A March haul route study for the proposed quarry near Rockwood provided “misleading” data, according to the Concerned Residents Coalition (CRC).
At the May 4 Guelph-Eramosa council meeting CRC members Doug Tripp and Perry Groskopf made a presentation about the recently-circulated study from Cole Engineering on behalf of pit proponent James Dick Construction Limited (JDCL).
The CRC wrote a report in response, outlining concerns with the methodology and execution of the JDCL report.
One of Tripp’s concerns surrounded the “creative use of averages.” The study used the Erin pit as a “proxy pit” to estimate potential truck traffic that could be created by the Rockwood quarry because the Rockwood pit application is for a 700,000 tonnes of aggregate and the Erin quarry has a license for 723,000 tonnes per year.
The Cole Engineering study suggests the average truckload would be 33 tonnes and estimated that there will be 21,213 truckloads per year. With the operation running for 12 hours a day, six days a week, from 6am to 6pm there will be, on average, about 69 truckloads a day, according to the study, Tripp said.
The estimated distributions for hauling, Tripp noted, are as follows: as little as 2 per cent in February and as much as 14% in June and August; 3% on Saturday and as much as 22% on Monday; and as little as 9% between 5 and 6pm but up to 12% at 8am, 10am and 12pm.
The Cole Engineering report states the pit will have minimal impact, with an average of 14 truck trips during the peak period of the morning dispersed over several haul routes.
When calculating his comparisons, Tripp did say his data also assumed the trucks used will be 10-wheel tandem dump trucks, just as the haul route study assumes.
However, he used a 16-tonne load rather than a 33-tonne load like in the study.
“Now I’m not sitting here to say that all of the trucks will be this truck,” he said. “Clearly it will be a mixture of different kinds of vehicles, they’ll have contractors that have their own fleet but it won’t be all tractor-trailers.”
Tripp also noted that the majority of the work will likely occur over a five-day week, not a six-day week like the study suggests.
“I adjusted the proponent’s data for truckloads and therefore truck trips to adjust for this unfortunate use of daily averages to suggest that 97% of the activity takes place in five days, so I adjusted for that to get a more realistic impression of what’s happening on the weekdays,” he said.
Using this math, Tripp said he estimates that peak activity will occur in August with 552 trips, whereas the study suggests it will be 268 trips.
Similarly, he said the numbers differed based on hourly estimates. While the study focused on averages, a low of 2.83 trucks per hour at 4pm and a high of 16.5 trucks per hour around noon, Tripp said it was the peak period of truck traffic that should be the focus.
“What we’re going to have to live with and the infrastructure has to deal with is peak loading, not average loading,” he said.
“And so even in their data, the maximums are significantly higher than the averages.”
In this case the Cole Engineering study suggested a maximum of 26 trucks per hour.
“Using our data … the averages of course are higher but more importantly, the maximum range up as high as 66 trucks an hour,” he explained.
“Approximately it’s a truck a minute.”
These higher averages also mean changes to the impact on traffic.
According to the Cole Engineering report 95% of the truck traffic will go east on Highway 7 to Acton (about 63 trucks an hour), 25% will go north (about 16 trucks an hour), 10% will go through downtown Acton (about six trucks an hour) and 34 trucks will go north and south on Regional Road 25.
Tripp went on to explain that the study shows the heavy vehicle traffic on Regional Road 25 (the baseline data) would rise 1%, from 7% to 8%.
However, Tripp explained that actually means there will be approximately 14% more trucks on the road. The CRC numbers showed the number of trucks traveling on the road will increase to 42%.
“Not, in our view, inconsequential,” Tripp said.
The study also said it wasn’t necessary to address portions of the terms of reference. Tripp pointed out this means the engineering firm didn’t address the baseline conditions and they chose not to examine land use plans in either municipality.
He said the impact on the social environment, the air quality, the agricultural assets in the area, cultural resources and characterization of the road were also not addressed.
“They chose not to develop their evaluation approach with the municipalities,” he said.
“That was something that one would think would have been at the front end of the study but they chose not to consult with council and staff and the other municipalities to develop their evaluation approach.”
He said JDCL also didn’t compare, evaluate and recommend preferred haul routes.
“They basically put out this distribution of routes and that’s about it,” he said. “They didn’t say anything about the effects of traffic on these routes and what mitigation would be required for those routes.”
Also, the Cole Engineering report indicated there was only room on the site for one truck to wait before the gates open at 5:30am and drivers will not be permitted to arrive before the 6am opening time.
Once the quarry is open in the morning the study indicates there is on-site space available for truck queuing so they won’t line up on the road. At the busiest point in August the study said there would be approximately 115 loads per day while in June it would be 113 and in November it would be 99.
“(That) there will be discipline applied to trucks and truckers who arrive early is not a lot of comfort, but maybe even more importantly, if the traffic is anything approaching what we’re suggesting it is during the operating day it’s hard to imagine how trucks can fail to have to line up to get in.”
According to CRC data, trucks could be arriving at the pit once every two minutes during peak periods.
“I’m not a gravel guy but I doubt that it’s possible to turn a truck around bring it in, load it, weigh it, do the paperwork and get back out in two minutes,” Tripp said. “So our view is that it’s inevitable that there will be queuing on the sixth line, Highway 7 and who knows where, as trucks are waiting to get into the quarry site.”
The CRC provided its report to the technical advisory committee and is recommending a thorough peer review be conducted.
