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Ontario Nature,
355 Lesmill Road,
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M3B 2W8Phone: (416) 444-8419
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Mayor William Finley and Council
Township of Alnwick-Haldimand Municipal Office,
10836 County Rd. 2
P.O. Box 70
Grafton, ON
K0K 2G0April 5, 2005
Dear Mayor Finley and Members of Council:
Re: Proposed Shelter Valley Aggregate Pit
Ontario Nature is concerned that the application by Shelter Valley Aggregates Ltd. (SVA) to establish an aggregate pit at Lot 5-6, Concession 3, in the Township of Alnwick-Haldimand, Northumberland County, will cause serious environmental damage to the area.
Ontario Nature protects and restores nature through research, education and conservation action. Founded in 1931, Ontario Nature champions woodlands, wetlands and wildlife, and preserves essential habitat through its own system of nature reserves. Ontario Nature is a charitable organization representing over 25,000 members and 140 member groups across the province, connecting individuals and communities to nature.
We recognize that demand for aggregates is growing in Ontario. However, Ontario Nature’s position is that this demand must be moderated across the province- through aggregate conservation, aggregate recycling and other demand management techniques- if we are to protect what remains of our natural areas. Ontario Nature advocates the design of ‘smarter’ communities that reduce our dependency on aggregates through firm urban boundaries to curb sprawl and to promote more compact urban form, as well as more and better public transit that means less dependence on the automobile usage that fuels construction of ever more aggregate-consuming roads and highways. (For more information on our smart communities work, please visit Ontario Nature’s website at www.ontarionature.org , ‘Provincial Issues’, ‘Southern Ontario Greenway Strategy’ and ‘Urban Sprawl/Smart Growth’).
The establishment and operation of the proposed Shelter Valley aggregate pit would have numerous aesthetic, economic, safety and environmental impacts on the area. Many of these impacts have already been identified to your Council by local residents and independent consultants. Based on reports from the Valley Voices Residents Association and Niblett Environmental Associates Inc.’s January 2004 Environmental Review, Ontario Nature is concerned that SVA’s proposal to extract up to 500 000 tonnes/year from the site will lead to:
-groundwater contamination and drawdown of local aquifers
-disturbance of an adjacent hazardous waste disposal site (containing DDT among other toxic waste)
-disturbance of fish habitat
-forest destruction and loss of ecological connectivity between significant natural areas
-up to 50% reduction in species diversity of area-sensitive birds and regionally significant plants.
Furthermore, although SVA propose to extract aggregate from 23 hectares of the total 29-hectare site, the company is planning to rehabilitate only five hectares at an unspecified time in the future. This will result in a net loss of forested habitat in the area, and significant fragmentation of any forest that remains.
The Provincial Policy Statement (PPS) under the Planning Act provides for development and site alteration within significant wildlife habitat if it can be demonstrated that no negative impacts will result (Section 2.1.4 of the PPS). Given the potential environmental effects of the proposed pit outlined above, it appears that the SVA proposal is not consistent with the PPS. In addition, it is particularly important to note that, while Section 2.5 of the PPS on Mineral Aggregate Resources contains several policies regarding extraction of aggregates, all the policies of the PPS must be taken into consideration when evaluating an aggregate application. This requirement is noted in clause 4.3 of Section 4- Implementation and Interpretation: “This Provincial Policy Statement shall be read in its entirety and all relevant policies are to be applied to each situation.” Therefore, it is incumbent upon your Council to give close consideration to the Natural Heritage policies of Section 2.1 in addition to all other policies of the PPS and strike an appropriate balance among these policies in your decision-making.
Ontario Nature urges your Council to reject a zoning by-law amendment permitting aggregate extraction on the Shelter Valley site. Unless SVA is able to significantly mitigate environmental damage to this important natural area, Ontario Nature takes the position that SVA should not be permitted to proceed with its application for the Shelter Valley Aggregate Pit.
We look forward to your response on this important matter.
Thank you.
Yours sincerely,
Linda Pim
A/ Director,
Conservation and Sciencecc: Valley Voices Residents Association
County of Northumberland
Lou Rinaldi, MPP Northumberland
Paul Macklin, MP Northumberland
