From: Melancthon Against Quarries

To: Ministry of Natural Resources and Forestry, Strada Aggregates, Township of Melancthon

Date: November 3, 2025

About Us

Melancthon Against Quarries (“MAQ”) is a grass roots citizens group based in Melancthon Township and reaching outside to other communities and organizations.

We have worked for the past year to raise awareness about the dangers presented by Strada’s proposed below the water table Blast Quarry and to express the community’s strong opposition to it.  We have so far not met a single person who is in favour of this application.

In the past year, we have

• Held 4 well attended Town Halls to gather opinions on the Blast Quarry
• E-mailed 14 Melancthon Against Quarry newsletters to 729 subscribers, and counting.
• Distributed 220 lawn signs
• Collected 450 petition signatures at town halls, markets, and door-to-door efforts.
• Developed an interactive website that serves as an info hub that effectively supports the community in sending in Comments Letters
• Helped writers to submit 520 Comments Letters
• Built a Facebook group with 443 members, providing an interactive platform for sharing updates and gathering feedback
• Engaged our fellow citizens in innumerable individual conversations about the proposed Blast Quarry

In all these interactions over the last thirteen months, not a single person stated that the Blast Quarry is needed or wanted.

An Overview

People here have lived with gravel pits for generations.  They have been seen as part of rural life. However, blasting below the water table changes everything.  Strada’s below the water table Blast Quarry would be the first such operation in the whole of Dufferin County.  Proposed for construction at the headwaters of the three rivers that support life in Melancthon and surrounding communities, it is universally considered in our community to pose wholly unnecessary risks to our well being.

As reported by the Reform Gravel Mining Coalition (RGMC), in October 2024, the available data confirms that there is a 6.2 billion tonne reserve of aggregates in the GGH alone that can meet construction needs for the next 38 yearswithout adding any new pits or quarries or expanding existing ones.  The fact that Strada considers that it can make a profit by selling this aggregate somewhere does not prove that there is a need to do so.  Our immediate neighbourhood is well served by operations surrounding communities.  Strada’s below the water table Blast Quarry in Melancthon is wholly unnecessary, and we support RGMC’s call for a pauseon the approval of new pits and quarries.

We believe that the views we express in this Comments Letter are shared by just about every single person in Melancthon Township and the surrounding communities.  The comments in this letter are not a simple expression of opposition, but a detailed and evidence-based account of the multiple risks this project poses to our health, safety, environment, and local economy. At its core, this issue is about balancing private profit against the long-term sustainability of communities and ecosystems. We strongly believe that approval of this project would represent a failure of the Government of Ontario to uphold its mandate to protect Ontario’s natural resources and the wellbeing of its citizens.

In this document, we set out the reasons for our opposition in detail:

• the unacceptable risks of fly rock and blasting hazards;
• the proven dangers of air pollution from dust and particulate matter;
• the hydrogeological risks of blasting below the water table;
• the economic and social decline that would follow;
• the dangers to traffic and road safety;
• the failures of consultation and transparency; the deficiencies in legal and regulatory oversight;
• the severe threats to ecological and environmental integrity;
• the irreparable damage to Melancthon Township as a community;
• the unnecessary nature of the quarry development given the significant existing aggregate supply in Ontario;

Each section draws on credible sources, scientific evidence, and the lived experience of residents.

We conclude by calling on the Ministry to deny the application outright.

The conclusion in Melancthon and beyond is clear and unanimous: the below the water table Blast Quarry is not needed and not wanted. By any conceivable standard, the risks of this project are too great, the safeguards too uncertain, and the consequences too far-reaching to justify approval.

1. Public Safety Risks: Fly Rock and Blasting Hazards

Blasting activities associated with limestone extraction carry an inherent risk of fly rock. This phenomenon occurs when fragments of rock are propelled beyond the intended blast zone, often unpredictably. Documented incidents in Ontario and beyond confirm that fly rock has caused serious injuries, property destruction, and even fatalities.

The National Institute for Occupational Safety and Health (NIOSH) in the United States classifies fly rock as one of the most significant hazards in surface mining operations. In our context, where homes, farms, and community infrastructure lie within close proximity to the proposed quarry, the risk is unacceptable. The Ministry’s own guidance emphasizes that fly rock cannot be entirely prevented—only managed through best practices. Residents cannot be asked to live under permanent threat of life-altering accidents.

Beyond physical safety, the psychological toll of regular blasting is significant. Detonations shake homes, startle residents, and can cause structural cracks in buildings. The vibrations disrupt sleep, generate stress and anxiety, and erode the sense of security in one’s own home. For families raising children or caring for elderly relatives, this stress is compounded daily.

We do not accept that these risks can be mitigated by requiring Strada to install real-time monitoring systems, share all blast data with the public, and accept automatic penalties for any accidents or incidents.

Strada offers no assurance that there is zero fly rock risk to our community.  Strada offers no assurance that they have either intention or the fully-secured financial means to indemnify us against loss or damage from blasting.

2. Air Quality and Public Health Impacts

Airborne dust and fine particulate matter generated by quarrying operations present a chronic, invisible danger. Particulates less than 2.5 microns in diameter (PM2.5) penetrate deep into the lungs, cross into the bloodstream, and contribute to cardiovascular and respiratory disease. The World Health Organization has set global air quality guidelines, yet repeatedly emphasizes that there is no safe level of exposure to PM2.5 or PM10. The Canadian Environmental Protection Act (CEPA) recognizes the need to control airborne contaminants, but enforcement at the provincial level has been weak.

Dust generated by blasting, crushing, screening, and truck traffic will not remain confined to the quarry site. Experience from other aggregate operations shows that dust travels kilometres under prevailing winds, infiltrating homes, schools, and workplaces. Limestone dust, being alkaline, can also chemically alter soil and water, damaging crops and natural vegetation.

The health consequences are well established: increased rates of asthma in children, aggravation of chronic obstructive pulmonary disease (COPD), heightened risk of strokes and heart attacks, and even lung cancer. These impacts carry not only human costs but also financial costs to our healthcare system.

Once again, we do not accept that these environment and health impacts can be mitigated. Allowing Strada to proceed with development of the Blast Quarry ultimately shifts the burden of corporate activity onto families and taxpayers.

Strada offers no assurance there is zero air quality risk to our community and those around us. Strada offers no assurance that they have either intention or  the fully-secured financial means to indemnify us against loss and damage from carcinogenic dust and fly rock.

3. Water and Hydrogeological Concerns

Once the blasting starts, no one can predict with certainty what will happen to our water. To make matters worse, the risks to water will change with every explosion – several times per week for up to 50 years.

Melancthon sits at the headwaters of the Pine, Boyne and Grand rivers. This must be the worst imaginable site for blasting below the water table.  It risks damage to the supply and quality of water in Melancthon and in communities downstream from us, including Shelburne, Mulmur, Alliston, Angus, Collingwood and Wasaga Beach. Its effects could reach the Nottawasaga and Georgian Bay.

Hydrogeological studies show that blasting below the water table can fracture bedrock, alter natural aquifer systems and create artificial pathways for contamination, including heavy metals. Once groundwater is disrupted, the impacts are permanent and irreversible. The Strada proposal includes dewatering of up to 6.6 million litres per day—an astonishing figure that exceeds the daily consumption of many municipalities. Such extraction risks drying out wells, reducing water levels in streams and permanently altering hydrological balance. 

Surface water tributaries that support sensitive ecosystems, such as Brook Trout habitats, could face stream flow reductions of 30–50% during dry seasons, according to independent hydrogeological models. These ecosystems are already under stress from climate change and  further disruption would be catastrophic.

The offer to truck water to residents in the event of well failure is inadequate and insulting. Water trucking has a shameful history in Canada. In many situations, a practice that was intended to be a short-term, “band-aid” solution has become a permanent feature of community life.  Nothing in the application for the proposed Blast Quarry satisfies us that residents of Melancthon Township will not face a similar, long-term fate.

Strada has no prior experience with water management on this scale and should not be permitted to “learn on the job”.  Water is not simply a commodity that big business should be permitted to experiment with, and deliver to affected residents as a “courtesy” or an afterthought. It is a living system that underpins the survival of communities, farms, and ecosystems. We urge the Ministry to recognize that once groundwater integrity is compromised, it cannot be restored, and, therefore, the application should be rejected.

Strada offers no assurance that there will be no harm to our current plentiful supply of pure water. Strada offers no assurance that they have either the intention or the fully-secured financial means to indemnify us from loss or damage to our water supply.

4. Economic and Social Consequences

The economic impacts of the Blast Quarry would be wide-ranging and overwhelmingly negative. Real estate values are already affected, with local agents reporting that buyers are reluctant to move into Melancthon because of the proposed quarry. A shrinking population undermines local businesses, from restaurants and shops to contractors and service providers. Agriculture, which depends on both local labour and stable land values, will be harmed as workers move away and property values decline. Municipal tax revenues will shrink, forcing the township to rely disproportionately on Strada. Such dependency is unhealthy, leaving communities vulnerable to the decisions of a single private corporation.

In addition, the indirect health costs borne by residents—medications for respiratory illnesses, hearing aids for noise damage, psychological services for stress—represent hidden economic burdens. These costs will not be covered by Strada but by families and the public health system. A thriving community depends on diverse, resilient economic activity. A quarry that drives residents away while externalizing its costs onto the community is the opposite of sustainable economic development. We foresee a community where our children face a growing lack of opportunity.

Strada offers no assurance that they have either the intention or the fully secured financial means to indemnify the community against loss or damage to our health.

5. Traffic and Infrastructure Risks

The proposed Blast Quarry would generate more than 100,000 truck trips annually, or nearly 477 per day – roughly 1 truck per minute, more in peak season. Much of this traffic would pass through a single choke point at Masonville on Highway 124, spilling on down towards Shelburne, then east and west from there. Melancthon’s rural roads, and indeed Ontario’s road system, were never designed for such volumes of industrial traffic, which will negatively impact drivers throughout southern Ontario.

The risks to road users are immediate: collisions with school buses, cyclists, or farm equipment; reduced visibility due to dust and spillage; and road degradation requiring constant maintenance. Research confirms that heavy truck traffic increases accident rates and accelerates infrastructure wear. Residents have no assurances that trucks will avoid residential areas, schools, or sensitive natural areas. Furthermore, noise and vibrations from constant truck traffic will compound the negative health impacts of blasting itself. Diesel exhaust is classified as carcinogenic by the International Agency for Research on Cancer (IARC), adding to the toxic burden faced on our roadways by people from Melancthon and those passing through.

It has been suggested that the impact of truck traffic could be mitigated through measures such as paving and widening of haul routes, dust suppression, noise barriers, and restrictions on truck hours. We disagree. Even if those measures could provide some minimal relief, the proposed $17,500 annual contribution from Strada does not come close to covering these costs, which would then be left to be borne instead by taxpayers.

Strada offers no assurance that they have either the intention or the fully secured financial means to protect the community and its individual members against the loss or damage to our roadways and traffic safety.

6. Environmental and Ecological Integrity

The proposed quarry lies at the headwaters of three critical river systems: the Pine, Boyne and Grand. These watersheds sustain biodiversity across southern Ontario. Blasting and dewatering threaten to alter water flows, degrade wetlands, and reduce biodiversity. Limestone dust, which is alkaline, coats vegetation and soil, disrupting photosynthesis and altering soil chemistry. The result is reduced agricultural productivity and degraded natural habitats. Wildlife will be affected not only by habitat loss but also by noise, vibration, and traffic, which fragment ecosystems and increase mortality. At a time when Ontario has committed to biodiversity conservation and climate resilience, approving such a destructive project would undermine provincial policy commitments.

Strada offers no assurance that they have either  the intention or the fully secured financial means to protect the community and its individual members against the loss or damage to our environment.

7. Community Well Being

Any one of the issues we are highlighting here ought to be sufficient basis for the Ministry to reject Strada’s application. In combination, however, they present the cumulative risk of permanent and irreparable harm to Melancthon as a healthy rural, agricultural community. This is what we hear from our community, over and over again,

As the application addresses topics in silos, it completely fails to consider how the numerous risks and impacts would add up to a devastating assault on community wellbeing.  The Blast Quarry would transform Melancthon from a productive, largely agriculture community to a mining community.  For some, it will become impossible to stay here, for others, it will become undesirable to move here.  For the young, it will not be an attractive place to return to, for water intensive businesses, it will become too risky to set up or expand. For outdoor activity and the tourism, a dusty mining community will never be a first choice.

For those who stay, a peaceful, rural life will become a daily battle with dust, fly rock, noise, shaking, gravel trucks, water trucks and dangerous driving. If their biggest asset is their Melancthon home, they face selling at a discounted price, possibly unable to pay out a mortgage. The calm harmony we now enjoy among long standing residents and newcomers alike will inevitably be replaced by social fragmentation.

To all of this will be added the anger and resentment that comes with knowing that this is entirely unnecessary. 

That they have even contemplated the Blast Quarry demonstrates a lack of loyalty from a developer who has, until now, been accepted here without complaint.

Strada offers no assurance that they have either the intention or  the fully secured financial means to protect the community from inevitable economic and social decline.

8. Failures of Consultation and Transparency

Community trust in Strada is already broken. The community’s understanding of the Community Engagement Agreement between Strada and the North Dufferin Agricultural and Community Task Force (NDACT) was clear: if independent peer reviews identified unreasonable adverse effects, Strada would not proceed with a formal application.

Yet in January 2025, when the independent peer reviewer Garry Hunter would not agree that there would be no unreasonable adverse impacts in the water sector, the applicant made its application anyway and Mr. Hunter’s role was abruptly terminated. 

As for the air quality and blasting issues, in January 2025, NDACT wrote to the consultant WSP, expressing significant concern and disagreement with its Peer Review Report on Strada’s Air Quality, Noise and Blasting studies.  NDACT stated that:

“It is NDACT’s opinion that the Strada Consultant Reports for Noise, Air and Blasting followed the current industry reporting standards in their creation in that they are cookie cutter, boiler plate commentary, largely theoretical, following Ministry guidelines and ensuring the analysis goes no further than the specific area of study. These studies fall short of assessing the environmental impacts caused by noise, air and blasting…

It is NDACT’s opinion that for a project of its kind (blasting; below the water table) all reports fall short of offering robust, current state content for input into the Site Plan…

NDACT receives the WSP Peer Review Report, but NDACT does not agree with all its findings and conclusions. …Considering the effort put into the Community Engagement Agreement, NDACT expected a different outcome.”

Strada’s Wellness Check Program has been plagued by transparency issues, failing to provide residents with meaningful data about their wells and natural features. They are not offering assurance or compensation because even they cannot predict with certainty what their liability could be once the blasting starts.

Witnesses have stated publicly that at the time of its original application to build an above the water table gravel pit, Strada stated that it would not apply for a permit to blast below the water table.  But now, this is exactly what it has done.  This is part of a pattern of behaviour suggests that Strada is unwilling to engage transparently with the community. The Ministry cannot ignore this history when evaluating the company’s assurances.

On October 9 Strada held an information session as required by s. 0.5(3) of the Regulations under the Aggregate Resources Act.  It was clear that the session was not intended to facilitate a meaningful discussion of the proposed Blast Quarry with the community. There was no presentation, no sit-down overview of the proposal and no question-and-answer period. Instead, there were several small displays, each staffed by a host authorized to address only one issue (e.g. ground water, air, etc.). The displays were in very small print addressing the issues in closed silos. and attendees were asked to wait their turn to ask the host their question. The hosts were unable to answer any questions outside of their very narrow area of their display. e

Finally, we question whether Strada has met the basic requirement in s. 0.5(2)(b) of the Regulation under the Act that “the application” be made available for the public to review for the duration of the consultation period. While we have been able to identify on the Strada website and elsewhere (e.g. the Melancthon Township website) the site plan and technical reports, we have been unable to determine which documents are current and form part of the application as finally submitted.

9. Legal and Oversight Deficiencies

The Auditor General of Ontario’s 2023 report identified systemic weaknesses in aggregate resource oversight: insufficient inspections, inadequate enforcement, and lack of transparency.  In such a context, approving a high-risk quarry below the water table would be reckless.

Without robust oversight mechanisms, communities are left vulnerable to corporate disregard or negligence. Self-regulation is not a substitute for public accountability. If the Ministry even contemplates approval, it must first demonstrate that the Government has properly resourced the regulatory system, with independent monitoring conducted by third parties and managed by government authorities. Anything less places unmerited trust in a company that would be  a first-time major water manager.

Given a deficit in the resources required to do robust evaluations, we question whether the Ministry is in a position to perform sufficient analysis of Strada’s application and supporting documentation through the lens of the considerations set out in s. 12 of the Act, and, therefore, to provide a top of class recommendation to the Minister.

10. Conclusion

For the reasons set out in this submission—spanning public health, safety, water, air, economic stability, traffic, transparency, governance, and ecology—we respectfully but firmly urge the Ontario Ministry of Natural Resources and Forestry to deny the Strada Quarry application. The risks are too great, the safeguards too uncertain, and the consequences too permanent.

We call on the Ministry to uphold the values of sustainability, accountability, and community protection, and to reject the Strada Quarry application outright.

Sincerely,

Melancthon Against Quarries: 

Core Team: Anas Attia, Veronique Audette, Janet Burke, Jim Funston, Sheila Hardy, Steve Hutton, Ernie Lynch, Jane Myers, Mark Pratt, Denise Ralph, Bette Ross, Rae Smith, Larry Taman, Roberta Taman, Kurt Weber, Sherry Webster

Cc:         Doug Ford
Sylvia Jones
Kyle Seeback
             

Appendix: References

• Auditor General of Ontario. (2023). Annual Report on Management of Aggregate Resources.
• World Health Organization. (2022). Global Air Quality Guidelines.
• American Lung Association. Particle Pollution and Health Effects.
• Environmental Defence Canada. Reports on Aggregate Impacts.
• International Agency for Research on Cancer (IARC). (2012). Diesel Engine Exhaust Carcinogenic Classification.
• Pope, C. A., & Dockery, D. W. (2006). Health Effects of Fine Particulate Air Pollution: Lines That Connect. New England Journal of Medicine, 356(5), 447–458.
• Forman, R. T. T., & Alexander, L. E. (1998). Roads and Their Major Ecological Effects. Annual Review of Ecology and Systematics, 29, 207–231.
• Town of Caledon & Region of Peel. (2023). Final Transportation Paper on Quarry Impacts.
• Hunter’s Associates Hydrogeology Consultants. (2024). Water Management Summary Report.
• RWDI Air Inc. (2024). Air Quality Assessment #2300646.
• David Suzuki Foundation, Ecojustice Canada, Ontario Nature Conservation – Reports on Quarry Impacts.
• Government of Canada. Canadian Environmental Protection Act (CEPA).
• Bhat, R. et al. (2014). Health Hazards of Stone Crusher Workers in India. Journal of Environmental and Occupational Science, 3(2), 81–84.
• Ontario Ministry of Natural Resources and Forestry. Aggregate Resources Policy Documents.
• Gravel Watch Ontario. (2024). Traffic Safety and Aggregate Truck Routes.