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Howe-Gastmeier-Chapnik Limited
sent to Trow Associates
December 23, 2003
Reference: Peer Review of "The Potential Impact of Noise From Aggregate Extraction and Processing at the Proposed Shelter Valley Pit, Part of Lot 5 and 6, Concession III, Township of Alnwick/Haldimand, County of Northumberland" dated February 25, 2003, Prepared by Aercoustics Engineering Limited. As requested, we have reviewed the above referenced report. Our review is also based on information gained during a tour of the site and surrounding area on November 12, 2003, discussion with representatives of the Township, Shelter Valley Aggregates and Valley Voices during that tour and information contained in the A.R.A. License Application and Planning Report and Pit Plans dated January 03, 2003 prepared by MacNaughton Hermsen Britton Clarkson Planning Limited. The Aercoustics report has been conducted using the appropriate Ministry of the Environment (MOE) Guidelines and criteria. The report identifies that excessive levels of noise will be caused by operations in the pit and identifies means of mitigation to allow the appropriate limits to be met. We are concerned that due to the complicated topography of the site and other factors the proposed mitigation may be insufficient or difficult to implement in practice. Since many neighbouring receptors are located in a rural valley, background sound levles are likely to be quite low and residual noise emissions may be of concern. Additional analysis is required concerning the noise impact of trucks on the haul routes. These issues are more fully explained in the following comments.1.
The two residences (R1 and R11) closest to the northern boundary of the pit have been omitted from the analysis since they are owned and occupied by the pit owners. In our experience, the MNR and MOE may not accept this omission and these residences should be included in analysis. Owners and occupants can change. The feasibility of providing sufficient mitigation should be investigated and shown to be feasible before a license is issued. There may be a means through property and legal agreements and zoning restrictions for the operator to install the mitigation for those residences if it is acceptable to all parties, but that is not known at this time.2.
The pit site is located on a hill. It was apparent during the site visit that if extraction proceeds from the north thowards the south as shown on the plans, operations on the pit floor would be clearly visible from residences located at higher elevation to the north of Shelter Valley Road. In this way, the proposed pit is different from many others in Ontario. Perimeter berming, which is generally a primary and permanent noise control feature would be ineffective in providing visual or accoustic shielding for those residences.3.
The Hanley residence is representative of this situation. it would be useful to also include the Hanley residence in the analysis.4.
Aercoustics has assigned a source level of 88 dBA at a distance of 30 m to the aggregate processing (crushing and screening) plant. In our experience this is a realistic sound level. It should be noted that under the Occupational Health and Safety Act, equipment operators should be provided with hearing protective devices if they will be working in the vicinity of this equipment for any length of time.5.
These source levels are such that the noise from this equipment could exceed MOE criteria at receptors up to several km away if sufficient accoustical shielding is not provided.6.
The mitigation plan therefore involves shielding the processing plant from all residential receptors with high (up to 12m) stockpiles or topographical features. it also indicated that the processing equipment is to be located no more than 30 m from the top of the shielding barrier in all sensitive directions for the barrier to provide sufficient shielding. It is not clear from either report or the pit plans how the simultaneous shielding of this equipment from a number of residences in different directions can be reliably accomplished. The impossibility of providing effective berming along the north limit of extraction complicates this situation.7.
Even with sufficient shielding to achieve the MOE Guideline limits at neighbouring receptors, it is likely that the processing equipment will be occassionally audible because of the low levels of background sound in the area. This is particularly the case at receptors to the east and north, which would be downwind under prevailing conditions. This report should address the issue of residual audibility to provide direction to both the pit operator and the Municipality in terms of how to address the complaints which could result.
8.
Similarly, the report provides no discussion of the sound from the backup beepers associated with the trucks and loaders operating at the site. Back up beepers are designed to be as audible as possible. Since they are considered to be safety devices, they are exempt from assessment. Nonetheless, they are often a source of community complaints.9.
Aercoustics has identified that the potential for shipping truck noise impact should be recognized and used as a criterion when selecting external haul routes. We concour, and recommend that a detailed analysis of the noise impact of trucking operations be undertaken. Such an analysis should identify the potentially impacted receptors, determine the existing traffic sound levels at those receptors and the amount by which sound levels are expected to increase due to haul trucks.10.
While it is not common practice to provide mitigation for individual residences with regard to haul trucks oerating on public roads, the degree of impact should be understood, and all possible alternatives investigated before approvals are given.11.
Aercoustics has calculated the receptor sound levels and berm heights based on a point of reception 1.5 m above the ground, typical of a person standing in their yard or sitting on a patio. The MOE identifies not just useable outdoor space, but also the plane of any window as a point of reception. Not including upstairs windows as a point of reception may arguably be appropriate for daytime operation, but processing and loading are proposed to occur as early as 6 a.m. Berm heights should be increased substantially to protect upstairs windwos, which are typically at an elevation of 4.5 m above the ground.12.
The report does not recommend any means of verifying the compliance of the facility with MOE sound level limits during operational phases, such as conducting regularly scheduled accoustical audits.13.
A statement should be provided indicating that a Certificate of Approval may be required for the aggregate processing plant. Generally, mobile aggregate processing equipment is exempt from requiring a C of A if it is operating below grade in a licensed pit. In this case since the pit is located on a hill, the pit floor (202 masl) is higher than the ground elevation at the north limit of extraction (197 masl) and the exemption may not apply. Obtaining a Certificate of Approval would provide the operator with a means of exhibiting compliance with MOE Guidelines.In summary, the report refers to the appropriate MOE assessment guidelines and criteria and attempts to demonstrate that with sufficient accoustical mitigation the criteria can be met. In our opinion, the report does not describe that mitigation in sufficient detail to demonstrate that the proposed operations will fully comply with MOE limits on an ongoing basis. The most potentially impacted receptor is omitted from the analysis. The receiver height is questionable, possibly leading to an underestimate of the noise impacts and the need for higher berms. The need to address the noise produced by offsite trucks is mentioned but significant additional analysis is required.
We suggest that Aercoustics provide clarification and additional information related to these issues.
We understand that the proponent is to provide a traffic impact assessment for the haul route in the near future and suggest that it address noise issues as well as those issues normally addressed. Howe Gastemier Chapnik Limited.
