Demand that Reprocessing of Toxic Demolition Debris be Prohibited in Gravel Pits near Aquifers
- by: PitSense Niagara Escarpment Group Inc.
- recipient: Ontario Government and Municipal Councils in Ontario
In early 2014 a new clause appeared in Ontario's 'Provincial Policy Statement' that says: "2.5.2.3 Mineral aggregate resource conservation shall be undertaken, including through the use of accessory aggregate recycling facilities within operations, wherever feasible." ("operations" refers to virgin aggregate extraction in pits and quarries)
We oppose this provision for the following reasons:
1) Recovery, reprocessing and recycling of useful aggregate materials from demolition debris involves the transport, stockpiling, sorting, crushing, blending, storage and further haulage of materials that are not suited to such processing in close proximity to our aquifers (drinking water sources) and “sensitive land uses” such as are found near many pits and quarries throughout Ontario.
2) There have been no studies of the technical requirements for safe and environmentally sound operation of such facilities within pits and quarries.
3) There have been no studies to demonstrate the economic viability of such operations, including the costs of transport of demolition wastes to and from the pits, at the varying quantities that might be expected.
4) There has been no consideration of the socio-economic impacts on residents and communities that are in proximity to pits and quarries.
5) There are no studies or reports regarding potential environmental and human health impacts from such operations.
6) The Ministry of Environment D-6 Guidelines that would normally apply to such Class 3 Industrial operations would not pertain to such operations established within pits and quarries.
7) The Ministry of Natural Resources does not possess the resources or expertise to properly supervise and manage such operations.
8) The words “where feasible” are undefined and so vague as to be meaningless and absent of any protective effect.
Accordingly we ask that you give full regard to the ‘Precautionary Principle’ and ensure that this reckless and ill-considered clause be repealed from PPS2014 and replaced with one prohibiting such reckless activities.
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Dear (member of provincial parliament or municipal councillor);
In early 2014 a new clause appeared in Ontario's 'Provincial Policy Statement' that says: "2.5.2.3 Mineral aggregate resource conservation shall be undertaken, including through the use of accessory aggregate recycling facilities within operations, wherever feasible." ("operations" refers to virgin aggregate extraction in pits and quarries)
I oppose this provision for the following reasons:
1) Recovery, reprocessing and recycling of useful aggregate materials from demolition debris involves the transport, stockpiling, sorting, crushing, blending, storage and further haulage of materials that are not suited to such processing in close proximity to our aquifers (drinking water sources) and “sensitive land uses” such as are found near many pits and quarries throughout Ontario.
2) There have been no studies of the technical requirements for safe and environmentally sound operation of such facilities within pits and quarries.
3) There have been no studies to demonstrate the economic viability of such operations, including the costs of transport of demolition wastes to and from the pits, at the varying quantities that might be expected.
4) There has been no consideration of the socio-economic impacts on residents and communities that are in proximity to pits and quarries.
5) There are no studies or reports regarding potential environmental and human health impacts from such operations.
6) The Ministry of Environment D-6 Guidelines that would normally apply to such Class 3 Industrial operations would not pertain to such operations established within pits and quarries.
7) The Ministry of Natural Resources does not possess the resources or expertise to properly supervise and manage such operations.
8) The words “where feasible” are undefined and so vague as to be meaningless and absent of any protective effect.
Accordingly I ask that you give full regard to the ‘Precautionary Principle’ and ensure that this reckless and ill-considered clause be repealed from PPS2014 and replaced with one prohibiting such reckless activities.
Repectfully;
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