Notice of objection filed by Ray Dorn
The Honourable David Anderson, P.C., M.P.
December 27, 2001
Dear Minister Anderson,
Roads are, if one pushes the interpretation of CEPA to an absurd extreme, CEPA toxic. Road construction includes the introduction in the environment of substances (gravel, pavement) that:
The strip of land that is itself a covered over to become a road is indeed a highly disturbed, perhaps destroyed habitat. However, it is not the intent of CEPA to include under its jurisdiction such contained effects of urbanization. The road, the ditch and the narrow strip of land affected by road salt are all confined areas that do not reflect an effect on the overall environment or ecosystem. Like the materials that make up the road, road salts applied to that narrow strip of land should not be considered CEPA toxic. They are encompassed in the road's disturbed habitat.
Sensitive areas may be affected by road salts. These elements are covered under the CEAA. Prior to the construction of major projects, like roads, the CEAA has provisions for requiring an assessment of effects including those on sensitive areas.
39 Bentbrook Crescent
Nepean, ON K2J 3Y1
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