Stephen Middleton wrote this letter with the Mono Mulmer Citizens Coalition (MC2). Thanks to MC2 and to Stephen.
Stephen’s background is in clinical chemistry, process, design, project and program management. He is a husband, father and grandfather.
He is a lifelong Monty Python fan and pun lover. Here is the letter.
This is the second of two letters from the Mono Mulmur Citizens’ Coalition. In out first letter (dated ##/##/####) we stated that we have serious concerns with the studies undertaken by Strada, especially in relation to the claim that the “hydrogeology, noise, air and blasting studies …. confirm no adverse impacts on the environment, water resources, or surrounding areas.” Strada is asking us to believe that (1) all risks have been identified, (2) all mitigation requirements will be flawlessly implemented, and (3) every aspect of the mitigation plan is 100% effective for all risks. In other words, Strada is claiming that there are absolutely no unknowns and that the possibility of any detrimental effect from all risks is zero percent. As any impartial risk assessment would confirm, this statement can only be true if the project is not undertaken.
Details of our concerns with the Hydrogeological and Hydrological Assessment, Air Quality Assessment, Traffic Impact Assessment and Agricultural Impact Assessment are given below.
Hydrogeological and Hydrological Assessment
We have concerns related to the following aspects of the study:
- As the authors note, “The site lies within an SGRA [significant groundwater recharge area] with a score of 6 and is identified as being a highly vulnerable aquifer (HVA).” An SGRA score of 6 indicates a high vulnerability to contamination and a high capacity for water to infiltrate the ground. These areas are crucial for maintaining drinking water supplies and at the same time very susceptible to contamination.
- The study also states that “Semi-annual water quality sampling for pH, Conductivity, Alkalinity, Bicarbonate, Chloride, Metals (Antimony, Arsenic, Barium, Beryllium, Boron, Cadmium, Calcium, Cobalt, Copper, Lead, Iron, Magnesium, Manganese, Mercury, Molybdenum, Nickel, Potassium, Selenium, Sodium, Silver, Strontium, Sulfur, Thallium, Thorium, Tin, Titanium, Tungsten, Uranium, Vanadium, Zinc), Nitrate/Nitrite, and Sulphate shall be conducted.”
- And that, “Annual water quality sampling for Petroleum Hydrocarbons Fractions F1 to F4, Benzene, Toluene, Ethylbenzene and Xylenes, and Oil and Grease shall be conducted.”
- The stipulated requirement for this testing clearly indicates the presence of a very real threat to this “highly vulnerable” and essential aquifer.
- The authors also describe the preparation and calibration of the simulation model on which much of their impact and risk assessment is based. However, they note significant limitations in the data used to calibrate the model, as evidenced in the following extracts:
- “It should be noted that the MECP well record data has a high intrinsic error (see Kassenaar and Wexler (2006)) and this impedes the ability to produce lower RMSE values. In addition to intrinsic measurement error, the MECP water levels represent one-time measurements at a point taken at different times over a timescale spanning decades. Measurements could have been taken in different seasons and in wet or dry years.”
- “Static water levels recorded in the MECP WWIS database served as a primary target for the regional-scale calibration. Numerous biases and errors are known to exist in the water well record data … Despite the known data quality issues, the WWIS data set is this best available data”
- “The comparative analysis included in this steady-state groundwater calibration section is limited to observed data collected above the Niagara Escarpment as intermediate and deep hydrostratigraphic units below the Escarpment were not explicitly modelled.”
- The above statements describe a model built on limited data with known biases and errors in which significant layers of hydrostratigraphic units cannot be covered since there is no data, flawed or otherwise.
- This model cannot possibly be used to conclude, as Strada is attempting to do, that all risks have been identified and there will be “no adverse impacts on the environment, water resources, or surrounding areas”.
- In addition, the assessment fails to consider that we are now entering what will be a protracted period of unprecedented climate change. The Canadian Drought Monitor (Agriculture and Agri-Food Canada) reports that, “Through July [2025], most of Canada recorded below – to well below – average precipitation driving both the spread and intensification of drought across the country.” And that, “southern and eastern Ontario received hot, dry conditions that expanded existing dry and drought areas.” It would be a grave error to consider this to be an anomaly rather than the beginning of a continuing pattern of increasing frequency of extreme weather events. Consider the potential impact, over the life of the proposed quarry, of the increasing need for agricultural irrigation and drinking water to support a growing population (estimated 40% growth in Ontario by 2025). This is not the time to be exposing a highly vulnerable critical resource to unnecessary risk.
Air Quality Assessment
We have two main concerns related to this study:
- The first is that the author’s considerations are primarily for the local effect of the quarry operation in relation to the existing “background” air quality.
- The effect of climate change and the related frequency and size of wildfires that we will experience over the life of the proposed quarry is completely missing.
- Wildfire activity continues occur each summer at record levels. In 2023 in Ontario there were 13 special air quality statements covering 55 days. The large majority of these were related to wildfire smoke. As far as we have been able to determine, data for 2024 and 2025 are not yet published; however, we expect that this data will show a continuing degradation of our air quality.
- Rather than considering the quarry contribution to air contamination in isolation; we should be asking, “Can we afford to add any additional contaminants to the already overburdened air we are breathing?” One of the deciding criteria should certainly be, “Is it absolutely necessary to do so?”
- The second concern is with the dust control measures prescribed for the quarry if it should go ahead.
- Dust mitigation will require a significant volume of water, placing an additional stress on a critical resource. In dry conditions, which are defined as 2 consecutive days without rainfall over 1mm, the quarry will be required to apply water at rates up to 1.5L/Square Meter every hour. The total quarry area is 123.8 hectares. The study does not provide any estimate of the size of the application area. Watering of the whole area would require 1,875,000 litres per hour. While we are not assuming that this will be necessary, water usage estimates for this control measure are needed.
Traffic Impact Assessment
The traffic impact study is very limited in breadth and the time frame over which traffic volumes are projected.
- Specifically, the area of focus is limited to the roads immediately surrounding the quarry and route 17 out to the intersection of highway 124 and the timeline for the traffic volume projections stops a 2032 when the quarry will be in full production and the peak steady state of truck traffic will be reached.
- The issue we have with this approach is that, (1) it does not consider the impact of the increased south-bound and returning north-bound truck traffic on the routes beyond the 17 and 24 intersection. And (2) it fails to account for the fact that, while the quarry truck traffic will continue at a steady-state, the volume of other traffic will continue to increase over time and will have to compete for road room with the heavy trucks.
- Traffic on the north and southbound routes is already a significant problem and this will exacerbate it.
Agricultural Impact Assessment
This assessment does not address specific observations and projections from the Hydrogeological report. The assessment begins by stating that, “Management of water resources is an important consideration for farm operations, particularly for watering field/vegetable crops and hydrating livestock. Changes to the hydrologic and/or hydrogeologic conditions in the area surrounding the subject lands could have a negative impact on farm operations and crop yields.” It goes on to sate that, based on the hydrogeological assessment, it is not anticipated that the proposed pit/quarry will have a negative impact on surrounding agricultural land. However, this statement does not explicitly address the following observations and projections from the Hydrogeological Report:
- “Hydrographs indicate that the difference between Baseline and Phase 2 streamflow at location STR7 in Horning’s Mills is expected to be between 10% and 20%. Of note is that the measured impact on streamflow affects small headwater streams with low flows throughout the year.”
- “The drawdown reduces streamflow and surface leakage into Pond NAT-18. Hydrographs indicate that the difference between Baseline and Phase 4A streamflows at location STR7, downstream of the pond are significant during the summer and moderate during the spring.”
- “Streamflow at location STR8, a low-order stream, is expected to be significantly reduced throughout the year”
It must be made clear whether or not the groundwater changes described above are pertinent to the Agricultural Impact Assessment and if not, why?
Risk, Mitigation, Remediation and Regulatory Oversight Concerns
Strada has not presented a formal risk identification and assessment matrix. Given the identified risks and unanswered questions that arise from the studies, Strada’s announcement that they “confirm no adverse impacts on the environment, water resources, or surrounding areas”, is very concerning. The impression is that Strada believes that if they repeat the “no risk, no risk, no risk” mantra often enough, it will somehow magically become reality.
The picture of the Ontario aggregate business provided in the 2023 Auditor General’s report, “Management of Aggregate Resources” only adds to our already serious concerns. The following extracts illustrate the state of the aggregate business as found by the Auditor General:
- “Our audit found that the Ministry did not have effective systems and processes in place to ensure compliance with the Aggregate Resources Act and aggregate-related regulations, policies and approvals, nor to oversee aggregate development and operations in a manner that minimizes adverse impacts on the environment.”
- “The Ministry has made recent progress to streamline and expedite the approvals process, but we found that this improvement has come at a cost to its inspection, enforcement and oversight activities.”
- “Non-compliance within the aggregate industry remains high. Over the past five years, the percentage of inspected sites deemed satisfactory by Ministry inspectors has remained low, fluctuating between 36% and 52%.”
- “Despite the high rate of non-compliance, the Ministry rarely pursued charges. Between 2018 and 2022, inspectors made 26 referrals, representing less than 1% of the over 3,400 violations identified during this time.”
- “The Ministry did not have processes in place to ensure that sites are promptly rehabilitated, and returned to productive use, after extraction is complete. While many aggregate operators properly rehabilitate their sites, we found 1,524 sites that have sat dormant (without reporting any aggregate extraction) for at least 10 years. These sites represent more than 25,000 hectares of land, approximately the size of Brampton, Ontario.”
- “There is a risk that those sites have, in fact, finished extraction and operators are avoiding rehabilitation efforts.”
This is not a picture of an industry that can be simply taken at its word, and trusted to do the right thing, when it comes to prioritizing the quality of our air, water and agricultural lands over profit. There can be no doubt that, over the lifespan of the proposed quarry, Ontario and the world will experience significant climate change. It would be unforgivably negligent to put our most critical resources (namely, food, air and water) at risk for a quarry expansion that Ontario does not really need.