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1. The reports do not address the unique nature of this site, given the close proximity to the covered bridge (a national historic site), potential impacts on tourism, designation of the area as a Cultural Heritage Landscape, and the proximity to several historic residences. The proposal attempts to inappropriately apply standard principles to a non-standard situation.
2 .There has been inadequate consultation with the Old Order Mennonites, a valuable part of our community and heritage. Many travel Letson Drive on a regular basis. An aggregate operation that cuts through this road will disrupt their way of life. Provisions must be made to shut down the conveyor as horse and buggies approach.
3. Capital states they have done sound and dust studies to ensure the neighbourhood will stay within legal limits for these types of pollution. The reports do not address how these tests will conducted to simulate real life operations, and to ensure hypothetical results will apply in reality. Thorough sound and dust studies throughout the community are required.
4. There has been inadequate notification of key stakeholders, including tourism offices, tour operators and residents throughout the river valley, who will incur abnormal sound impacts because of the unique acoustics of the valley.
5. The proposal violates Section 5.3.6 of the Regional Municipality of Waterloo Official Plan. Contrary to the statements of Capital Paving, the proposed extractive areas site plan lies within the regulation limit established by the Grand River Conservation Authority.
6. The requested variance to reduce the required setback of the aggregate extraction zone to 4 meters will greatly damage tree root systems and result in tree death. Tree death in the proposed buffer zone may expose residents and tourists to noise and dust levels that exceed MOE regulations and will negatively impact this locally significant woodland.
7. The information regarding natural heritage resources is incomplete. The wildlife survey does not include large-bodied and conspicuous species known to occupy the subject lands, such as wild turkeys and turkey vultures, and those species on adjacent lands that are connected by streamflow to the subject lands, such as snapping turtles, river otters and minks. It is impossible to determine the projected impact of this project on natural heritage resources, as required by the ARA and Section 2.1.6 of the Provincial Planning Policy 2005, when the natural resources have not received a reasonable inventory.
8. The claim that the pit will have no impact on significant freshwater species and fish habitat is unsubstantiated. There is no information provided regarding the effects of flood events. Capital Paving requested below water table extraction and large ponds immediately adjacent to the 100 year flood line and inside the GRCA floodplain regulation limit. This report does not include a plan to mitigate catastrophic effects on fish habitat associated with the flooding of an industrial processing site. For this reason, the proposal may be in violation of the Fisheries Act.
9. The proposal will violate both the Provincial Planning Act 2005, and the Cleanwater Act. Capital Paving is requesting the placement of aggregate washers, grinders and other processing equipment immediately adjacent to the 100 year flood line and inside the GRCA floodplain regulation limit. Some municipal water sources utilize Grand River waters downstream of the proposed site. Staff to run this equipment must be provided with sanitary facilities, and fuel and lubricants will be required to run this machinery. No plan of where sanitary facilities will be situated and where the wastes will be disposed of is provided. No plan for containment of these substances in flood conditions is provided.
10. We object to the proposal to extract aggregate, stockpile materials, create large processing ponds and place grinders, washers, fuel storage and other equipment within the Grand River Conservation Authority regulation limit. Development within this zone is strictly regulated in order to prevent the creation of new flooding hazards or the aggravation of existing ones (Ontario Regulation 150/06). Altering the slope and elevation, placing large equipment, and stockpiling materials within this region will alter flooding regimes both in the immediate area and downstream. In addition, fuel storage in the area may pollute downstream areas in a flooding event and so will not be consistent with Provincial Policy Statement 2005, section 2.5.2.2.
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