January 16, Mr. David Trotman Mono Centre Road Mono, ON L9W 6S3
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1 Ministry of Municipal Affairs Ministry of Housing Ministère des Affaires municipales Ministère du Logement Municipal Services Office Bureau des services aux municipalités Western Ontario de l Ouest de l Ontario 659 Exeter Road, 2 nd Floor 659 Exeter Road, 2 e étage London ON N6E 1L3 London ON N6E 1L3 Tel.: Tél. : Toll-Free: Sans frais : Fax: Téléc. : January 16, 2018 Mr. David Trotman Mono Centre Road Mono, ON L9W 6S3 david.trotman@townofmono.com Re: Town of Mono Official Plan Amendment No and Zoning By-law Amendment No (Greenwood Violet Hill Pit) Provincial One Window technical review Ministry of Natural Resources and Forestry, Ministry of the Environment and Climate Change, and Ministry of Transportation comments Dear Mr. Trotman, Thank you for circulating the above noted Planning Act applications relating to the proposed Violet Hill Pit to the Ministry of Municipal Affairs. These files were further circulated through the One Window Planning Service to the Ministry of Natural Resources and Forestry (MNRF), Ministry of the Environment and Climate Change (MOECC), and Ministry of Transportation (MTO) for review and comment. Provincial staff offer the following One Window technical comments for the consideration of the Town of Mono, the County of Dufferin, and the applicant/owner. MINISTRY OF NATURAL RESOURCES AND FORESTRY (MNRF) MNRF staff have reviewed the Planning Report, dated June 29, 2016, prepared by Ron Davidson, Land Use Planning Inc. in support of the application to amend the Town of Mono Official Plan to redesignate the subject lands (located at 30th Sideroad between the 3rd and 4th Lines EHS) from Rural to Extractive. The applicant, Greenwood Holding Limited/ Ontario Limited (Greenwood) has applied to MNRF for a Class "A" Category 3 licence under the Aggregate Resources Act (ARA). MNRF has previously provided comments on the ARA application as follows: MNRF reviewed the Natural Environment Level 1 and 2 Technical Report, dated June 2016, and site plans, dated January 2016, in support of the application for a licence under the ARA and provided comments in a letter to Greenwood on November 10, In this letter, MNRF advised that they objected to the ARA application until additional information was provided with respect to Butternut and
2 that appropriate measures would be undertaken for the protection of this species in relation to the proposed aggregate extraction to the satisfaction of MNRF. MNRF reviewed a response letter, dated January 19, 2017, from Greenwood which addressed the concerns in MNRF's letter of November 10, MNRF advised Greenwood in a letter dated February 13, 2017 that MNRF was satisfied that appropriate measures would be undertaken for the protection of endangered and threatened species in relation to the proposed aggregate extraction. MNRF requested that specific notes be placed on the site plan which requires the operator to demonstrate to the satisfaction of MNRF that Endangered Species Act requirements related to the protection of Butternut and their habitat have been met. MNRF requested revised site plans for review and advised that once MNRF had confirmed that noted changes had been made on the site plans with respect to Species at Risk, MNRF would remove the objection to the ARA application. MNRF has not received revised site plans from Greenwood at this time, although MNRF has been sent information by Greenwood related to an alternative exit option that was being considered. MNRF notes that the Town of Mono has received draft site plans (July 7, 2017) which differ from those provided in the ARA application and which incorporate this alternative exit option. Until such time as MNRF has received revised site plans and has confirmed their satisfaction with the revisions, MNRF cannot clear their objection to the ARA application. The above comment applies to MNRF s position related to the ARA application for the proposed Violet Hill Pit. With respect to the proposed Planning Act applications, MNRF has no comments or concerns. MINISTRY OF THE ENVIRONMENT AND CLIMATE CHANGE (MOECC) It is understood that Greenwood Holding Limited/ Ontario Limited has made application for an amendment to the Town of Mono Official Plan to permit the extraction of sand and gravel on the subject lands. Extraction is anticipated to occur at a rate of 1,000,000 tonnes/year and is to occur above the water table. Accordingly, a Class A Licence is also being sought from the Ministry of Natural Resources and Forestry (MNRF). In accordance with a Memorandum of Understanding between MOECC and MNRF, MOECC does not review Level I and II hydrogeological reports when the proponent indicates that extraction is going to occur above the water table as in this case. Crushing, screening and washing are also contemplated as part of the operation. Concrete and asphalt will also be brought onto the site for recycling. The Planning Report mentions that approvals under the Ontario Water Resources Act will be required for the processing of aggregate and recycled materials. However, it has not been clearly stated as to which approvals are going to be required. Therefore, as water will be required in order to conduct aggregate washing, if more than 50,000 L/day is to be extracted for this purpose, a Permit to Take Water (PTTW) will be required pursuant to Section 34 of the Ontario Water Resources Act. Discharge criteria for the used washwater will also be subject to MOECC approval in order to be adequately protective
3 of the receiving water. These criteria may be covered by the PTTW, or may be within a separate Section 53 (sewage) approval. Please note that while a noise assessment was prepared, it has not been reviewed as, by agreement between MOECC and MNRF, MOECC does not review noise studies for areas that are covered by an ARA licence and which will be subject to provincial standards. A series of standardized conditions relating to noise, and based on the site specific conclusions of each noise study are applied to the licence by MNRF. MOECC notes that the Valcoustics report was peer-reviewed by RWDI, and that RWDI was in general agreement with the noise mitigation measures proposed by Valcoustics. An air quality impact report was also completed and peer-reviewed. While there is no review of these reports for the purpose of the ARA licence or the required planning approvals, MOECC will likely be involved in the review of the air and noise reports as the crushing/processing and aggregate recycling will likely be subject to approval by MOECC pursuant to the Environmental Protection Act, to ensure that emissions into the atmosphere do not exceed established limits. MINISTRY OF TRANSPORTATION (MTO) The following documents have been reviewed by MTO: Planning Report dated June 29, 2016, prepared by Rob Davidson, Land Use Planning Consultants Inc. Revised Traffic Review CCTA File Dated July 5, 2017 Haul Route Amendment Letter Dated July 7, 2017 Revised Site Plans Draft 07 July, 2017 Letter from Mono Township Complete Application OPA and ZBA dated August 10, The MTO has been reviewing and commented on this development proposal since July 10, The proposal (and applications) have been considered and reviewed in accordance with the requirements of MTO s highway access policies, criteria, and the Public Transportation and Highway Improvement Act. MTO is only supportive of the proposed development proposal if acceptable site access and haul route is achievable and the proposed quarry does not negatively impact the operational functionality of Highway 89. MTO has previously provided comments on the above noted Planning Report (dated June 29, 2016) and application. In regards to direct Highway 89 access, MTO would like to reiterate the comments provided on June 14, 2016; July 10, 2015; and August 9, MTO is not supportive of direct Highway 89 access for the following reasons: A lot of record with highway frontage, which also has frontage on a public road, shall obtain its access connection from the public road. The subject lands have
4 frontage on multiple public roads and the proposal is to have all access from Highway 89. The proposed access connection has substandard (reduced) sight lines for both motorists entering the highway and motorists already on the highway. MTO requires that new highway access connections shall meet the minimum sight distance (visibility) requirements. Highway 89 along the subject lands is a class 2B Arterial, Controlled Access Highway. In order to qualify for a new (or upgrade to) commercial/industrial access on this class of highway, a minimum separation of 1600m from other public road/commercial access is desired (800m min.). The proposed access is located 460m west of 4th Line E. and 680m east of 3 Line. In review of the revised haul route, site plan and traffic study (dated July 5, 2017), MTO provided the following comments to the Town of Mono on August 14, 2017: MTO generally agrees with the revised access location (along 3rd Line East) and the findings of the Traffic Review, however, the following are items that will require further review and discussion: Page 6, Last sentence: For speeds greater than 60 km/hr, GDSOHM E.7.1 recommends a right turn taper with a parallel lane (a total length of 165 m). This will need to be evaluated and discussed further. Page 7, last sentence of first paragraph: A 1.2 Down Grade Factor must be applied to the deceleration length, equaling a total length of 326 m for the left turn lane. The total distance rd rd between the CL of 3 Line East and CL of 3 Line is 335 m. Page 7, first bullet: A 1.5 m offset beyond the intersection is also required for the runout lane. Page 10: Suggests consideration for staged road improvements. MTO is not supportive of staged improvements, as the traffic mitigation measures (turning lanes etc.) are required to be in place before truck traffic is moving to and from the development site. Analysis: If the proposed development application commences, further details related to design including (but not limited to) site line analysis and road geometry will need to be conducted and submitted as part of the Environmental Assessment and design. Stormwater Management Report To ensure that stormwater runoff from this property does not affect MTO s highway drainage system or highway property limit, MTO requires the owner(s) to submit a stormwater management report along with grading/drainage plans for the proposed development for review and approval as a condition of MTO permit approvals. The
5 owner's consultant should refer to the website at: acts for MTO drainage requirements to assist in preparing their report. MTO Permit requirements The following MTO permits will be required prior to commencement of any site activities: Building and Land Use permit: For any grading, (non-direct) entrances or constriction activities within the MTO permit control area. Sign Permit: For any site signing visible from Highway 89. Encroachment Permit: For any works, including utility installations or connections, within the highway property limit. MTO permits are only available for the subject development if approval from the local municipality and all agencies having jurisdiction have been received. The owner should be aware that highway improvements identified from MTO s review and analysis of the traffic study will be the financial responsibility of the owner. A Legal Agreement will be required to be entered into between the owner and MTO, whereby the owner(s) agrees to assume financial responsibility for the design and construction of the new street/entrance and all necessary associated highway improvements. MTO would appreciate receiving a copy of the Official Plan Amendment, if approved, for their records. MTO s Transportation Planning and Infrastructure The following comments relate to MTO s transportation planning and infrastructure mandate, applicable provincial policies and plans, including the Provincial Policy Statement, 2014 (PPS), Growth Plan for the Greater Golden Horseshoe (the Growth Plan), Greenbelt Plan, Oak Ridges Moraine Conservation Plan, and MTO guidelines, such as MTO s Transit-Supportive Guidelines, Freight-Supportive Guidelines (FSG), and Ontario s Cycling Strategy. MTO has circulated this draft amendment and supporting documents to the Environmental Policy Office, and offer the following coordinated comments: Provincial Initiatives There are a number of provincial initiatives underway that may impact the policies, strategies, and actions proposed in the draft OPA and future land use and transportation policies: Completion of the Coordinated Land Use Planning Review: The Coordinated Land Use Planning Review was completed on May 18, 2017, and the Growth Plan for the Greater Golden Horseshoe, Greenbelt Plan, and Oak Ridges Moraine Conservation Plan came into effect on July 1, The conformity work for upper and single-tier municipalities is to be completed by 2022.
6 Greater Golden Horseshoe (GGH) Transportation Plan: MTO is undertaking a transportation study to develop a long-term multimodal transportation plan for the GGH. The work will advance multimodal transportation planning in the GGH and provide planning direction to transportation agencies and service providers for all modes, including highways, railways, regional transit systems, cycling and walking. The planning will take place over the next two years and is anticipated to be completed in early MTO would also appreciate the Town of Mono to consider the following comments: Noise Mitigation Considerations MTO notes that the planning report provided by the consultant states that noise impacts of up to 5 dba are predicted. As per MTO s noise guide, Environmental Guide for Noise (2006), noise mitigation measures must be considered for an undertaking that increases future sound levels by 5 dba or where the absolute future sound level is greater than 65 dba. Please consider including noise mitigation measures for this application. Traffic Flow Considerations MTO notes that there is no information related to the increased traffic flow (e.g. additional number of trucks per day) in the report, only that time of operation would be used as a mitigation measure. Please consider including greater details regarding increased truck traffic flow in this area, especially given the rural nature of this property. Freight Movement Considerations MTO s Freight-Supportive Guidelines may be a helpful resource to support the Town s policy objectives. Where appropriate, consideration may be given to the Freight-Supportive Guidelines for this application, as it relates to the proposed haulage route and design. The guidelines can be found here: Examples of relevant sections are as follows: o Chapter 3.10 on Rural Sites: This chapter specifically outlines considerations of the impact that freight movements will have on the surrounding rural areas. o Chapter 4.1 on Access and Intersections: This chapter discusses key considerations such as truck acceleration and decelerations as well as truck turning movements. This is relevant to the section of the planning report that suggests a direct access route from the pit to Provincial Highway 89.
7 MTO recommends the above noted items be addressed and/or included in the OPA. MTO staff would be pleased to discuss any of the above comments further: Please contact Mr. Zolt Katzirz, Corridor Management Planner, West Region Highway Corridor Management Office in London at (519) or via at With respect to comments specific to MTO s Transportation Planning and Infrastructure, please contact Mr. Michael Casey, Manager, Provincial Planning Office, Transportation Planning Branch at (416) or via at michael.casey@ontario.ca. Thank you again for circulating these applications to the Ministry of Municipal Affairs. Please do not hesitate to contact the undersigned should you have any questions or concerns. Regards, Tyler Shantz, BES Planner Ministry of Municipal Affairs Municipal Services Office Western 659 Exeter Road, 2 nd floor London, ON N6E 1L3 T: E: Tyler.Shantz@Ontario.ca Cc ( only): Randall Roth, WSP Erick Boyd, MMA Kim Benner, MNRF Barbara Slattery, MOECC Zsolt Katzirz, MTO
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