This lengthy comment was…

This lengthy comment was sent as a letter to relavent employees of MEPC before this ERO posting was published. It differs in content in that names and supporting reference material have been removed.

Dear Sir,

According to PCQ PTTW 7645-AAYS3Y, Port Colborne Quarries Inc’s permit expires on August 31, 2021. Before a new permit is issued to PCQ we want to bring to your attention information that may not have been considered when the current permit was granted and information that may influence the granting of future permits.

Port Colborne Quarries (PCQ) has created an east-west trench that is 1 km long in Pit # 1. Another 0.8 km is added through Pit # 2. They are currently quarrying Pit # 3 that adds another 0.6 km and they recently applied for a permit for Pit # 3 extension which will add another 1.0 km. if a category 2 (Quarrying below the water table) permit is granted. This trench cuts 8 metres into the Onondaga aquifer. In order to keep the pits dry for operations that happen on the quarry floor, water has to be pumped out. The sources of water are precipitation, both direct and from the surrounding recharge area, and flow from the Onondaga Aquifer.

Currently PCQ has PTTW totalling 25,466,400 litres per day. We believe this PTTW should be zero litres per day and still allow PCQ to operate. The rationale for this is that pumps in Pits # 1 & # 2 be removed and the pump(s) in Pit # 3 and Pit # 3 extension have the outlet switched from the Wignell Drain to Pit # 2.

According to Permit 4444 issued by MNRF, Pit # 2 is to be rehabilitated to a passive recreational lake and this was to be completed simultaneously with the commencement of quarrying Pit # 3. It was not done. A small portion of the bottom of Pit # 2 is being used as a haul road to move aggregate between Pit # 3 and processing equipment and scales in Pit # 1.

The plan for the future, as stated in PCQ documents requesting a new permit for Pit # 3 extension, is to move the scales and entrance - exit to Highway # 3 near Carl Rd. The processing equipment is to be moved to Pit # 3. Once these moves are completed, it allows for the pumps in Pit # 2 and the pump in Pit #1 to be removed. There is need for the pit walls to be sloped, according to the Registered 1982 Quarry Agreement between PCQ and The City of Port Colborne, before the pits are allowed to refill to the water table level. Other than the time to do this rehabilitation work, which is long overdue, there is no need to remove water from Pit # 1 and Pit # 2.

The goal is to re-establish the integrity of the Onondaga Aquifer and the supply of quality and quantity of water to the area that it supplies.

We do not know all that you do for the approval of a permit but have gleaned from an appeal by Tiny Township that you follow something referred to as MECP’s Statement of Environmental Values (SEV)….. ss. 7 and 11 of the EBR including:
a) the precautionary principle
b) environmentally preventive and rehabilitative strategies
c) cumulative effects
d) sustainable development
e) transparency, reporting, and engagement principles, and
f) the ecosystem approach.

We can comment on, c, d, and f, with the hope that it helps you with your analysis.

Cumulative Effects

The present permit allows the sum of sump 2,3, & 4 to be discharged into the Wignell Drain. Under maximum conditions this is 18,900,000 litres/day. With the increase in area of pit # 3 extension, there is likely, at some time, to be a need for a 4th sump and an additional similar capacity of approximately 8,000,000 litres. It is easier to visualize this volume if it is converted to 218 litre drums. It would be about 120,000 drums a day. That is a huge volume of water. In the past, and it may still be the case, high water flows caused erosion of the bank north of the St Joseph’s Cemetery on Lakeshore Rd East. Eliminating the flow from the quarry will have a positive effect on the function of the drain.

The interrupting east-west trench, as it is extended, will have a cumulative effect on the surrounding area. The flow through the aquifer is generally from north to south. As the quarry expanded eastward, it affected the volume of water available to residents south of the quarry. It can also affect any resident that is within the drawdown cone created by the quarry. This affect will continue to grow for the next 35 to 40 years. PCQ has purchased Carl Road and will remove it as they quarry eastward. This is unlike the barriers to flow created by Snider Road, and Babion Road which allows Pit # 1 and Pit # 2 to be filled independent of each other. When the pumps are removed, it will progressively re-establish the continuity of the watercourse. Not issuing a PTTW will not stop the extension of the east-west trench which will, in 40 years, exist from Babion Road to Miller Road, and be 1.6 km in length. However, it will reduce the east-west trench effect from Highway 140 to Babion Road, which is a distance of 1.8 km.

Sustainable Development

NWPA acknowledges the need for materials for non agricultural development. We believe that although quarrying is disruptive to its neighbours, it can be done. Our focus is the sustainability of the source of water both in quantity and quality. For this reason, we have requested the MNRF that PCQ be issued a category 1 permit ( quarry above the water table). Such a permit will maintain the integrity of the Onondaga Aquifer. It will reduce the risk of contamination entering the water supply after quarrying is completed and the pumps shut down 40 years from now.

The Ecosystem Approach

The point to be made here is that precipitation falling on land with overburden gets absorbed until the ground is saturated. This recharges the soil and the ground water in the aquifer. Precipitation falling on the hard floor of the quarry becomes runoff immediately and must be pumped. Nature usually takes a more metered approach and allows for a more natural development of the ditch banks ecosystem as well as fish habitat within the water in the Wignell Drain. Fish species have been studied in the drains and the Wignell Drain is a spawning bed for Northern Pike.

During high volume flow, silt is carried to Lake Erie and settles in the lee of Cassidey Point in Lorraine Bay. Silt in this shallow portion of the bay is a problem that leads to the germination and growth of lake weed that makes the area poor for recreational uses.
When there is a storm that creates high wave action, the lake weed breaks off and washes along the shore, fouling about 2 km of shoreline. Several years ago, the Lorraine Bay Water Quality Group and the drainage Superintendent, looked into what could be done to improve water quality coming from the municipal drains and flowing into Lorraine Bay. One of the strategies was to install settling ponds at strategic locations along Wignell Drain. During low flow conditions, this problem is reduced by proper settling before pumping. Our premise is that by pumping from Pit # 3 into Pit # 2, and removing the pumps from Pit # 2, the problem of silt from the quarry is nullified.

Respectfully,