Ministry of Natural Resources & Forestry
Ms. Calinda Manning, Aggregate Specialist
Integrated Aggregate Operations Section Ministry of Natural Resources and Forestry
300 Water Street, 4th Floor, South tower 
Peterborough, ON K9J 3C7 Canada
ARAapprovals@ontario.ca

Nelson Aggregate Co.  
2433 No. 2 Sideroad 
Burlington, ON L7P 0G8 Canada

Dec 14, 2020

Re. Nelson Aggregate Quarry Application, Mount Nemo
EBR No. 019-2698

Dear Ministry of Natural Resources representatives,

We understand that Nelson Aggregate and its parent company Lafarge are seeking permission to rezone land for two new quarries (South and West) on top of Mount Nemo, in Burlington, Ontario. We understand that the proponent is looking to extract rock in areas that are Significant Woodlands, Class 1 Agricultural farmland, Endangered Species habitat (bats and birds), and we also note that the proposed South extraction area abuts spring-fed Provincially Significant wetlands and provincially protected endangered species habitat (Jefferson salamander).

We very much oppose this new application. It is inappropriately sited and poor planning, especially in this age of climate crisis and biodiversity loss. This proposal puts well water, significant habitat and protected areas at risk. It would destroy habitats by changing water regimes and negatively affect the form and functions of protected ecosystems. It outright removes Species at Risk habitat and our best farmland.

Halton Region maps show that the South quarry proposal extraction area is completely ringed by Key Features within the Greenbelt and Halton Regional Natural Heritage System. This proposed extraction area is a small hole encircled by these forests, wetlands, tributaries and ponds. These are high quality, biologically rich Provincially Significant Wetlands, Habitat of an Endangered Species, and Significant Woodlands. This area is a Highly Vulnerable Aquifer (HVA) area.  It is located behind our home and farm. We have been here for 50 years. We share a property line with the proponent, and we also share forests and wetland habitats that overlap both of our properties. We are both stewards of Class 1 Prime Agricultural land.

Grasslands, forests and hedgerow corridors provide for a myriad of wildlife here, including significant amounts of Bobolink, sparrow and interior bird species. The Grindstone Creek Provincially Significant Wetland complex, which overlaps both of our properties, is a collection of 15+ wetlands, some which are spring fed and some of which are headwater tributaries of the Mount Nemo and Grindstone Creek. Protected Jefferson Salamander habitat covers much of this area. This is the “birthplace” of the Grindstone Creek, which flows through Waterdown (Smokey Hollows Falls) and on to Lake Ontario at the Royal Botanical Gardens in Burlington. We haven’t used any chemical sprays on our farm in over 30 years on our perennial mixed native hay crop. We are proud to be stewards of such headwaters and incredible biodiversity.  

The top of Mount Nemo is 400 million year old Karst limestone that has been worn into channels, caves and springs for millennia. As mentioned, it is mapped a Highly Vulnerable Aquifer (HVA) area.  This fractured landscape, shaped by seeps and sinkholes and old growth forest characteristics, reinforces the interconnectedness and hydro-conductivity here, and the porous layers of the living world.

In this landscape ecosystems are interconnected and sensitive to change. They are interrelated through groundwater and through soils and substrate.  

The West quarry proposal is in an area whose forests are also mapped as a ‘Key Features’ area with the Greenbelt and Halton Region Natural Heritage System. The proponent seeks to remove a huge area of greenspace, Significant Woodlands, wetlands and prime soils. It also wants to remove colonies of an Endangered Species of bat and habitat of the Eastern Pee-Wee, barn and tree swallow and other at-risk bird species.  Though it has been used as a golf course for the past number of decades, this land was previously farmland in the best agricultural zone in the country. In the West quarry site the proponent is also seeking permission to kill 25,000 young trees, planted by the MNRF and Conservation Authority as a managed forest, with tax incentives and a contractual obligation with the owner of at least 15-year tree stewardship. Any reference to environmental stewardship put forward by this proponent must be regarded in the light of the destruction they propose.

With their last application to the Ministry in 2006 Nelson Aggregate’s field surveys were significantly deficient. The company neglected to study adjacent southern properties within 120m of the proposed quarry, though a mandated study area, and they missed key features, which locals had to eventually point out to authorities. Nelson did not document a number of species, most importantly the Jefferson Salamander, an at-risk species now considered Endangered by the Province of Ontario. (It was listed as “Threatened” only 10 years ago). Other crucial indicators of wetland significance were also missed, and the company, therefore, expressed a considerably different picture to government agencies of what was on the ground in the proposed quarry area. Later, in 2006, during the quarry application review period the company was found by Conservation Halton to have dredged and drained wetlands and illegally placed fill. They also were found to have relocated Butternut trees out of the wetlands. This is what the company did while the environmental characteristics of the site were being reviewed by the MNRF, NEC, and the Joint Agency Review Team. The dredging and culvert installation resulted in a subsequent siltation event that suffocated salamander egg masses downstream and caused salamander mortality.

Due to a lack of trust, credibility and transparency. For reasons of a delayed and prolonged progressive rehabilitation of their existing quarry. For the amount of imported and untested fill the company has shipped into its quarry below the water table every working day for years. For unacceptable levels of dust affecting our neighbour’s respiratory health and a lack of transparency with data sharing. For frequently exceeding legal noise and vibration levels during blasting, and for a track record that includes dredging and moving Endangered trees while wetlands were under review. For ignoring or supressing information on Species At Risk. For the cumulative effects of a quarry already operating for 70 years and hollowing out the aquifer and very foundation of Mount Nemo. For the risks to Lake Medad and the Lake Medad ANSI. For the cultural significance of the archaeological discovery of an Attawandaron longhouse and artefacts on the proposed South quarry site. For the grave potential risks of active quarrying and seismic vibrations next to numerous active pipelines. For extra stress, cracking and corrosion of old pipes pumping diesel, diluted bitumen and poisonous chemicals at high pressure. For well water problems that have occurred for years around the existing quarry on # 2 Side Road, and beyond. And for the preciousness of drinking water prioritized above all else.

For these and other reasons, we believe our regulators at the Provincial level must find the siting of this proposal inappropriate and reject this application.

We look forward to participating in this review process.



Sincerely,


Sarah Harmer, Alan Harmer and Isabelle Harmer
On behalf the Harmer family

Burlington, On