Thursday, May 21, 2020


First of all I have decided to postpone further comment about well OW-14 d,i.s that was discussed here yesterday.

In Tuesday's Waterloo Region Record there was an article titled "Wilmot mining aggregate below water table". In today's Record was a Letter To The Editor from Norm Cheesman, executive director Ontario Stone, Sand and Gravel Association (SSGA). I think it is pretty clear that the SSGA are a lobby group for aggregate producers and have a large vested interest in the maintenance of the status quo. In other words they are making money and lots of it and that is their first and foremost reason to be in existence as well as to lobby for fewer restrictions, rules and enforcement of their industry all of which cost them money. Notice I am not opposed to their right to lobby as it is quite understandable.

The first Record article discusses Wilmot Township's both recent and past experiences with below the water table extraction of sand and gravel. The Township's gravel pit at the corner of Queen and Huron St. has been operating below the water table since 2010, extracting 3,000 to 5,000 tonnes of gravel each year. While the area is a significant groundwater recharge zone allegedly it is far enough away from municipal drinking water supply wells to not negatively impact them. Interestingly there was no mention of neighbours, their private wells, and or any issues dealing with noise, dust, visual impacts, or truck traffic. Those issues combined with the damaging of high quality farm soils from topsoil removal are all part of the usual opposition to gravel pits. I haven't been out to view the area but at first blush at least may assume that its' location is better than many other pits in Waterloo Region.

The second article is the Letter To The Editor. Again there is virtually no mention of the often controversial issues of noise, dust, traffic, visual impacts and destruction of high quality farmland. The focus is entirely on the alleged lack of groundwater impacts caused by gravel pits. In my opinion Mr. Cheesman is gilding the lily. He boldly claims that "Thousands of pits and quarries have been operating in the province for hundreds of years with no demonstrable significant adverse effects to water." Oh boy! His statements previous to this one claim that quarries and pits that operate below the water table are required by law to mitigate impacts to wells, streams and wetlands. He is essentially bragging that every single aggregate company in Ontario, ever, has operated perfectly with zero spills of gasoline or diesel when refueling trucks and loaders and furthermore no grease, oil or fuel has ever leaked from equipment on site. He is also indirectly stating that no aggregate company has ever used their gravel pits for illegal waste disposal in order to fill them up (i.e. "rehabilitation"). Finally he is suggesting indirectly that our enforcement whether by the Ontario MECP (Environment) or the Ministry of Natural Resources (MNR) is adequate or satisfactory.

In regards to Mr. Cheesman's bold claim about no damage in Ontario, ever, from anyone, let me simply say this. Horse feathers! Do you sir have perfect knowledge going back hundreds of years? Do you have every MNR or MECP Occurrence Report, complaint or inspection notice going back hundreds of years? Have you personally spoken to every long term nearby resident of every gravel pit in the province who knew the state of nearby surface water, streams and creeks prior to the existence of their local gravel pit? I think not! You sir are committing puffery of the most blatant kind.

Regarding his indirect only suggestion that enforcement by either the MECP or MNR is adequate or satisfactory, he must have asked those two bodies for their opinions on that matter. I personally have spent thirty years dealing with the Ontario MOE/MECP both concerning Elmira ground and surface water as well as numerous other issues throughout Waterloo Region. On a good day I will think that that body are underfunded, incompetent and negligent. On a bad day my opinions of them, based upon their actions and decisions, are even worse.

Regarding illegal waste disposal in gravel pits let me simply say that I have seen and photographed foundry wastes including papers, office wastes and phenolic resins being dumped in a local former gravel pit near Elmira. I reported it and little or nothing was done to my knowledge. Illegal use of gravel pits for waste disposal has been going on for just as long as illegal toxic waste disposal has occurred in municipal landfills throughout Waterloo Region and likely throughout the province.

Mr. Cheesman your claims are absurd however I do admit that surface and ground water testing downgradient of gravel pits is and always has been inadequate to non-existent which may buttress your claim of " demonstrable significant adverse effects to water." That said a lack of testing and a lack of data does not imply or prove no adverse effects.

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