Noise & Environmental Concerns
CRAA’S RESPONSE TO THE OFFICE OF THE AUDITOR GENERAL ASSESSMENT OF THE AGGREGATE RESOURCES ACT AND ITS MANAGEMENT
To Ministry of Natural Resources (MNR)
THE PROPONENT is seeking authorization for processing, loading, and shipping operations at the the Proponent’s Pit (Part Lot 20, Concession 3, 13945 Telephone Rd., Cramahe Township) on a 24-hour basis when required. Approval of this application would pave the way for the Proponent to establish an asphalt plant on-site.
The ultimate goal of this application is to enable the construction and operation of an asphalt plant at this location.
Compliance Concerns
A December 2023 Auditor General’s Audit found that the Ministry lacks effective systems and processes to ensure compliance with the Aggregate Resources Act, related regulations, and policies. The report highlighted:
High non-compliance rates within the aggregate industry, with minimal enforcement and few charges pursued.
Lack of oversight on self-reporting, leaving the Ministry unable to verify whether pit and quarry operators adhere to their operating conditions, rehabilitate sites as required, or report non-compliance accurately.
Considerations for 24-Hour Operation Approval
Before granting approval for continuous operation, key assessments should be mandatory, including:
Traffic & Infrastructure Impact
Compliance with Township Traffic Control By-laws.
Designated haulage routes for heavy truck movements.
Potential need for road use agreements.
Environmental Impact
Required studies on air quality, water resources, and local ecosystems.
Permit to Take Water (PTTW) for usage exceeding 50,000+ liters/day.
Noise & Light Pollution Mitigation
24/7 operations require enhanced assessments for noise and light pollution.
Municipal approvals must account for continuous operation impacts.
Public & Stakeholder Engagement
Community Consultation may be required for zoning changes or environmental approvals.
Indigenous Consultation may be necessary depending on the project location.
Lack of Transparency
At two separate meetings, the Proponent was asked to provide information on traffic impact, noise levels, and procedural compliance. The applicant refused to provide any details, instead stating that the site is zoned for Aggregate Extraction, which permits an asphalt plant. No further information was given or offered.
This lack of transparency raises serious concerns about how the applicant intends to operate. It suggests a pattern of behavior that seeks to exploit regulatory gaps within the aggregate industry, potentially leading to a non-compliant operation with little oversight or accountability.
Call to Action
Given these circumstances, we strongly urge the Ministry of Natural Resources (MNR) to deny this application. The applicant’s engagement with the Township Council and community demonstrates a disregard for due process and responsible operation.
Approval under these conditions would set a dangerous precedent, allowing non-compliant industrial activities with significant environmental and community impacts.
We request that the MNR uphold public interest, environmental responsibility, and regulatory integrity by rejecting this application.
Read the Auditor General’s report here
REPORTS NOT PROVIDED:
ACOUSTIC ASSESSMENT REPORT
The Subject property is in a Rural Residential neighbourhood and because of the proximity to this large settlement area the CRAA believes that a full Acoustic Assessment Report is necessary and should be provided by the Proponent.
Who is responsible and liable for the loss of enjoyment of one’s personal property due to unending noise and disruption?
WATER SAFETY
Given the Rural Residential nature of this neighbourhood and the proximity to the large settlement area known as Little Lake the CRAA believes that a full Environmental assessment is necessary of the Biddy Creek Conservation area.
In Ontario and therefor Colborne, Wellhead Protection areas (WHPAS) are zones around a well that are protected to ensure groundwater quality for the residents on Town Water.
Well owners are responsible for maintaining their own wells to prevent contamination.
The investment that each resident has made into drilling wells and maintaining them must be acknowledged by Council and protected just as their Urban counterparts.
Should this proposal be approved, who then is liable for the costs associated with contaminated wells, a contaminated lake and a contaminated watershed?
