March 6, 2019
To SLCO Members
Re: Continuation of Objection Letters - Proposed Lippa Pit and Quarry
This is a follow-up letter on the topic of Objector Letters. In my communication of February 13, I informed members that if they continue to have objections to the Lippa Quarry application and are not satisfied by the information in the package from John Ewart (lawyer for the Lippa family), they are required to provide a second letter to keep their Objector status, either by personal delivery, by registered mail or by e-mail.
If you have submitted an objection letter in the past, we urge you to take a few minutes to re-submit and update your letter of objection. This second letter needs to be delivered to both the Applicant and the MRNF by Friday March 8, 2019, which makes e-mail the preferred method of communication. Note that an e-mailed objection that does not contain a valid postal address (i.e. a street address, not a PO Box) will not be considered acceptable.
A number of people reported having difficulty retrieving these reports from the Skelton Brumwell site (Lippa’s engineering firm), including our experts. Two requests to Lippa’s lawyer to extend the deadline have gone unanswered.
We instructed our experts to prepare submissions to the Ministry of Natural Resources and Forests (‘MNRF’) to respond to the updated technical reports submitted by Lippa’s consultants. According to our experts, here are just a few of the deficiencies in the reports:
Water Quality
1. It has not been demonstrated Skeleton Lake, an ultra-oligotrophic (or ultra-clean) body of water, will be protected. This is a bottom line for residents. 2. Lippa’s consultant disagrees with Ministry of the Environment Conservation and Parks (formerly the MOECC) conclusion that Skeleton Lake has a high phosphorus sensitivity. This is contrary to the findings of our very highly regarded water experts. 3. Proposed mitigation measures such as diffusing discharge of phosphorus and implementing new Stormwater Best Management Practices are not clearly defined, and no comments or approval is indicated from MOCF. 4. The technologies proposed to treat the phosphorus laden effluent water are designed to trap fine suspended particulate and reduce phosphorus suspended in water. There is no assurance this will have any significant effect on phosphorus entering the lake. 5. Dissolved phosphorus is a primary concern for Skeleton Lake because the rock Lippa proposes to blast and crush is high in phosphorus.
1. It has not been demonstrated Skeleton Lake, an ultra-oligotrophic (or ultra-clean) body of water, will be protected. This is a bottom line for residents.
2. Lippa’s consultant disagrees with Ministry of the Environment Conservation and Parks (formerly the MOECC) conclusion that Skeleton Lake has a high phosphorus sensitivity. This is contrary to the findings of our very highly regarded water experts.
3. Proposed mitigation measures such as diffusing discharge of phosphorus and implementing new Stormwater Best Management Practices are not clearly defined, and no comments or approval is indicated from MOCF.
4. The technologies proposed to treat the phosphorus laden effluent water are designed to trap fine suspended particulate and reduce phosphorus suspended in water. There is no assurance this will have any significant effect on phosphorus entering the lake.
5. Dissolved phosphorus is a primary concern for Skeleton Lake because the rock Lippa proposes to blast and crush is high in phosphorus.
Noise Impacts
1. Noise impacts are a still a significant concern. In fact, along Butler Mill Road, they will be enormous (22dB) increase in noise over the status quo on the lake. That’s like sitting in your living room with a quiet dishwasher running (40-45 dB) vs. having someone turn on the television in your living room so loud you can’t carry on a conversation (60-65 dB). 2. Our expert predicts the noise will be so disruptive, our quiet community will be downgraded from an acceptable noise impact area from a quiet rural rating Class 3, to a Class 2 or 1 area, equal to an urban or suburban noise zone. This would be like moving from a very quiet Skeleton Lake (Class 1) to a street near a busy intersection e.g. Leslie and Finch Ave., Toronto. 3. The updated acoustical report lacks basic information which makes it difficult assess the impacts. 4. The mapping is not clear enough to identify all of the affected neighbours. 5. Missing factors along the haul route such as gradients (hills) in the road leading to the quarry means that the quarry is potentially 5dB louder than predicted. There is a very high potential that people are going to be woken from their sleep! 6. No analysis is presented whether or not the haul route selected is the route that most minimizes noise impacts for residents and the environment. 7. The hours of operation mean it is likely loud trucks will begin at 5:45 am, with trucks sitting outside the quarry gate idling.
1. Noise impacts are a still a significant concern. In fact, along Butler Mill Road, they will be enormous (22dB) increase in noise over the status quo on the lake. That’s like sitting in your living room with a quiet dishwasher running (40-45 dB) vs. having someone turn on the television in your living room so loud you can’t carry on a conversation (60-65 dB).
2. Our expert predicts the noise will be so disruptive, our quiet community will be downgraded from an acceptable noise impact area from a quiet rural rating Class 3, to a Class 2 or 1 area, equal to an urban or suburban noise zone. This would be like moving from a very quiet Skeleton Lake (Class 1) to a street near a busy intersection e.g. Leslie and Finch Ave., Toronto.
3. The updated acoustical report lacks basic information which makes it difficult assess the impacts.
4. The mapping is not clear enough to identify all of the affected neighbours.
5. Missing factors along the haul route such as gradients (hills) in the road leading to the quarry means that the quarry is potentially 5dB louder than predicted. There is a very high potential that people are going to be woken from their sleep!
6. No analysis is presented whether or not the haul route selected is the route that most minimizes noise impacts for residents and the environment.
7. The hours of operation mean it is likely loud trucks will begin at 5:45 am, with trucks sitting outside the quarry gate idling.
Traffic Safety
1. Based on a review by a qualified traffic safety engineer retained by SLCO, we are of the opinion that the safety of the haul route has not been fully assessed. 2. Specifically, school bus operations and truck traffic interactions have not been fully assessed, we can’t be sure our kids are safe. 3. Intersection, curve and hill sightlines have been identified as deficient (possibly unsafe) along the proposed haul route corridor but have not been addressed in terms of improvements to the road needed. 4. The proponent’s safety consultant concluded that the 80 km/h posted speed is not appropriate for the roadway geometrics and operations, which raises the clear question of whether 80 km/h is too fast to be safe for heavily loaded aggregate haulers. 5. In addition, the Lippa’s safety consultant concludes that there have been only two collisions along the haul route over a five-year period. According to our expert, this frequency seems extremely low for even the best performing rural roadway over a 5-year period. 6. The increase in collision potential due to slower moving trucks has not been quantitatively assessed and therefore it is unknown if it poses a risk, which is a legitimate concern for people sharing the road with these new trucks.
1. Based on a review by a qualified traffic safety engineer retained by SLCO, we are of the opinion that the safety of the haul route has not been fully assessed.
2. Specifically, school bus operations and truck traffic interactions have not been fully assessed, we can’t be sure our kids are safe.
3. Intersection, curve and hill sightlines have been identified as deficient (possibly unsafe) along the proposed haul route corridor but have not been addressed in terms of improvements to the road needed.
4. The proponent’s safety consultant concluded that the 80 km/h posted speed is not appropriate for the roadway geometrics and operations, which raises the clear question of whether 80 km/h is too fast to be safe for heavily loaded aggregate haulers.
5. In addition, the Lippa’s safety consultant concludes that there have been only two collisions along the haul route over a five-year period. According to our expert, this frequency seems extremely low for even the best performing rural roadway over a 5-year period.
6. The increase in collision potential due to slower moving trucks has not been quantitatively assessed and therefore it is unknown if it poses a risk, which is a legitimate concern for people sharing the road with these new trucks.
Land Use Planning
1. The Township and SLCO remain opposed to the application, including the aspect of crushing within 2km of a waterbody. If the Township and subsequently the LPAT prohibits the crushing, the operation changes significantly and all of the related reports would need to change. 2. We question if a pit in this remote location is viable if the raw aggregate must be shipped somewhere else for processing before being shipped to market. This is a lot of travel on our roads that may pose an unnecessary traffic safety risk. 3. Until this matter is resolved, it seems premature for any agency or impacted resident or First Nation to provide final comments on the application. 4. The Official Plan states:
1. The Township and SLCO remain opposed to the application, including the aspect of crushing within 2km of a waterbody. If the Township and subsequently the LPAT prohibits the crushing, the operation changes significantly and all of the related reports would need to change.
2. We question if a pit in this remote location is viable if the raw aggregate must be shipped somewhere else for processing before being shipped to market. This is a lot of travel on our roads that may pose an unnecessary traffic safety risk.
3. Until this matter is resolved, it seems premature for any agency or impacted resident or First Nation to provide final comments on the application.
4. The Official Plan states:
a. 14.7 The siting of an Aggregate Pit should be based on the following criteria, in addition to all requirements of the Aggregate Resources Act:
· Site is located on an arterial or major collector road capable of handling the increased traffic and haul loads; · Site is in close proximity to a provincial highway.
· Site is located on an arterial or major collector road capable of handling the increased traffic and haul loads;
· Site is in close proximity to a provincial highway.
5. In our opinion, the site meets neither of these criteria and these policies. These policies are intended to prevent the traffic safety issues that have been identified above.
You might find these points helpful as you draft your letter. In parallel, SLCO is preparing its own letter of objection, based on these points, which we will circulate to the SLCO membership as soon as it is available.
Sincerely,
Scott May
President - Skeleton Lake Cottagers Organization
e: scott@skeletonlake.ca
c: 416 559 2839
