July 10. 2017

 

To:

Ministry of Natural Resources and Forestry​​​
Parry Sound District, Bracebridge Field office​​​
Ministry of Natural Resources and Forestry
1350 High Falls Road,​​​​​​
Bracebridge, ON, P1L 1W9

Attention: Jeff Schosser, Aggregates Inspector/Specialist​​
e-mail: MNRF.BRA@Ontario.ca

 

Frank and Elizabeth Lippa
c/o Skelton Brumwell & Associates Inc.
​​​93 Bell Farm Road, Suite 107
Barrie, Ontario
​​​​​L4M 5G1

Attention: Caitlin Port, RPP
​​​​​e-mail: cport@skeltonbrumwell.ca

 

Letter of Objection Regarding: Proposed Quarry
Location:
1089 Butler Mill Road, Rosseau, ON
North Half of Lot 4 and Part of Lots 4 and 3, Concession 4, Geographic Township of Cardwell,
Township of Muskoka Lakes, District of Municipality of Muskoka

I have several concerns regarding the proposed quarry, but here I will focus primarily on releases to air and to water.
The limits that the province will apply to releases from the quarry are not known to us at this time, but are to be established after the current application has been approved by MNRF. Limits for releases to water will be part of the Environmental Compliance Approval (ECA) for industrial sewage works, and the Permit to Take Water (PTTW), both issued by MOECC. Air emissions may be controlled under Ontario Regulation 319/05, implemented by MOECC, and procedures, but not limits, for control of dust emissions are stipulated in the Aggregate Resources Act.
It is my belief, in fact my knowledge, that these limits to releases will fail to protect the local environment and the health of those living there. How can I say this when I have not yet seen these limits ?
I say this because I spent much of my career, spanning more that 30 years, as a professional engineer with Environment Canada, developing standards for releases to air and water from a range of industrial activities. Over that time it became increasingly clear that the way these release standards, best practices etc. were developed precluded them being adequately protective of the environment and health. Let me be clear, it is not just some particular type or group of release standards that is flawed, it is the way they are developed, and in fact their very nature that is flawed. And this applies not just to release standards in Ontario, or Canada, but also in the U.S. and generally in the western world.
A summary discussion of how and why release standards are flawed is presented in the addendum to this note.
The “bottom line” on release standards is that we should not fall into the trap of believing that because any particular enterprise will meet “all the appropriate environmental standards”, it will necessarily be safe for the environment and for health. This problem with release standards is not meant as a criticism of my former colleagues at the MOECC, MNRF, Environment Canada or any other regulatory organization. The problem is the way western society as a whole deals with protection of the environment and health.
Should it seem that I wish to stop all industrial development in order to protect environment and health, I can assure you that the truth is vastly different. My opinion is that much of the industrial development of the past could have gone ahead without major problems to the environment, health or the economy if we had “gotten it right” on controlling releases. And much of the development foreseen for the future could go ahead if we get it right starting now. We need to do this to protect our future and that of our children and grandchildren.
And “getting it right” is not a matter of dream or fantasy. Many of the aspects of “getting it right” have been thoroughly researched, debated and largely agreed upon for many years by scientists, engineers, economists and legal experts. Some of these aspects include the precautionary principle, cumulative effects assessment and full life-cycle cost accountability. What is lacking is primarily the political will to put these into effect at the senior political and ultimately global level.
So what to do about the proposed Lippa Quarry ?
I expect that others have addressed or will address the potential, not quantified as yet, but likely present to some degree, for releases of suspended particulate matter, heavy metals, phosphorus and perhaps other contaminants in the mine dewatering releases, and the releases of very fine respirable particulates including PM 10 and PM2.5, in the fugitive dust emissions from the quarry. PM 10 and PM2.5 are known carcinogens that have well-documented health impacts, no safe exposure levels, and can be transported long distances in the atmosphere. Where there is potential for such harmful releases and there are sensitive environments such as Skeleton Lake and human populations nearby, there are only two reasonable options:
1. At the very least, make approval contingent upon the implementation of exemplary controls on releases. These controls should go far beyond achievement of current release standards and be accompanied by rigorous monitoring to ensure that releases are in fact being kept to “at background” levels in all conditions, including off-standard or unexpected circumstances. Failure to achieve such control on releases should be grounds for withdrawal of permission to operate. If it is not possible to ensure such control, then approval should be denied.
2. Deny the application outright, based on its proximity to sensitive environments and populations.
I submit to you that option 2. is the more appropriate option for MNRF.

Sincerely,
Geoff Ross
 

 

ADDENDUM
Why are release standards not adequately protective of the environment and health ??
1. Release standards are most often based on the premise that the concentration or quantity of releases can be reduced to levels at which there is no clear evidence of damage to the environment or health. This premise is flawed in at least two important ways:
a) The rigour of scientific methods is such that it usually takes a very long time to develop conclusive evidence that some level of releases will in fact cause damage. Strong (but not conclusive) evidence of damage may exist, but this is rarely enough to result in limits to releases. The stringency of any release limits to be implemented will, at best, be subject to the scientific certainty supporting them. This usually develops in stages, supporting more stringent release limits as the science becomes more conclusive over time. Our society has been reluctant to embrace the precautionary principle, which would support more stringent release limits where it is likely, but not conclusively proven, that damage will occur. So release limits based on rigorous science are associated with serious time delays in responding to problems.
The following are just some of the more prominent of the many examples of where this approach has allowed problems to become serious before greater control of releases is required.
Atmospheric deposition of acidic pollutants, commonly known as acid rain, has caused countless billions of dollars worth of impacts on health and the environment, and has resulted in industry and society as a whole spending many billions to try to correct the problem. Much of this could have been avoided had we gotten releases of acid gases effectively under control in the early days. We could have, but we didn’t. And though we now have release standards that have reduced the severity of the problem, we haven’t solved it. The release standards approach is not good enough. New manifestations of the acid rain problem, such as calcium depletion in soils and lakes, are becoming apparent and will likely continue to impose severe costs on society.
Ozone and fine particulates in the air we breathe, commonly known as “smog” continue to cost billions of dollars per year in health damage alone in Ontario. The pollutants that cause smog, their sources and ways to control them, have been known for a very long time. Standards to control these emissions have been a more recent development, and emissions from some sources have declined by as much as 99%, but the problem is still far from solved. The health damage continues. The standards approach is not good enough.
Mercury releases from chlor-alkali plants associated with pulp and paper led to such severe problems with mercury in fish, and the consequent health impacts on those eating fish, that the plants were ultimately shut down. This is one example of where it was actually recognized that release standards were not going to suffice; shut-down was the only answer. The river systems are still seriously damaged. But mercury in fish is currently a problem in waters not touched by chlor-alkali plants. The mercury is in large part coming from power plants and smelters throughout North America and in fact the world. Emission standards for such plants have not, at least until very recently, even addressed mercury.
b) Some substances have no threshold for impacts on the environment or health. That is to say, there is no level at which the substance has no impact. Silica dust, in the form of respirable particulate matter such as is released from quarrying operations, is one of these substances. Releases of silica dust are commonly referred to as “fugitive emissions”, meaning that they have escaped whatever control measures are in place, often because they come from a number of dispersed and difficult to control points. Very small particles can be transported substantial distances . Thus, control measures, such as water sprays, or point of impingement standards at the quarry boundary, do not ensure safety for the environment or health in areas adjacent to points of release. The only thing that can reasonably be done is to ensure that points of release of such substances are separated by substantial distances from sensitive environments and human populations.
2. Where release standards have been developed they have rarely been developed based on environmental or health impacts. Generally they have been based on applying a degree of control that has been demonstrated to be technically and economically feasible. In other words, “we know how to do it and it won’t cost too much”. Thus, the release standards are not necessarily related in any way to impacts on environment or health. Without solid data on the environmental or health costs of releases, the release standards and the technology necessary to achieve them can be seriously compromised by arguments that they are too expensive. And so, if they exist at all, the release standards are likely to represent what is felt to be a “reasonable” level of effort to control releases. Our experience has been that in nearly all cases this level of effort has over time been found to be not enough. Note that this trend is unidirectional, i.e. it is always found that we need to further reduce our releases; I know of no examples of the reverse for major environmental issues.
3. Where release standards have been developed for a substance they are nearly always applied to one source at a time and fail to address the cumulative environmental and health impacts of releases of the same substance from other sources. A number of sources, each of which may be controlled to the point where their impacts are too small to measure, may in total be causing serious problems.
4. The release standards in nearly all cases fail to deal with the fact that the costs of controlling releases are not the same for all sources. As a result some individual sources will face much higher control costs than others. These will generally become the reference point for not requiring further control in order to avoid “excessive” costs. But overall costs could be reduced and greater control of releases achieved more efficiently by going beyond release standards. The closest Ontario has come to this has been in the “Countdown Acid Rain” program, where emission caps were placed on smelters and power plants, leaving Ontario Hydro (at that time) to determine where (at which plants) releases could be reduced to meet the overall cap at least cost. But even this program failed to provide any monetary incentive to reduce beyond the level of the Ontario Hydro cap. The U.S. went a step further with their system of SO2 emission caps for power plants, but even it failed to provide incentives for reductions below the overall cap. Ultimately, Ontario phased-out coal-fired power generation in recognition of the environmental costs of its acid gas, smog precursor, mercury and CO2 emissions. But this came after spending $billions on the release standards approach.
5. Release standards are never developed for all sources of a substance, but usually only for the major and most “visible” sources and those most amenable to source control. The fact that there are no release limits for a source does not indicate that it poses no threat to the environment and health.

 

 

Ministry of Natural Resources and Forestry
Attention: Jeff Schosser

Skelton Brummell and Associates
Attention: Caitlin Port

Mr. Schosser/Ms. Port,

My letter comes to you to object to the Lippa Quarry Mining License Application. There are many reasons for my objections, however I only list several at this time.

WATER QUALITY:
To allow the proposed Quarry to use explosives on granite so close to Skeleton Lake will destroy the limestone shell of the Lake. The Lake water will be exposed to mercury and phosphorus contamination. Five generations of my family have enjoyed this oasis. Most cottagers use the Lake water for drinking. We have tried, and have been successful, in maintaining the water quality while adhering to Municipal regulations and Zoning requirements. Destroying or reducing the water quality would be a tragedy.

HEALTH RISKS:
It has been determined that the silica dust emanating from the Quarry will be detrimental to the health of those around the Lake and Community. The negative impact on the air quality in the area must be prohibited. We pride ourselves in nurturing and promoting green space. This must not be destroyed.

ROAD TRAFFIC:
To suggest that seven large aggregate carrying trucks every hour will not effect the road and surrounding communities is foolishness. The road is built on bog in many areas. It currently needs repair on an annual basis. Approval of this Application would require tax payers to provide addition funds for repair of the road destroyed by a commercial endeavour. The lives of the individuals and families who use or live near the road will be negatively impacted. This road is used by cyclists, local school buses and tourists to say nothing of the local traffic. To add large aggregate-carrying truck traffic with the turns, twists and hills of this road is a safety risk. Large trucks with heavy loads cannot stop quickly. This is a recipe for a major disaster. Surely the MNR&F must seriously consider the risk management of this situation.

I support the Township of Muskoka Lakes Council and the Town of Huntsville Council in non support for this Quarry. They have considered the risks and have made the correct decision to not support the Lippa Quarry Mining License. The two Municipalities have determined that there is no benefit to the community in approving this application. Muskoka has enough aggregate from the current eighteen quarries to last many years.

 

Teddene Long

 

 

On July 10,  the SLCO’s legal council, Donnelly Law, filed an official Letter of Objection with the MNRF calling on them to reject the application by Mr. Frank Lippa for a Class “A” License to operate a pit and quarry on Butler Mill Rd.  

You can read the Letter of Objection in its entirety here:  2017 07 10 Ltr from Donnelly Law re Objection to Lippa Pit.pdf

 

 

The following letter was submitted by Linda Tone who was kind enough to share her thoughts after attending the ToML meeting on June 16th.

 

I am writing to you to express my feelings about the proposed LIPPA PIT-

My parents purchased this property in the 70’s after having to leave Silver Sands Campground due to unforeseen circumstances . With heavy hearts they searched and searched for the perfect piece of land, and found it. They worked for 4 years to clear the land as we lived in Toronto and both of them were working during the week so they could only come up on weekends and holidays. After all their hard work and tireless effort their dream was a reality- Cedar Shores Campground was open in 1978/79.
My parents loved Muskoka so much they wanted to share all the beauty and solitude our great area supplied with no effort on Mother Natures part. Not very big but very private- some people don’t even know its here.

Dad and Mom were involved the Deer Feeding Association in the winter soon after moving up here and in a few years had up to 68 beautiful deer right in our backyard. Travellers on the road would see them and stop at the top of the driveway and my parents would ask them to come in and have tea and watch them up close through the big picture window in the basement, in the middle was my Mom talking to them and putting seed down as if she were talking to a group of kids- it was amazing.

Our little lake -Slocombe- was stocked for the campers to fish in . To this day we do not allow gas motors in our lake, you row ,canoe- kayak, use an electric motor , or fish from the shore. Unfortunately the Pike have come from a surrounding lake through the water system that connects all our lakes, in one way or the other, either underground or above ground. They are a very invasive species .

We have first – second – and third generation campers here and have people looking for spots all the time, but alas we are at capacity. My parents have since passed away and left this beautiful Campground in the families care to keep their dream alive. Making sure that we keep our promise not to make drastic changes to the property to harm the wildlife or surrounding bush area.

There are turtles, painted and snappers, deer, turkey vultures, and other wildlife on the roads all the time and I have stopped numerous times to help get them off the road, so periodically there are two or three cars stopped on Muskoka Rd. #3- not very good or very safe if there are going to be more large trucks on the road- at 80klms in this section I doubt that a large truck loaded or not will be able to stop that quickly.

In building the proposed Pit, I am afraid even as far away as we are from it that our little lake will be harmed , our beautiful rocks that are all over our property will be stressed, the poor animals that live in the area will be tortured by the noise, the campers – our family trying to get out of our driveway all of this will be a life threatening issue for all. What about the Postal Person that makes frequent stops at the driveways to deliver mail, people trying to get out of Old Aspdin Rd. how about the multitude of Motorcycles and Car clubs, of Bicycle groups and joggers that travel this road and the neighbours that have to walk on the road to get to their mailboxes.

I do understand that this is a short cut to Parry Sound , the road to the Dump, to beautiful Skeleton Lake and all its cottagers, to other campgrounds , to Rousseau , but putting 70% more trucks on our road seems a little drastic and unnecessary, and a detriment to the road quality which will certainly change with all the excess weight that will be added to it.

We were at the meeting and I listened to all of the statistics about the rocks fracturing, the lakes, the air quality, the noise ,the safety to wildlife and most importantly the people that live in the area. It was also stated that there are 9 pits already in Muskoka- we need another one WHY??
One comment was that the pit will fail because of that- too many already. This pit will not benefit Muskoka but destroy it. Our Green House Gas issue is severe enough , lets not add more problems to our air. How much more with the Health system have to spend to keep us healthy if this gets approved. I don’t want to see my old age suffer because someone wants to make more money. If money is the issue build something that will benefit the Muskoka area- we need more housing- a seniors home- hey even another campground will bring in money for the life of your family- trust me I know.

On closing I wish to say that I pay taxes on two properties, and my family has a vote up here, I hope that counts for something. Please see your way to not allowing this Pit to become the biggest mistake you will have to live with the rest of your life.

 

Mrs. Linda Tone
Utterson, Ontario

 

MNRF objection letters are to be sent to both addresses or emails below by July 10, 2017.

Objection letters must contain the objector’s complete postal mailing address where a response can be delivered, or the objections will not be considered acceptable.

You may wish to reference Technical Reports filed with ToML:
http://stopmuskokapit.ca/reports/technical-reports-documents-for-lippa-pit-and-quarry/

 

Addresses for Objection Letters:

The Applicant:
Frank and Elizabeth Lippa
c/o Skelton Brumwell & Associates Inc.
93 Bell Farm Road, Suite 107
Barrie, Ontario
L4M 5G1

Attention: Caitlin Port, RPP
e-mail: cport@skeltonbrumwell.ca

MNRF:
Ministry of Natural Resources and Forestry
Parry Sound District, Bracebridge Field office
Ministry of Natural Resources and Forestry
1350 High Falls Road,
Bracebridge, ON, P1L 1W9

Attention: Jeff Schosser, Aggregates Inspector/Specialist
e-mail: MNRF.BRA@Ontario.ca

 

Aggregate Resources Act
Form 1 – Notice of Application for a Licence

Frank and Elizabeth Lippa of 17 Haas Road, Etobicoe, Ontario, M9W 3A1, hereby gives notice that an application has been made for a Category 1 & 2, Class ‘A’ Licence, to excavate aggregate from a pit and quarry (below the established water table) of 54.8 hectares (135.4 acres), located in :

1089 Butler Mill Road, Rosseau, ON
North Half of Lot 4 and Part of Lots 4 and 3, Concession 4, Geographic Township of Cardwell,
Township of Muskoka Lakes, District of Municipality of Muskoka

This application is for a new pit and quarry. The Annual Tonnage Condition applied for is 200, 000 tonnes.

A detailed site plan and reports for the proposal may be examined at the Township of Muskoka Lakes or at the Bracebridge Ministry of Natural Resources and Forestry office.

Any person(s) wishing to object to this application must send, in writing, their objection with reason(s) to the Applicant and the local office of the Ministry of Natural Resources and Forestry at the addresses below. Note: E-mail submissions are acceptable; however they must contain the objector’s complete postal mailing address where a response can be delivered. E-mail objections which do not contain a postal address will not be considered acceptable.

The Applicant:
Frank and Elizabeth Lippa
c/o Skelton Brumwell & Associates Inc.
93 Bell Farm Road, Suite 107
Barrie, Ontario
L4M 5G1

Attention: Caitlin Port, RPP
e-mail: cport@skeltonbrumwell.ca

MNRF:
Ministry of Natural Resources and Forestry
Parry Sound District, Bracebridge Field office
Ministry of Natural Resources and Forestry
1350 High Falls Road,
Bracebridge, ON, P1L 1W9

Attention: Jeff Schosser, Aggregates Inspector/Specialist
e-mail: MNRF.BRA@Ontario.ca

The last day on which objections may be filled with the Applicant and the Ministry is the 10th day of July 2017.

Note: All information in respect to this application including written support or objections, the names and address of any objector(s) is available for public review for the purpose of this application under the Aggregate Resources Act. In submitting a written objection an objector consents under the Freedom of Information and Protection of Privacy Act to its disclosure for the purposes of the application.

 

 

To All Those Who Love Muskoka

I’ve been coming to our family cottage at Skeleton Lake for more than sixty years, and I have always loved the natural beauty and tranquility of a place that has no equal in my experience.

I was very upset recently, when I learned that Frank Lippa has applied for amendments to the Official Plan of the Township of Muskoka, that would allow him to develop a large-scale pit and quarry, less than 2kms from Skeleton Lake, and very close to our cottage. Over the years, members of my extended family, and friends from around the world, have enjoyed staying at Skeleton Lake, and we have done our best to support the local economy, building cottages and permanent homes, paying property taxes, buying furniture, shopping for groceries, and visiting bars and restaurants.

If the Lippa application succeeds, and the quarry development is allowed to go ahead, this will be devastating, not only to my family, but for all those, who live close to Muskoka Road #3 between Huntsville and Rosseau. On average, more than 100 loads of sand and gravel per day will be carried in large trucks on this small winding road, with 70% of the trucks going towards Huntsville and 30% of the trucks going towards Rosseau. These trucks will pose a serious threat to local residents, and to those tourists, who choose to take this road, which has been designated as a scenic route. The trucks will also pose an ongoing threat to the abundant wildlife in the area, including moose, deer, porcupines and snapping turtles.

Most tourists come to Muskoka to enjoy the natural beauty and tranquility of a place that is renowned throughout the world. These tourists don’t come to see gravel pits and hear dump trucks!

I love Muskoka, and if you love Muskoka, please go to stopmuskokapit.ca, and join me in the campaign to stop the pit!

Tom Newman

Newman’s Bay, Skeleton Lake, Muskoka

 

 

You may not know that our tourism, Skeleton Lake, Lake Rosseau and Lake Joseph are under a horrifying threat by a quarry looking to get started in a key area impacting multiple townships and cities including Huntsville. At 100 metres deep in its centre, our ‘Impact Crater’ Lake is very unique. It is spring fed and uniquely clear. The damage of blasting could forever remove this amazing lake, which runs into Lake Rosseau and Lake Joseph…so the ripple effect could be significant. Want to know more, sign a petition or join us on June 16 at 9 a.m. for a public meeting (FB: StopMuskokaPit). In addition to the broader ecology impact, Aspdin Rd would become the main thoroughfare of approx. 100 trucks a day, 7 days a week. The pit is planned for 1089 Butler Mill Road. Our experience with quarries is specific. We lived in Washago with a quarry several miles away, not as large as the one being proposed, and every day the ground shook the house when they blasted – but that was nothing compared to the damage to the road, which could not be maintained because of poor planning on the town’s part. The volume of trucks was bad enough, but not as bad as when the road had pot-holes. The trucks would rattle so loud it was impossible to ignore – like a shotgun by your ear as the back-end loaders banged against their mounting. Here, in the summer, we have a very busy road with tourist traffic travelling within the region right past our business and home. If the quarry goes in the serene drive may look like Toronto on a weekday at 6:30 p.m.!

All the best,
Sparky

 

 

We have received much information re the above quarry/pit. To our horror it is unbelievable that the township is seriously considering their proposal/rezoning.

How could council even consider changing a zoning that was designed to protect the environment & most importantly the safety of your constituents.

A) The quarry is not outside the 2 km boundary of the water front set back.
B) The total disregard for the environmentally sensitive zoning that exists around the site, which your predecessors had the foresight to establish.
C) The persons who live on Muskoka 3 will have life altering consequences. With the proposed heavy transport truck traffic, children riding their bikes, recreational runner/walker/cyclists will be put at severe risk if you make these absurd amendments
D) The damage to the tourists industry will be catastrophic. People come from all over the world to enjoy & experience MUSKOKA.
E) The safety of Children getting on & off school buses are more than enough reason to turn down this rezoning.
F) Muskoka 3 is not a provincial highway & is not built to with stand the volume of trucks proposed. Who will be responsible for the major road repairs that will occur.

Five generations of our family have made Skeleton Lake our place of solitude during all four seasons on a lake that is second to none. We totally disagree with the development of the pit and quarry that will destroy the tranquil natural habitat and surrounding area. There is a reason why this area is currently not zoned for this intrusive industry and associated business.

Skeleton Lake has a natural limestone base. To have blasting in less than 2 km will crack the natural stone, allowing contaminants/mercury into a pristine lake. It is presently the only lake in muskoka that does not have mercury contamination.

Stop it now before it is too late.

Paul & Deborah Horn