The proposed gravel pit is immediately adjacent to our village, situated as it is on the west side of Harrington. The negative impacts and problems associated with gravel pits, and this gravel pit in particular, will be borne by the residents of an otherwise beautiful, but increasingly less peaceful rural village. 20 residences sit within 500m of the pit. A further 20 are within 1000m distance, and more just beyond that. An 1869 stone schoolhouse, operating as a community centre with Registered Charity status, is immediately across the road. Two recent CHER studies, one for the schoolhouse (2023), and the other for the Harrington Conservation Area (2021), recommend that these areas or structures are deserving of designation by Zorra Township and/or Oxford County under the Ontario Heritage Act. We believe a settlement area is no place to situate a gravel pit.

Gravel pits are dusty places. Airborne dust created by equipment as it extracts, screens and crushes gravel, and then loads gravel onto dump trucks will be carried and deposited throughout our village by the prevailing westerly winds. This will also extend along haul routes as the extracted gravel is distributed.Damage to the respiratory health of many individuals in our community will result. 

Dust suppression cannot be addressed as the applicant states. Spraying water or other dust suppressant chemicals on the pit floor will help only slightly (while contaminating groundwater).

The pit is close to the village but will also begin operations right at the corner closest to the road. Situated overlooking the village, the noise will have no barrier.

The consultant, Harrington McAvan’s, noise mitigation strategies are inconsistent with actual noise level readings from other gravel pits, including pits owned and operated by the applicant. We believe our noise consultants will demonstrate that noise mitigation strategies are unrealistic and over-optimistic. The applicant’s consultants also do not address the noise that will be created by trucks leaving the pit. We have taken readings of 101.8dB produced by gravel trucks pulling out from the intersection of Conc. 29 and Rd. 96. These identical noise levels will be produced at the gravel pit entrance, and they are beyond acceptable levels set by the Ministry of Environment, Conservation and Parks.

The traffic study results submitted by the applicant conclude that pit-related traffic operations are expected to have minimal impact on existing local traffic. We have requested but have not received a traffic study apparently carried out by RJ Burnside for the applicant. This “study” does not address the significant existing traffic and, in particular, the transport trucks on Rd. 96 coming from the west down the hill into Harrington where the pit entrance is to be located. From the crest of the hill to the pit entrance is only 350m. There is a significant hazardous collision potential as fast-moving transports meet crawling dump trucks at the bottom of the hill. The “study” has not addressed this glaringly obvious hazard. The “study” also ignores the recent 2023 designation of Harrington as a “Community Safety Zone”, addressing our longstanding concerns regarding traffic volume, speeding, school bus stops, nature school activity and pedestrian activity. Residents who currently encounter a large volume of truck and other traffic, will now have upwards of a further 20 dump trucks per hour (into and out of the village) driving through Harrington.

The Mineral Aggregate Resources section of the Provincial Policy Statement on land-use planning states that “extraction shall be undertaken in a manner which minimizes social, economic and environmental impacts.” The above-noted impacts have been only slightly mitigated (noise, dust) or not at all (traffic). And meanwhile, the economic impacts have been ignored. Our property values will be significantly undermined by having a gravel pit next door. The applicant did not submit an economic impact study that addressed the economic pluses and minuses of establishing a pit in our community. Studies show that properties within 500m of a gravel pit can lose upwards of 25% of their value. Properties within 1000m of a pit can lose upwards of 15% of their value. Taking a very cautious approach to using these percentages, and substituting 12.5% and 7.5% respectively, with an average value of approx. $750,000 each, the 20 closest houses to the proposed pit will lose almost $100,000 each in value; the next 20 closest will lose approx. $56,000 each - a total loss to Harrington property values of approx. $2.9m. MPAC accepts proximity to a gravel pit as grounds for seeking reassessment. That is also a potential loss of tax revenue to Zorra.

The pit site is within an area mapped by UTRCA as a Highly Vulnerable Groundwater Recharge Area. Village residents rely on wells as shallow as 12’, while others have artesian water flowing naturally into their homes. It is alarming to read in the GeoTech Report that the applicant has not asked to know how much gravel sits above the water table, and that only three years of water monitoring are offered. A below water extraction licence will almost certainly be sought after three years, imperilling our village residential wells.

This pit proposes to mine aggregate within meters of Road 96 and Sideroad 31. Trees, bush areas, and grassland will be cleared and replaced with dirt piles as high as 7 meters. The land will be stripped bare for extraction, which will be clearly visible from the road [ADD MORE HERE]

Without sunset clauses, i.e., defined limits on the life of the operation after which a transition to the planned after-use is undertaken, there is no guarantee the lands will ever be recovered for promised rehabilitation to previous or compatible uses as often cited by site plans. For municipalities, the loss of revenues from land reclassification by MPAC can be a permanent concern. It could be active for years, languish waiting for more extraction as the owner sees fit, and never be restored. 

Aggregate advocates point to a very few rehabilitation projects often completed with public money and/or work by community or children’s groups while ignoring the vast majority of pits left for decades under licence or from before the current Act which have not seen rehabilitation. Restoration is not merely rewilding. The success of rehabilitation, e.g., to agricultural purposes, is contested by the National Farmers’ Union which points to lost soil fertility.

A “Cultural Heritage Evaluation Report” has not been conducted as required by the MNRF approval process, only an archeological assessment, making the applicant’s submission incomplete. The applicant has submitted documentation maintaining that the project area has not been identified under the Ontario Heritage Act as being of cultural heritage value, when in fact there are two recent CHER studies pertaining to the project area that declare a cultural heritage value. Because a “Cultural Heritage Evaluation Report” was not conducted, there has not been an evaluation confirming what we know to be the presence of “one or more built heritage resources or cultural heritage landscapes”. When the presence of these attributes is confirmed, there will be a further requirement for a “Heritage Impact Assessment”.

Finally, one of the built heritage resources that hasn’t been identified is the 1869 schoolhouse. The registered charity operating this schoolhouse as a community centre has responded to funding challenges by developing a plan to sever and sell two residential building lots (directly across from the site). The community’s hope has been that this will produce approximately $500,000 in revenue to either upgrade the building or to gift the funds to the Oxford Community Foundation for investment in Zorra Township community betterment and charitable activities. The lots are now likely worthless, with great loss to Harrington and Zorra Township. Maps prepared by the applicant’s consultants show two “1876” schoolhouses, where there are no schoolhouses, while the actual 1869 schoolhouse directly across from the site is labelled “School(1914)”. 

All farmland is precious. Prime agricultural land is at record prices in Ontario, and of vital importance for crops and sustainability of food production. Oxford County boasts one of the highest per acre values of farmland in Ontario.