Please replace the earlier…

Please replace the earlier comment this one:

I am writing to register my concerns about the Strada Aggregates application number 025-1082 to take water for aggregate washing at their Melancthon site. I am someone who has spent 50 years with my family toiling to make our rural properties in Mulmur beautiful places to live and see out our remaining years. Like all of my family and neighbours, we are completely dependent on our private wells. Given that we are all in the Pine River Valley, we are likely downstream on the same aquifer that the Strada Melancthon pit is sitting on.

Here are my concerns with the application:

1. Mathematical inconsistencies and lack of clarity:
• maximum rate per minute (litres): 6,000
• maximum number of hours of taking per day: 11
• maximum volume per day (litres): 5,000,000
6000 litres/minute is 360,000 litres/hour. If this is done for 11 hours/day that gives a maximum allowable volume of 3,960.000 litres/day NOT 5,000,000 litres/day!! This is 26% more than what the rate/minute and hours/day specified in the proposal indicates. So are they asking for 5 million litres/day or 3.96 million litres/day?? Over the 10 year duration of the permit, that’s a 3.8 billion litre difference! Such an error in a document of this importance is deeply troubling. It suggests either a lack of due diligence or a disregard for accuracy — neither of which inspires confidence that Strada will responsibly manage or report its water use.

2. Risk to Water table

I see that this proposal has been designated as Category 3 — the highest potential of environmental risk. This alone should trigger rigorous scrutiny. What studies have been done to show that taking this water (be it 3.96 or 5.0 million litres/day) will not have an adverse effect on the water table? Am I correct in thinking that this proposal would not be approved if a study were to show significant risk to our water table?

Even if studies predict a negligible impact, how much faith can we put in them given that hydrogeology is an imprecise and unpredictable science. Unquestionably, there is risk involved. Who bears the risk? Is it the approving body, MNR? Is it our provincial government? Is it Strada? Or is it the landowners downstream of the Strada pit. Landowners who have nothing to gain and everything to lose? Do we need to resort to legal recourse to protect our water or can we trust that the Ontario government has our back?

3. Water quality and contamination risk

Despite the fact this is a Category 3 application which has the highest potential for environmental risk, the proposal provides little to no detail on how wash water will be treated or contained. If sediment ponds are used, are they properly lined and sized to prevent runoff of chemical and petroleum spills, and silt and heavy metal laden water into the underlying aquifer and contaminating it? The proposed flow rate of 5 million litres per day would fill 2 Olympic size swimming pools. Containment failures could be catastrophic.

4. Enforcement of approved practices and limits

Data shows that enforcement actions against noncompliance are rare. It would appear that either the MNR is not mandated or not funded to provide adequate monitoring and enforcement. Given the limited enforcement capacity, there is little to keep potentially harmful but expeditious operational management practices at the pit in check. Since the political will to protect our water is not in place, why are we even considering allowing more water taking which compounds the risk and potentially affects thousands of people who are reliant on the aquifer and the watersheds it feeds?