Commenter: Melancthon Against Quarries

To: Ministry of Natural Resources and Forestry

Date:  September 16, 2025

Introduction

Melancthon Against Quarries is an initiative of a citizens group based in Melancthon Township and reaching outside to other communities.

We have worked for the past year to raise awareness about the dangers presented Strada’s proposed below the water table Blast Quarry and to express the community’s strong opposition to it.  We have distributed flyers and lawn signs in Melancthon, hosted three Town Hall information sessions and participated in others. We are the publishers of  Melancthon Against Quarries, our newsletter which now has 503 subscribers. We are currently circulating in person and online petitions expressing the community’s strong opposition to the Strada Blast Quarry.

People here have lived for many years without complaint about gravel pits.  They have been seen as part of rural life.  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 support life in Melancthon and surrounding communities, it is widely considered to pose wholly unnecessary risks to our community.

As reported by the Reform Gravel Mining Coalition (RGMC), in October 2024, the Ministry released an updated study on aggregate supply and demand in the Greater Golden Horseshoe (GGH). The report confirms there is a 6.2 billion tonne reserve of aggregates in the GGH 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 sell this aggregate somewhere does not prove that there is a need to do so.  This whole area 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 these comments are shared by the overwhelming majority of residents of Melancthon Township and the surrounding communities.  These comments 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 Ministry 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; and the unnecessary nature of the quarry development given the significant existing aggregate supply in Ontario. Each section draws on credible sources, scientific evidence, and lived experience of residents.

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

Our collective message is clear: 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.

We ask for Strada’s assurance that there will be zero fly rock risk to our community.

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.

We ask for Strada’s assurance that there will be zero air quality risk to our community.

3. Water and Hydrogeological Concerns

Blasting below the water table introduces risks that extend far beyond the boundaries of the quarry. Hydrogeological studies have shown that blasting can fracture bedrock, altering natural aquifer systems and creating artificial pathways for contamination. 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; further disruption would be catastrophic.

The promise of trucking water to residents in the event of well failure is inadequate and insulting. Water trucking has a shameful history in Canada in relation to poor water quality on a number of First Nations. In many of those situations, the practice was intended to be a short-term, “band-aid” solution, but has become a permanent feature of life in those communities. Nothing in the application for the proposed Blast Quarry suggests that residents of Melancthon Township will not face a similar, long-term fate.

Since Melancthon is the site of the headwaters of the Pine, Boyne and Grand rivers, we would also point out that approving this project would put at risk water quality in the Nottawasaga River and Georgian Bay, and downstream communities from Melancthon including Alliston, Angus, Collingwood and Wasaga Beach.

Strada has no prior experience with water management on this scale, and should not be permitted to “learn on the job” given the significant impacts we’ve described. 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.

We ask for Strada’s assurance that there will be not decrease in our current supply of pure water.

4. Economic and Social Consequences

The economic impacts of the quarry will be wide-ranging and overwhelmingly negative. Real estate values are already affected, with local agents reporting that buyers are reluctant to move into Melancthon due to the uncertainty of the quarry’s approval. 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 growing lack of opportunity

We ask for Strada’s assurance that they have the intention and the financial means to protect the community and its individual members against the economic loss their below the water table Blast Quarry will surely cause.

5. Traffic and Infrastructure Risks

The quarry would generate approximately 125,000 truck trips annually, or nearly 350 per day. 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 by residents.

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.

We ask for Strada’s assurance that they have the intention and the secure financial means to protect the community and its individual members against the economic loss their below the water table Blast Quarry will surely cause.

6. Failures of Consultation and Transparency

Community trust in Strada is already broken. The Community Engagement Agreement signed with 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 reviewer Garry Hunter raised concerns, his role was abruptly terminated and Strada proceeded with its application anyway. This represents a clear breach of trust and of the spirit of the Community Engagement Agreement.

Also in January 2025, NDACT wrote to WSP, expressing significant concern and disagreement with WSP’s Peer Review Report respecting Strada’s Air Quality, Noise and Blasting studies. NDACT indicated 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 is similarly flawed, failing to provide residents with transparent or meaningful data about their wells and natural features.

Promises of transparency have not been kept. This pattern of behaviour suggests that Strada is unwilling to engage honestly with the community. The Ministry cannot ignore this history when evaluating the company’s assurances.

7. 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.

8. 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 regulatory systems have been reformed, with independent monitoring conducted by third parties, funded by Strada but managed by government authorities. Anything less places too much trust in a company with a history of disregarding community agreements.

9. Community Well Being

Any of the issues raised above ought to be sufficient basis for the Ministry to reject Strada’s application. In combination, they present the risk of permanent and irreparable harm to Melancthon as an agricultural and rural community.

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.

Approving this project would represent a profound failure of public duty. We call on the Ministry to uphold the values of sustainability, accountability, and community protection, and to reject the Strada Quarry application outright.

Sincerely,

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.