Our friend and team member Veronique Audette posted a detailed comment on Facebook. She lives very close to the propose blast quarry.
Here is her post.
Formal Objection to ARA Application by Strada Aggregates Inc. – Proposed Below-Water-Table Limestone Quarry (Lot 13, Concession 3 OS, Melancthon Township)
We are residents and stewards of a property located less than 100 m from the proposed quarry expansion by Strada Aggregates. We live on this land with our 9-month-old child, relying on a spring-fed pond and groundwater well for drinking water, crop irrigation, and for our not-for-profit community workshops. Our vision is to create a long-term homestead grounded in sustainability, health, and community resilience. Adjacent to this homestead are the plans of our federally registered charity, which include stewardship workshops and land-based learning. Despite multiple attempts to reach Strada to discuss restoration efforts and ecological collaboration, we have received no response.
After reviewing all the relevant documentation, we are submitting this letter as a formal objection to the proposed below-water-table quarry expansion. The risks to our health, water, property infrastructure, property value, and surrounding ecosystems are significant and inadequately addressed in the application materials.
2. Grounds for Objection
A. Groundwater Drawdown and Agricultural Risk
The application proposes to blast and extract limestone below the water table, necessitating the dewatering of approximately 6.7 million litres daily—three times Shelburne’s total municipal use. Our porous soil conditions and proximity to the blast site increases the likelihood of:
- Permanent loss or contamination of our groundwater well
- Drying of our spring-fed pond and connected habitats
We opted to participate in the NDACT WELLness check program, and had a site visit in July of 2024, but the operator did not collect any baseline data or samples from our well, and did not take measurements of our pond, springs and natural water features. Strada has committed to providing access to fresh water in the event that our ground well water might diminish or become contaminated, if this change is a result of mining operations. Without baseline data, how will we ever prove liability when our well fails or becomes contaminated? Having reviewed the public facing documents, there is no adequate well management response plan beyond a general promise to fix issues. There is no mention of compensation or guaranteed fixes for long term water access problems and no mention of solutions for changes in natural water features.
The hydrogeological assessment submitted by Strada Aggregates fails to provide a full inventory of private wells, a proper water budget, or cumulative drawdown modelling. Our property is not listed in Figure 11: Off-Site Domestic Water Well Monitoring. Given our proximity to the blast site, any legitimate and principled study would include this data.
Further, the proposed monitoring program is inadequate at ensuring our families water quality. Blasting poses a risk to well water contamination and since our well is not included in the monitoring framework, we risk exposure to contaminants without our knowledge.
In section 8 of the Hydrogeological Assessment, the Well Complaints Procedure, Strada commits to provide a temporary water supply within 48 hours, until the cause of the disruption can be identified and for a week afterwards. There is no mention of any overseeing body to ensure compliance, or any compensation for this disruption. Permanent solutions are also inadequate, given that they suggest digging a deeper well or moving the well. There is no study or data to ensure that a disruption would necessarily be resolved with these so called solutions. If well system rehabilitation and replacement is not possible, what then? Strada proposes these same weak measures, without compensation procedures or assurances of compliance, in the event that water quality measurements exceed the Ontario Drinking Water Quality Standards. However, as mentioned, there are no water quality monitoring mechanisms applicable to our well so our ability to identify contaminants is limited.
Section 9 entitled Site Plan Recommendations is also problematic. In essence, Strada commits to suspending or moving operations if water levels change more than the established thresholds. This presumes a water table change will necessarily be marginal, temporary and does not account for the possibility of a catastrophic, irreversible event.
Because the hydrogeological data does not conclude that our well and wetland feature will be protected from damage, and the Aggregate Resources Act requires that aggregate operations not cause adverse effects on adjacent water wells, we ask that the application for a below the water table quarry be rejected.
B. Ecological Disruption
Our pond is home to frogs, insects, amphibians and birds that depend on groundwater-fed wetlands. Even modest water table changes could irreversibly harm this ecosystem. No groundwater-dependent ecosystem (GDE) analysis was conducted. This contradicts Ontario’s own Aggregate Resources Act standards.
We have observed several endangered species and species at risk on our property, which would certainly be impacted by a change in ground water. These species include the Hines Emerald Dragonfly, the Prothonotary Warbler, the Spotted Turtle, the snapping turtle, Blanchard’s Cricket frog, and the Acadian Flycatcher. These species rely on wetlands for survival and, in the event that the 10-acre wetland and pond feature on our property suffer water loss, these species would undoubtedly suffer further habitat loss and death. Strata’s request to rezone certain areas of the quarry site from environmental protection to resource extraction endangers these species further by threatening their fragile habitat.
We ask that the Township of Melancthon and The County of Dufferin reject the Zoning By-law Amendment request to “re-designate a portion of the Subject Lands from “Environmental Protection”, subject to policy 5.4.2 (j) to “Extractive Industrial”. We ask that the Township of Melancthon and The County of Dufferin reject the Zoning By-law Amendment request 12-1979 which further diminishes conservation zoning in favour of Extractive Industrial Zoning.
The conclusions of the Hydrogeological Assessment concede that “streams and wetlands may see small changes in flows and levels” but that these are “likely below what is measurable”. However, Gary Hunter, who served as NDACT’s Trusted Peer Reviewer on the Strata project for almost three years, stated that the modelling under-predicted dry-weather groundwater and base flow in drought conditions by a factor of 2 to 3. Wetland species, especially those relying on cold weather systems are extremely vulnerable to any changes. This presumption of negligible effect is unfounded and irresponsible.
Strada’s application proposes to divert groundwater between watersheds, from Pine River towards the Boyne River. Mr. Hunter further flagged that this diversion could cause a substantial drop in Pine River’s base flow and cause wells, streams and ponds to dry up. He estimated up to a 37% reduction in low-flow conditions, a stark contrast to the 2.3% reduction postulated in the application.
The Hydrogeological Assessment also does not account for or propose any restoration or compensation plans in the event of surface natural water feature changes, which would affect the value and quality of our property.
The Natural Resource Solutions Inc. Natural Environment Report conducted a field assessment of the Site, and 120 m surrounding the site. This scope is too narrow to account for water feature changes and environmental impacts from our natural water feature and spring. Despite this narrow scope of study, areas of threatened and endangered species habitat were confirmed and the area was deemed an area of significant wildlife habitat.
The application proposes to destroy four small so called “non significant” wetlands and relocate the species at risk within them. This mention of a new wetland creation is problematic because it fails to answer important questions, amongst them: who will oversee this sensitive project, how much time will be allowed for the establishment of this wetland, and will the migration from one wetland to another be observed prior to disruption? Again, this mitigating measure only applies to the study area and does not account for the hundreds of hectares of wetland at risk as a result of below the water table mining operations.
Finally, the Nottawasaga Valley Conservation Authority, the County of Dufferin and Township of Melancthon Official Plans identify the Subject area as located within a highly vulnerable aquifer and groundwater recharge area. This further strengthens the need for a large scope environmental impact study, which has not been conducted to date.
Because our pond and local wetlands are an invaluable asset, and risks were not properly addressed in the application materials, we ask that the application for a below the water table quarry be rejected.
C. Air Quality & Silica Dust Concerns
We live less than 100 metres from the proposed blast face. Blasting and crushing limestone releases crystalline silica—a carcinogenic dust that is easily inhaled and dangerous at low concentrations. Strada’s air quality report lacks:
- Real-world dispersion modeling under prevailing winds
- An enforceable public-facing monitoring plan
This creates unacceptable health risks, particularly for our infant child. In the study, the emissions from wind erosion of stockpiles are excluded because of the implied application of mitigating measures. As noted previously, we have observed a lack of compliance regarding these dust mitigation measures. The quarry is set to continue operations of aggregate mining, so the cumulative impact of their current operations, without the implementation of mitigating measures, combined with the introduction of carcinogenic silica dust poses a significant risk to our health.
Because this quarry expansion poses a significant risk to the quality of our air, and the Canadian Environmental Protection Act protects against air contamination we ask that the application for a below the water table quarry be rejected.
D. Blasting Risks and Proximity
Explotech’s Blast Impact Analysis omits predicted vibration and airblast levels at residences under 100 metres. No resonant frequency study or baseline vibration data is provided. Repeated blasts, even if technically compliant, can cause structural wear, sleep disruption, and psychological stress.
The blasting analysis (Explotech) states vibrations and noise will remain within provincial limits. However, the report fails to address:
- Detailed flyrock safety modeling relative to nearby residences
- Site-specific vibration monitoring commitments
- Well disruption mitigation measures
Flyrock poses a significant threat to our safety, our animals’ welfare, and buildings. The report does not provide transparent exclusion zones or site-specific plans to manage this risk. Moreover, while the report claims vibrations won’t affect wells, as mentioned our wells baseline data was not collected.
Because Blasting poses a significant risk to our health, given our proximity to the blast site, we ask that the application for a below the water table quarry be rejected.
E. Property Devaluation & Livability Loss
Our property is not only our home—it is our primary asset and future. This project will cause:
- Noise, dust, and traffic incompatible with residential use
- Increased risk to our health and water supply
- Devaluation of our land, reducing financial security and quality of life
Strada offers zero compensation for declining property values, dust-related crop damage, increased truck traffic, or disruptions to rural lifestyles. Their current offer to “truck in water” if a well is destroyed is impractical and dismissive. As a young family building a sustainable homestead and community resource, the risks posed by this quarry imperil not only our property, but our long-term livelihood and mission.
Because this project will cause undue financial loss and hardship, with no plans to mitigate these concerns, we ask that the application for a below the water table quarry be rejected.
F. Conflicts of Interest
The grounds for objection are not only embedded in the technical details of the application, but also in the process by which those technical conclusions were reached. There are apparent contradictions between what the proponent’s consultants portrayed (e.g. “no significant impact”) and what independent experts feared (e.g. major water flow changes). Finally, the agreement between NDACT and Strada created a potential conflict of interest.
Uniquely, NDACT and Strada entered a formal “Community Engagement Agreement” in December 2022. This agreement essentially set a good-faith framework: if ongoing peer-reviewed studies found that the proposed quarry would cause “unreasonable adverse environmental effects,” then Strada would agree to not proceed with a formal application. Conversely, if the studies found no serious harm, NDACT would not object to Strada’s application.
However, Strada filed its official applications for a quarry license (ARA) and planning amendments before the critical hydrogeology peer review was completed, violating the spirit, if not letter, of the agreement. Mr. Hunter, the community’s hydrogeologist, strenuously objected to this move and even directly asked Strada to withdraw the application until the scientific process was finished. He labeled Strada’s premature filing as “heavy-handed” and “a breach of the public trust.” The dismissal of Mr. Hunter in March of 2025 further demonstrates the blatant disregard for commitments made, and further destroys confidence in Strada’s ‘self-monitoring’ strategy in other areas of their application. Since they did not maintain integrity in their first public commitment, I have little confidence they will follow through with the rigorous monitoring needed to ensure local water supply safety.
We formally request that NDACT recuse itself as community engagement arbiter. Their letter of support, dated June 25 2025, that “resolves to no object to the Melancthon Application once filed” demonstrates support for the application, before the peer review process was completed. This illustrates that NDACT has not upheld their commitments to the community and nullifies their position as arbiter.
3. Closing
We respectfully request that:
- The Township of Melancthon and the MNRF reject the current application based on water and health impacts, environmental risk, policy non-compliance and financial hardship.
We are a young family who chose to purchase this land because of the rural quality of life, the beauty of the natural features of the land and the promise of a healthy and vibrant life for our children. This dream, and our ability to realize it elsewhere is threatened by this application. Not only does it endanger our health and vitality by potentially contaminating or threatening our access to water, it also challenges our financial future, and our ability to reclaim our property value. This application endangers our broader dream as a family, which is to life off the land and create a place for community learning and land based education. For all of these reasons, and with the health and future of our infant daughter in mind, we implore that you reject Strada’s application for mining below the water table.
We have included technical Appendices as a summary of our concerns.
Profound gratitude for your consideration,
Veronique Audette, Roman Tataryn, Violette Tataryn
Enclosures:
Technical Appendices to Objection Letter Regarding Strada Aggregates Quarry Expansion
Appendix A: Hydrogeological Concerns and Errors
- Omission of Key Data
- Our well is not included in Figure 11: Off-Site Domestic Water Well Monitoring (Tatham & EarthFx Level 1 & 2 Hydrogeological Assessment, July 2025). This is a serious oversight given our immediate proximity to the blast site.
- No baseline well monitoring data were collected during NDACT’s WELLness check (July 2024). The site visit did not include sampling, flow rates, or measurements from our spring-fed pond.
- Unreliable Modeling & Drawdown Underestimation
- The Maximum Predicted Water Table Report (Tatham, Jan 2025) models groundwater drawdown only on-site, without considering the regional cone of depression or downstream influence.
- The model fails to account for anisotropic flow conditions typical of fractured limestone aquifers, which may cause unpredictable water level declines far beyond the site boundary.
- Garry Hunter, the independent hydrogeologist, noted that the model underpredicts baseflow loss by 2–3x during drought conditions. The proponent assumes only 2.3% impact to Pine River flows, whereas Hunter estimates up to 37% reduction—posing a severe underestimation of regional hydrological risk.
- Missing Well Response Plan Details
- The Well Complaints Procedure (Section
lacks independent oversight. No third-party monitoring, real-time reporting, or enforcement mechanism is defined.
- Strada proposes to dig a deeper well or move existing wells if disruption occurs. However, the hydrogeological assessment provides no assurance these options will restore safe drinking water, nor any case studies or analogous success data.
- No cumulative effects analysis or long-term water budget is included, meaning potential compounded impacts from future industrial and climate variability are not considered.
Appendix B: Air Quality and Health Risk Deficiencies
- Lack of Silica Dust Risk Modelling
- No prevailing wind analysis or topographical influence study is included. This is critical given that predominant wind patterns could direct dust and crystalline silica emissions directly toward neighbouring residences within 100m.
- There is no silica-specific risk assessment, despite the project involving limestone blasting, a well-documented source of respirable crystalline silica (RCS).
- Absence of Real-Time Monitoring Plan
- No public-facing air monitoring or emergency response system is proposed. Residents cannot independently verify compliance or respond to health threats.
- Mitigation measures such as water spray systems are not consistently implemented under the current quarry operations, with dust plumes frequently observed, contradicting claims made in the application.
- The Dust Management Plan fails to identify accountability, operational thresholds, or penalties for non-compliance.
Appendix C: Blasting Impact Concerns
- Omission of Vulnerable Receptors
- Explotech’s Blast Analysis omits modelling for homes under 100m from the blast zone, despite clear residential occupancy in this range.
- The report does not assess vibration transfer to shallow or fractured bedrock wells.
- Lack of Site-Specific Flyrock Modeling
- The report contains no weather-adjusted flyrock modelling. Parameters such as freeze-thaw cycles, terrain slope, and wind are not incorporated.
- No exclusion zones are delineated. Properties with livestock and homes with children are left unaddressed despite the elevated safety risk.
- Well and Structural Degradation Risks
- No resonance frequency testing was performed for nearby buildings or well shafts. This is a standard requirement for projects with high-intensity repeated blasting.
- There is no commitment to repair structural damage or rehabilitate wells, and no protocol to assess damage severity over time.
Appendix D: Environmental Assessment Gaps
- Inadequate Study Scope
- NRSI’s Natural Environment Assessment (Jan 2025) limited its fieldwork to a 120m buffer, excluding properties with interconnected habitats.
- Key wetland systems, such as the spring-fed pond on our property, were omitted. These systems have hydrological and ecological connectivity and should have been included under the precautionary principle.
- Contradiction with Provincial Policies
- The proposed rezoning from “Environmental Protection” to “Extractive Industrial” directly contradicts the County and Township Official Plans that designate this area as a Highly Vulnerable Aquifer and Significant Groundwater Recharge Area.
- According to Ontario Regulation 287/07 (Clean Water Act), vulnerable aquifers are to receive additional protection measures, not industrial upzoning.
- No Monitoring or Contingency Plan
- There is no adaptive management plan should groundwater-dependent ecosystems experience stress. This omission violates Section 4.5.2 of the Aggregate Resources Act policy framework.
- The plan to destroy 4 wetlands and “recreate” one lacks a construction timeline, monitoring metrics, or species-at-risk transition strategy. This fails to demonstrate no-net-loss principles under Ontario’s Natural Heritage policies.
Appendix E: Procedural Irregularities and Conflicts of Interest
- Premature Filing and Breach of Community Agreement
- Strada filed its ARA and ZBA applications prior to the completion of the third-party hydrogeological peer review, contravening the spirit of its 2022 Community Engagement Agreement with NDACT.
- Garry Hunter, the lead independent reviewer, objected to the filing and was subsequently removed, which compromised the independence of the technical review process.
- Lack of Transparent Consultation
- Strada has not responded to formal inquiries from adjacent landowners, including direct communications.
- Public documents reference a water supply plan that is not included in the submitted application materials, raising concerns about selective transparency.
- Despite commitments made in community meetings, these assurances are not codified in the application documents or site plans, making them unenforceable.
References:
- Tatham and EarthFx Hydrogeological Assessment: https://melancthontownship.ca/wp-content/uploads/2025/07/3.-Tatham-and-EarthFx-Level-1-and-2-Hydrogeological-Assessment-June-26-2025-July-11-2025.pdf
- Explotech Blast Impact Report: https://melancthontownship.ca/wp-content/uploads/2025/07/6.-Explotech-Blasting-Impact-Analysis-Jan-12-2025-July-11-2025.pdf
- Natural Resource Solutions Inc. Environment Assessment: https://melancthontownship.ca/wp-content/uploads/2025/07/5.-NRSI-Natural-Environment-Assessment-January-2025-July-11-2025.pdf
- Maximum Predicted Water Table Report: https://melancthontownship.ca/wp-content/uploads/2025/07/4.-Tatham-Maximum-Predicted-Water-Table-Report-Jan-13-2025-July-11-2025.pdf
- Ontario Regulation 287/07 under the Clean Water Act: https://www.ontario.ca/laws/regulation/070287