive locations, alternatives materials (mining tailings, slag, glass, tires), and technologies (light weight concrete), which would result in far less environmental costs and negative impact. There are 27 active pit and quarry licenses within the Region of Halton, generating an estimated 11 million tonnes of mineral aggregates per year, that’s approx. 330,000 full truck loads; extracted from 2000 hectares

• f land area.

Much of the production from Halton Region quarries is sent to the GTA. Halton has more supply than it needs.

3

The aggregate industry advocates “close-to-market” sources. Therefore, the GTA should get its aggregate supplies from quarries closer to the point of use. (Possibly from mining under Lake Ontario) Abundance begets waste… Scarcity sparks innovation. Why then isn’t the aggregate industry developing less destructive alternatives? The simple reason is, because limestone is inexpensive; supply has been readily available; there are no incentives to develop alternatives; and the aggregate companies do not have to pay an ecological premium for exploiting this non-renewable resource from environmentally sensitive areas;…society pays dearly however. Why aren’t governments, the largest aggregate users, not doing more to reduce usage… by limiting urban sprawl; by intensification of our communities; by changing construction codes and standards; by mandating the use of recycled building materials or substitute materials, as have other governments around the world? Why do we misuse ‘virgin’ high quality limestone for back-filling basements, garages and weeping tiles? Ontario uses 15 mt of aggregates per capita, the US 9.1 mt per capita, and the UK 4.8 mt per capita. Why aren’t governments specifying the source of aggregates from lesser ecologically sensitive areas? When will governments adopt a world-class Green Gravel standard for government projects? (Reduce, Reuse, Recycle, mining waste, underground mining) The existing Nelson Aggregate quarry in Burlington recycles 40,000 tons per year of “waste” (really source resources) construction materials and asphalt, according to them. When compared to their 2 million tons of annual production, that is only 2%... a drop in a bucket. The UK recycles 24%; Holland, Belgium and Denmark recycles 90% of all demolition materials. Many other industries use recycled content in their supply stream, ranging from 10%, 25%, 50%, even 100%. When will the aggregate and shale industries commit to reusing and recycling all the concrete, cement block, asphalt and brick construction wastes generated from construction projects? When will the aggregate industry increase the use of alternative materials, such as mine tailings, slag, glass, and tires… instead of relying on virgin limestone from the Niagara Escarpment or other environmentally sensitive areas? The ‘close-to-market’ argument made by quarry operators on the Niagara Escarpment is misleading. It does not square with the negative environmental impact of heavy trucks having to climb up the Niagara Escarpment, half as high as the 553 meter CN Tower (295m vs. 625m). Hauling heavy loads uphill generates more noxious emissions and greenhouse gases, and consumes more fuel. One could haul from significantly greater distances to obtain mineral aggregates, yet result in the same emissions and fuel cost. (Heavy gravel trucks loaded with materials for recycle or rehabilitation fill; gigantic rock movers from the proposed quarry to the old quarry for processing) The only prudent and ecologically sustainable course of action for our governments is to DENY the Nelson Aggregate license application. Please put the environment first. Become leaders in ecological Sustainability. Give the residents on Mount Nemo and the Village of Lowville their “quality of life” back, after over a century

• f disruptive and destructive open pit mining.

Join with the Halton community and dozens of environmental groups in creating more ecologically sustainable alternative uses for this pearl we call the Mount Nemo plateau. Together we will invent a sustainable future for this area. We need people with vision and a determination to create something good for our grandchildren and their grandchildren. Imagine a place in harmony with its environment and its society, a place the envy of others. Thank you