Re: EBR Registry # IB05E3033 - Approval of an amendment to the Niagara Escarpment Plan
Lake Ontario Waterkeeper strongly opposes amending the Niagara Escarpment Plan to permit the establishment of a licensed quarry. Reasons for this opposition are as follows:
Opening up new areas on the Niagara Escarpment for mineral resource extraction undermines the very purpose of the Niagara Escarpment Plan: ?To provide for the maintenance of the Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such development occurs as is compatible with that natural environment.?
Creating new quarry land on the Escarpment is also contrary to the objectives of the Niagara Escarpment Plan. New quarry land will not protect unique ecologic and historic areas. New quarry land will not maintain or enhance the quality and character of natural streams and water supplies. New quarry land would not provide opportunities for outdoor recreation. New quarry land will not maintain or enhance the open landscape character of the Niagara Escarpment or preserve the natural scenery. New quarry land will not create public areas or facilitate public access to the Niagara Escarpment.
Waterkeeper is particularly concerned that the Niagara Escarpment Plan may be amended in order to serve the desires of industry rather than the interests of the Escarpment. This is in clear contradiction to Objective 5, which is, ?To ensure that all new development is compatible with the purpose of the Plan.? Clearly, industry should conform to the goals of the Plan, and not vice versa.
Waterkeeper?s interpretation of the Niagara Escarpment Plan is consistent with other provincial and federal environmental initiatives. For example, source water and greenbelt protection strategies clearly recognize the importance of protecting the Escarpment and the dangers of allowing development pressures to eclipse sound environmental planning.
Furthermore, there is no evidence whatsoever to suggest that the protections of the Niagara Escarpment Plan or complementary federal and provincial programs should be abandoned in order to accommodate a new quarry on the Niagara Escarpment.
Waterkeeper notes that the EBR posting itself lacks critical information: There is no justification for expanding quarrying activities. There is no analysis of alternative supplies. Finally, there is no discussion about the potential environmental impacts resulting from increased quarrying activities in the region.
The EBR posting does make reference to a ?rehabilitation? plan. Waterkeeper respectfully suggests that ?rehabilitation? amounts to little more than false charity. No wetlands constructed in the future can compensate for the dramatic, lengthy disruption to the natural ecosystem that the quarry activities would bring today.
In light of the facts outlined above, Waterkeeper asks that approval to amend the Niagara Escarpment Plan not be granted.
In making this request, Waterkeeper supports the submissions of other community and environmental organizations who are opposing the expansion of quarrying activities on the Niagara Escarpment.
President & Waterkeeper