CRAA submits LEGAL ANALYSIS to STOP the Asphalt Plant!
The Cramahe Resident Advocate Association (The“CRAA”), has hired legal representation in the community’s campaign against a proposed Asphalt Plant to be located in Cramahe Township on the south side of Telephone Road and flanked by Dunk Road.
Gowling WLG is one of Canada’s foremost national law firms. Its Toronto office is a national leader in the law and policy relating to aggregates extraction, asphalt manufacture, and related environmental and planning issues. The analysis by Gowling WLGC submitted to the Ministry of the Environment, Conservation and Parks by CRAA, responds to a proposal that was submitted to that Ministry.
It was submitted June 19 th , 2025, with a comment period for residents and stakeholders to submit their observations, concerns and remarks. The proposal is by Fidelity Property Group Inc. (“Fidelity”) for an Environmental Compliance Approval (Air) (“ECA”) to establish and operate a permanent hot mix asphalt plant at Lot 20, Concession 3, in the Township of Cramahe in Northumberland County, Ontario.
Proposal details (as posted on the ERO site)
This proposal is for an ECA with Limited Operational Flexibility (air) if Approved this would replace current Environmental Compliance Approvals for Air at this facility and includes the addition of new and historically unapproved sources for all emissions from Fidelity, operating a permanent hot mix asphalt plant including raw materials, grades of aggregate and recycled asphalt pavement. The emission sources from the manufacturing and associated processes that discharge to the air include liquid asphalt cement tanks, baghouse exhausts and hot oil heaters, and crushers. Emissions to the air from these sources at the proposed facility include:
Arsenic
Benzene
Benzo(a)pyrene
Carbon monoxide
Crystalline silica
Lead
Naphthalene.
Read the full Legal submission presented to the ERO, the Township and the proponents of the Asphalt Plant.