Based on the information provided in Nelson's application regarding the impacts on the natural environment, we note the following concerns:
The report claims that there are no “significant” impacts to local species and local ecosystems associated with the two new pits. But the elimination of the natural environment species, including species at risk, associated with open-pit mining is not insignificant: rather it is an industrial practice with enormous and disruptive impacts on living ecosystems. No "rehabilitation" or enhancement" plan layered over a depleted limestone pit can replace the complex, rich, biodiversity of the prime farmland and natural ecosystems that currently thrive in the areas now being considered for permanent destruction from mining. Any disruption, including man-made “enhancements” will lead to a net environmental loss and it must not be represented as otherwise.
The community was not consulted about the rehabilitation and enhancement proposals for both Nelson Aggregate’s existing and proposed quarry sites—most notably for the alteration, dredging and grading of the regulated and protected Jefferson Salamander habitats. These sensitive areas must remain off-limits. Nelson Aggregate's proposal to “enhance” the endangered Jefferson Salamander in Provincially regulated and Joint Board ruled habitats, causes very serious concerns about the safety and prosperity of this species.
The field surveys were done throughout a very short-period of time, which renders the data unreliable. These surveys underestimate the amount of species that are present in the study area, do not identify/list many fauna and flora species that are known to live in the area, and do not fully explore all the impacts that open-pit mining will have on these diverse and complex ecosystems. For instance, the removal of natural areas that have been classified as breeding grounds for some bat and bird species during the “off-season” will have significant negative impacts on the breeding patterns of these species in the subsequent season. Despite this logical outcome, the report claims that the proposed mining operation will have no impact on the natural breeding patterns.
The removal, manipulation, or disruption of the designated natural habitats for Jefferson Salamander must not be permitted. The report provides no studies or evaluations to prove how the proposed off-site "ecological enhancement" plan will serve as a viable replacement for the rich and complex ecosystem that many species, including threatened and endangered species, like the Jefferson Salamanders and Butternut trees currently inhabit, and which is essential to their survival. In the past, Nelson Aggregate has moved endangered Butternut trees for their convenience. Allowing Nelson Aggregate to continue disrupting the natural environment with or without permission is of significant concerns to a number of citizens and organizations.
The removal of Halton NHS designated wetlands, watercourses, woodlands are unacceptable; and the impacts on the Grindstone Creek Headwaters Complex Provincially Significant Wetlands are also unacceptable.