Valley Voices Letter to Alnwick/Haldimand Township Council:
July 01, 2003
To: All Council Members
Re: Shelter Valley Aggregates, Ltd. Proposal for Zoning By-law Amendment
We are writing on behalf of the Valley Voices to express our concerns regarding the recent application for re-zoning of Part Lots 5 and 6, Concession 3 to Extractive Industrial (M3) from Rural (RU).
Valley Voices is a rapidly growing citizen's group, which currently represents over 80 property owners in the Shelter Valley area. We believe that there are serious errors, omissions and oversights in this application for re-zoning, and that it is not in compliance with either the Township of Haldimand Official Plan or the Aggregate Resources Act. We strongly urge Alnwick-Haldimand Township to reject this proposal for re-zoning, as well as the proposal for a site-specific exception related to Rural and Environmental Control zones.
Our specific concerns relate to several different aspects of the proposal, as follows:
Environmental Impact: The proposed gravel pit will have a significant negative impact on the local environment, due to increased noise and vibration due to large trucks (possibly in excess of 30 tonnes) and stationary equipment operation, and dust produced during aggregate extraction. In addition, the proposed pit, may result in disturbances to a previously closed hazardous waste disposal area (the exact location of which is unclear), and will require the development of an intrusive roadway through an Environmental Control area, associated with a Cold Creek tributary.
Hydrogeology: Even though the proposed extraction will not proceed below the water table, it is nonetheless very likely to interfere with local wells and ponds. Disturbance of the overlying gravel may allow contaminants (such as dust suppressant, fuel and oil) to enter the local groundwater. In addition, large amounts of water will likely be removed from the aquifer; aggregate facilities of this size may use hundreds of thousands of litres of water per day at peak capacity, to wash gravel and suppress dust. The site plan contains contradictory statements in this regard: at one point stating that water would be the primary dust suppressant, yet later claiming that no water taking will be required at the site. Any water extraction would be inconsistent with a water bottling operation proposed for the vicinity; it is not clear that these two potential demands for water taking have been taken into account.
Economic Impact: The proposed aggregate operation has a tremendous potential for negative economic impact on the township. The economic impact will be most severe on local agricultural operations, which will suffer from dust (which can be disastrous on produce crops) and changes to the water table (which could dry up local irrigation ponds and wells. Shelter Valley Road also supports several small businesses (such as artist's studios, a camp ground and a golf course), all of which will suffer from the increased heavy truck traffic and disturbance of the ambience of the valley. Common sense dictates that the property values of numerous nearby residences and building lots will be significantly reduced, it is also likely that the construction of new residences along Shelter Valley Road will be curtailed (as will the renovation and improvement of existing homes). The tranquil rural environment currently makes Shelter Valley Road an attractive location for home construction on large lots. In addition, the region in question benefits from close proximity to the Oak Ridges Morain, making it almost certainly a prime area for future residential development. If Alnwick-Haldimand township approves this request it will send a strong message directly in contrast to promotional material, which states that "... The Oak Ridges Moraine Conservation Plan gives protection from many of the less desirable aspects of rural life. It is almost like living in a Provincial Park."
Scenic Beauty and Amenities: The operation of an aggregate facility on this site will result in dramatic and irrevocable changes that will destroy the scenic beauty of this area. Shelter Valley Road has become the location of choice for several new residences, due mainly to the tranquil environment and magnificent views of rolling hills. THe introduction of raised berms around the extraction site will create an eyesore that will nonetheless be ineffective in screening the pit from view of surrounding residences at higher elevations (210-230 m); the proposal is seriously flawed in this regard by not taking the steep terrain into account. In addition, the proposed extraction will essentially remove a 20 m high hill, which is the highest terrain in the immediate area (230 m); surely it will not be possible to hide this fact with a 4 m berm.
Noise: The noise estimates associated with the proposal are flawed due to the fact that they begin with the assumption that the "surrounding area is essentially flat or gently rolling terrain." The fact is that aggregate removal will take place at relatively high elevations on steep terrain on the flank of a valley and the extraction operation. if allowed to continue to completion, will remove a 20 m (65 ft) high hill. The noise associated with equipment operation will propagate in a direct line to nearby residences; no berm is likely to abate this noise. In addition, it appears that the proposed setbacks may be inconsistent with the Official Plan. The proposed operating hours of 6 am to 7 pm (Monday to Saturday)would create a severe inconvenience for many local residents, many of whom have retired to this area, drawn by the quiet surroundings. Truck traffic associated with the operation will propagate and echo through the valley; there is no indication that the specific terrain has been taken into account in the noise study.
Traffic and Roads: There are several complex considerations with respect to traffic and roads. It is unclear what the maximum number of truck pass-bys per day could be at peak operating capacity, but it is likely to be as high as 500. Since these trucks will weigh between 20 and 35 tonnes, extensive and expensive damage is likely to result to local roads. Aside from the costly damage, there are safety issues related to this tremendous increase to heavy truck traffic in the area. Vehicular traffic along this road includes children on bicycles, school buses, slow moving farm vehicles, ATV's, snowmobiles, and tourist traffic; is it reasonable to expect to add hundreds of trucks per day to Shelter Valley Road and not see a significant increase in serious traffic accidents? It is also unclear what routes trucks may take to and from the pit. Although the proposal suggests that most trucks will travel east on Shelter Valley Road, we have no assurance that they will not travel west (if the delivery site makes this the shortest route) and thereby inconvenience residents along the entire length of Shelter Valley Road. Trucks that do travel east will meet Percy Street at the bottom of a steep hill, creating potential safety problems with heavily loaded trucks.
Rehabilitation: Given that the proposed pit operation has the potential to destroy the natural beauty of a section of the valley, it is extremely important that residents of Alnwick-Haldimand Township be given a detailed description of the rehabilitation plans for the area. At the outset, it is difficult to imagine what this rehabilitation would entail, since the aggregate extraction would essentially remove a 20 metre hill, using techniques similar to strip mining. Since the applicants state that they are under no obligation to return the land to agricultural use, there is no guarantee that they would not simply "walk away" from the site at some point in the future. The proposal gives no indication of the maximum lifetime of the operation (although it is likely to be 10-20 years), so it is impossible to tell when the land would be completely rehabilitated. There is no indication of any previous successful attempts by Shelter Valley Aggregates to rehabilitate aggregate extraction sites.
Land uses contrary to Official Plan: A portion of the proposed gravel pit site (12%) is designated either Rural of Closed Waste Disposal, and may therefore require an amendment to the Official Plan; it is not clear that this can be dealt with by a re-zoning request. The proposal also makes mention that "the applicant wishes to apply for an exception provision to the Rural and Environmental Control zones north of the site which will permit the use of land for the location and operation of a private aggregate haul route". We believe this request for a site-specific exception should be reviewed concurrently with the exisiting application.
We urge Council to scrutinize this proposal carefully, given the history of the recent re-zoning applications by the property owner. The Township was asked to consider a re-zoning application for this same property within the past year, at which time a portion of the proposed extraction operation was severed and re-zoned RU-346, for proposed rural uses, including residential. This re-zoning request stated that the subject land was vacant, but "... will have a single family dwelling erected in the future". Area residents were informed of this request and allowed it to proceed; re-zoning was passed on August 14, 2002. It is now abundantly clear that plans for aggregate extraction were well underway at that time, making the proposal for rural residential re-zoning disingenuous, if not deliberately misleading. The severed and re-zoned parcel now constitutes Section A of the proposed gravel pit. Given this history, it would be wise for all parties to consider the facts of this proposal carefully, and not take any information at face value.
Summary: We believe that there are specific technical errors in this proposal that should result in its rejection by Council. In addition, we believe that approval of this re-zoning request would not be consistent with the long term goal of attracting increased rural residential development in Alnwick-Haldimand.
This decision will irrevocably alter the character of Shelter Valley Road, which is arguably the heart of the Township.
Due to the significance of the re-zoning request, we also request a delay of at least 90 days before a decision is made, in order for all parties to obtain additional information. In this regard, we urge Council to request peer review of the reports provided by the proponent, using the services of independant consultants, so that Council may make an informed decision.
On behalf of Valley Voices citizens group,
Mark Towers, Bob Mitro,
Co-chair, Scenic Beauty and Rehabilitation Co-chair, Noise, Traffic and Safety
Henricus Jansen, Jim Bissonnette,
Co-chair, Economic Impact Co-chair, Environmental
cc: Doug Galt, M.P.P., Paul Macklin, M.P., Mayor Bill Finley
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