The Ministry of Environment submitted 19 pages of comments to the Ministry of Natural Resources (within the 45 day time frame) regarding Highlands application for an Aggregate license.
Here is the full letter, posted on AWARE-Simcoe's site: http://www.aware-simcoe.ca/images/stories/hydro-g-moe.pdf
Here are the hi-lites:
Page 2
“It is our position that the reports ailed to demonstrate a three dimensional understanding of the geology, hydrogeology and hydrology of the site….”
“Please note that MOE expressed its expectations for a groundwater recharge study during a meeting with Genivar on November 30, 2010. These expectations have not been met to date.”
Page 3
“As such it is not clear whether the modeled flow are representative of actual flows….”
Page 4
“Given the above noted inadequacies and concerns, the ministry objects to the application.”
Page 6
“The reports failed to demonstrate a three dimensional understanding of the geology, hydrogeology and hydrology of the site.”
“The MOE listed its expectations for a groundwater recharge study during a meeting with Jason Baldson of Genivar on November 30, 2010. These expectations have not been met to date.”
Page 9
“Geniver do not appear to understand the palacozoic geology of the site.”
Page 10
“There are inconsistencies between the statements made by Genivar and the evidence recorded in the bore hole logs."
“…though this may be true, this statement is not supported by documented data.”
Page 11
“The data has not been presented in a manner in which to demonstrate this.”
Page 12
“Background datashould be collected for more than two years. This data should be collected over a longer period of time."
Page 13
“This statement is unsupported by data.”
Page 17
“the MOE listed in its expectations for a groundwater recharge study during a meeting with Jason Baldson of Genivar on November 30, 2010. These expectations have not been met.”
Page 18
“Given the simplistic interpretation of the geology, stratigraphy and lack of documented support for much of the geological interpretation, the model hydrostratigraphic units are questions. It is also noted that the density of regional boreholes is not consistent around the proposed excavation.”
There you have it in a nutshel, so to speak.
Their studies would appear to suck!! Like really, really bad.
The Highland's quarry is toast, burnt. Any reasonable person looking at this proposal from the very beginning would know that it can not work, should not be allowed. Their application reports confirm this. We have to hope that the bureaucrats in MNR are not imbeciles, and that they will stop this before any more energy is wasted.
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