The Township of Melancthon…

The Township of Melancthon does not support the approval of the proposed PTTW Amendment at this time.

As Ministry staff are aware, the subject site is also the subject of an ongoing licence application under the Aggregate Resources Act. It would be inappropriate for the MECP to reach conclusions on the PTTW Amendment that would prejudge technical questions that are still under review in the context of the ARA application.

In addition, there are inconsistencies between what is proposed in the PTTW Amendment and the current ARA licence. These discrepancies should be clarified prior to any approval.

For example, the PTTW Amendment would permit 365 days of taking per year whereas the current aggregate license only permits processing 6 days a week and excludes holidays (i.e. less than 365 days a year). The current PTTW authorizes takings up to 230 days per year. Also, the maximum volume sought per day (5,000,000L) does not appear to line up with the proposed rate of taking which is 6000L/min for 11 hours per day, equalling to 3,960,000L per day. Based on these discrepancies, the PTTW Amendment appears to go beyond what would be needed under the current licence. Finally, the application does not explain why more than double the current rate of water taking is required to support continued operations under the current licence.

The Township’s hydrogeology consultants have undertaken a preliminary peer review of the PTTW Amendment supporting documentation (see attached) and have raised a number of technical questions. In particular, while aggregate washing operations are stated to be "above the water table", the wash ponds are described in the supporting documentation as being constructed below/within the overburden groundwater table, and the existing/proposed water taking is in fact from the shallow overburden aquifer (which is exposed by the excavated wash ponds).

In the context of the ARA application, the Township’s peer reviewers are also considering the supporting documentation's conclusion that nearby natural ponds are perched above the water table. Given the described stratigraphy in the area they are still considering whether or not this is a supportable conclusion. In their opinion, there is insufficient information in the PTTW Amendment application to justify the MECP reaching any conclusion on this point until the full ARA review process has run its course.

The process of reviewing this application has been complex and time consuming because of the potential for interconnection with the ARA application, inconsistencies in the application itself, the volume of information submitted in support of the ARA application and the questions coming out of our review so far. As a result, the Township is requesting sufficient time extensions to allow for fulsome and thorough review of the two applications to facilitate a full understanding of any interconnection and to ensure the information presented in both applications is clear, consistent, and accurate.

In summary, the proposed PTTW Amendment is not consistent with the current ARA licence for the Strada site. No justification has been provided for the proposed PTTW Amendment in the context of the current licence. The Township is concerned that approval of the proposed PTTW Amendment could be seen as an endorsement of certain opinions and conclusions regarding the local groundwater regime that are important to the ARA licence application (e.g. the perched nature of wetlands) without the benefit of a complete review under the ARA process. For these reasons, the Township suggests that the PTTW Amendment should be deferred to be considered together with the proposed ARA licence application.