Background. The applicant (Murray Group) for the proposed Bowman Pit extension (the Shoemaker Pit) have submitted a planning document which includes an SEI (Statement of Environmental Impact) which was prepared by a Kitchener company called Limnoterra Inc. In the present report we give concerns about the Limnoterra SEI with regard to the proposed site and the surrounding land, streams, water flow and water table.

In some cases, related concerns are given about the Site Plan (by Geo. Davis & Associates), the Planning Report (by Stovel & Associates), or the application to MNR (Section 9 report) (by Stovel & Associates). Following are points of concern.

Wetland preservation. The applicant treats the central wetland of the proposed pit as Provincially Significant, which is appropriate because this wetland is on the list of wetlands to be classified by MNR, and is expected to be designated as Provincially Significant. There is no discussion in the Limnoterra report of how this wetland is to be preserved. For example: How is its hydroperiod (variation in water level, etc., during the cycle of a year) to be preserved? Plan A in the site plan removes a major part of the northeast slope leading to this wetland, and an explanation is essential to explain how this removal does (or does not) effect the wetland hydroperiod. Plan B is even more extreme in that it apparently removes almost all of this slope. We believe that without a careful analysis to show that this wetland is (or is not) preserved, the SEI is incomplete. We request a scientific analysis of the preservation of this wetland. We believe this is a serious omission from the SEI, and that this information must be supplied to allow a careful and reasoned evaluation of the environmental impact of this proposal.

Cold creek preservation. According to the Site Plan prepared by Geo. Davis & Associates, the excavation in the new pit is to extend to be within approximately 35 metres of Middlebrook Creek, which is a cold water creek. The Site Plan shows the removal of approximately 25 meters of the slope leading down to the creek at this same point. There is no discussion in the Limnoterra report to show how this excavation will (or will not) affect the flow, temperature, etc, of this cold water creek. We request a scientific analysis of the preservation of this creek, in light of this close-by excavation. We believe this is a serious omission from the SEI, and that this information must be supplied to allow a careful and reasoned evaluation of the environmental impact of this proposal.

Hydrogeological analysis. Hydrogeology is a mature, scientific field. For a proposal such as the one presented by the applicant, in which there are close-by and sensitive environmental features (two cold water creeks and a wetland), it is essential to have a clear and distinct hydrogeological analysis. In other words, if one and a half million metric tonnes of gravel are going to be removed next to this environment, how do we know this environment is not going to be affected? The Limnoterra Report does not separate hydrogeological analysis from their general discussion. We request a clear and distinct hydrogeological analysis by a hydrogeological expert. We believe this is a serious omission from the SEI, and that this information must be supplied to allow a careful and reasoned evaluation of the environmental impact of this proposal.

Expert status. We understand that Limnoterra is acting as an expert in their preparation of this SEI. It seems appropriate therefore, for Limnoterra to submit the names of persons who have prepared the various parts of the SEI report along with the relevant biographical information (their publications, past experience, etc.) for these people. This information should allow the public and Township Councillors to gauge the expertise of Limnoterra by direct evidence rather than by hearsay.

Height above watertable. The Site Plan proposes excavation to one metre above the watertable. It appears that new MNR regulations allow excavation only to 1.5 (one and a half) metres above the watertable. It may be, that in an environmentally sensitive area such as this site, 2 metres are more appropriate. We request clarification as to whether this pit will be treated under old regulations or new regulations.

Figure correction. In Figures 7 and 8 of the Limnoterra report, showing cross section lines for bore hole information, some of the bore holes are mislabelled. We request that the applicant correct these figures. We believe that it is difficult to correctly interpret the waterflow and watertable information in the presence of the mislabelling in these figures.

Incorrect map. Map 1 from the Planning Report by Stovel & Associates presents what appears to be an aerial photograph of the Shoemaker site, with its surrounding area. This Map has an error of distortion, apparently due to gluing two photographs together without properly aligning these photographs. The result is: a "strip" of land about 50 metres wide simply disappears on the right side of the Map. The result is that the Map shrinks Mr. Shoemaker's back field (part of the site) which has an actual width of approximately 70 metres to approximately 20 metres wide as it appears on the Map. We request that a corrected Map be supplied in the report to avoid possible misinterpretation regarding the site.

Marking of pit site. The figures in the Limnoterra report (for example, figures 2, 3, 4, etc.) consistently (we believe) show the northeast boundary of the site incorrectly. In particular, these figures show the boundary running generally along the direction of Middlebrook about 25 to 35 meters (approximately) away from the tree line along Middlebrook Creek. We believe that this is incorrect, in that the line is actually directly along the tree line. We request that corrected figures be supplied in the report to avoid possible misinterpretation regarding the site.

Limit to excavation. In figures 2, 3, etc. of the Limnoterra report, it appears that the excavation in the Darrington pit has extended beyond the limit of the Darrington pit boundary (on the southwest side, near Carroll Creek). We request either an explanation of the excavation beyond the site boundary, or else a correction of the figures.

North direction marking. In Pilkington Township, the alignment of lots is very close to 45 degrees from true North. The Limnoterra figures consistently show North in a westerly direction rather that as actual North. It would seem helpful to correct this problem.