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11. Insufficient information has been provided to evaluate the impacts of dust and other emissions on local residents, tourists, and heritage sites, and the conclusions drawn about the classification of the site are questionable. Under Ontario Regulation 346, sources are required to limit their emissions of suspended particulate matter within certain standards. However, the report contains no estimates of total particulate matter produced by the mining operation or haul route. Moreover, claims that the proposed pit should be considered as a Class II industrial facility according to the MOE D-6 guidelines seem inappropriate given the proposed pit includes the large physical size, outside storage of products, large production volumes, continuous movement of products and high probability of fugitive emissions described as characteristic of a Class III facility. Therefore, the minimum setback distances from guideline D-6 of 300 m from homes and the Grand River, and 1 km setback from the West Montrose covered bridge should be required.
12. The information regarding the impact on a large wetland is incomplete, and the conclusions based on provided information are questionable. It is likely this pit will violate Section 2.5.2.2 of the Provincial Policy Statement 2005. A reassessment of the wetland boundaries and peer review of the potential impact on this wetland is required. This review needs to include information about the magnitude and water source of the permit to take water request, the combined the effects of groundwater changes, below groundwater extraction, surface flow changes during the extraction phase and the dust and silt associated with extreme proximity of the wetland to both the edge of extraction and the 2 constructed ponds (10 m according to the published GRCA map of the wetland). In addition, justification for violating the GRCA policy requiring a 120 m setback from wetlands greater than 2 hectares (Ontario Regulation 150/06) needs to be provided and reviewed.
13. Contrary claims, the pit will have a significant detrimental visual impact during its operation. In addition, insufficient information regarding the visual impact has been provided. The proposed pit will be visible and in the foreground from the Grand River, a Canadian heritage river adjacent to the site, and from various road vistas that include the covered bridge. In addition, there is no information regarding the lighting of the site, but it is assumed that a large lighting system is proposed that will destroy the landscape character of this area at night, creating an unacceptable social impact contrary to Provincial Planning Policy 2005. Finally the visual impact assessment makes no mention of the fact that most of the shielding vegetation is deciduous and therefore site extraction will be on full view to tourists and residences for at least 7 months of the year.
14. The hydrological report included in the application to MNR is incomplete. The hydrological report did not include a well inventory. As a result at least 56% of the wells within 300m of the north side of the subject lands (those on Rivers Edge Drive) were omitted from the report. The majority of these are shallow dug wells susceptible to impact, and within very close proximity to the extraction zones. Therefore is seems unlikely that the proposed pit will be consistent with Provincial Policy Statement 2005, section 2.5.2.2
15. The proposal fails to adequately address the harmful airborne particulate matter which will be created. Residents and visitors will be exposed to airborne dust and particulate matter (including but not limited to Airborne Silica – a designated substance under the Occupational Health and Safety Act and subject to rigorous engineering controls) created by the pit’s activities. Capital Paving’s proposal does not address the exposure which will occur to residents and other people.
16. The proposal does not address the detrimental impact on three major trails that traverse the area. These trails are well used and documented. The Trans Canada Trail and Kissing Bridge Trail are in close proximity to the proposed pit, less than 100 meters away at some points. The Grand Valley Trail runs south through a bush on the edge of the proposed Gravel Pit, then runs approximately 300 meters along the north edge of the proposed pit, then south through the proposed pit for approximately 400 meters. Operation of a pit in this area would negatively impact use and enjoyment of these trails, and would have an adverse impact on tourism in the area.
17. The proposal does not address economic impacts of a pit in this unique tourist area. A major “draw” of West Montrose is the beauty and tranquility of the area. The noise, traffic, visual intrusion and pollution caused by a large gravel pit will change this dramatically. The economic impact for the area is significant. Market values of West Montrose homes may drop significantly. The tourist experience will be diminished, resulting in reduced visits and revenues for the Township, Region and local businesses, including the West Montrose Family Campground, Olde Bridge Place Bed & Breakfast Inn, Lost Acres Variety Store and other farm retail operations. These businesses will lose significant revenues as the tranquil, relaxing environment sought by many people will be gone. Economic impacts will be exacerbated by the excavation of Letson Drive, which will restrict horse and buggy traffic to and from retail businesses.
18. The report does not address the economic impact on tours of the Covered Bridge area. Most tours now include travel along Jigs Hollow Road, where views will be adversely impacted. They also include travel to the covered bridge, then south on Letson to the Mennonite woodworking shop and meeting house, and along Letson to the Mennonite school house and Mennonite shops along Katherine Street. The appeal of these tours will be adversely impacted by the presence of a gravel pit and overhead conveyor.
19. The proposal does not address the close proximity to the West Montrose Family Campground and associated noise impacts. This campground is home for numerous full season and weekend campers who travel from all over to enjoy the tranquility and unique characteristics of the area. Specifically, the noise levels have been adequately addressed for people who are residing in trailers and tents with little or no sound insulation.
20. Capital’s proposal does not address the cultural heritage aspects of the West Montrose Area - tranquil beauty entwined with the observable Old order Mennonite Culture and Ontario's only remaining covered bridge. The area has been identified as a prime candidate for Cultural Heritage Landscape designation by the Waterloo Region Public Advisory Committee. Dr. Robert Shipley, Head of the University of Waterloo Heritage Resources Centre intends to make a report and recommendation on the proposal for such designation. The physical boundaries of the designated area are yet to be determined, but could well include all or part of the licensed area. It would be imprudent to approve a license for a pit before this designation is finalized.
