September 1, 2023 Ministry…

September 1, 2023

Ministry of the Environment, Conservation and Parks
Client Services and Permissions Branch
135 St. Clair Ave West
1st Floor
Toronto, Ontario M4V 1P5

Re: ERO 019-7489, C. H. Demill Holdings Inc, Permit to Take Water. Ministry Reference Number 4702-CUKQSA

Dear Sir/Madam:

The following summarizes the concerns brought forth by CAMQ members over the recent ERO application to amend Permit to Take Water (PTTW) No. 4242-C2PM2T for C. H. Demill Holdings Inc. This amendment intends to ‘combine the water takings associated with Melrose quarry and Long’s Quarry into a single instrument.’

BACKGROUND:
CAMQ is an incorporated, not-for-profit group whose membership consists of local residents, farmers and other persons who are greatly concerned about the impacts of quarrying activities in a location that has no municipal water supply. According to Quinte Conservation, Tyendinaga Township is one of the Quinte area municipalities known to have a high drought impact risk. (Quinte Conservation, p. 27)

While much about the Long’s Quarry has been studied, CAMQ members remain concerned about groundwater with the recent approval of the adjacent Melrose Quarry.

Please consider the following:

• Increased water taking: ERO 019-7489 proposes to increase water taking from 1,315,000 l/day for 305 days/year & 3,000,000 l/day for 60 days/year for the Long’s Quarry to 3,945,600 l/day for 365 days/year for both quarries, for 10 years.

• This Category 3 PTTW application is for an area in which the aquifers are recognized as ‘low yielding’ (Ontario. ERT, [205]). According to the ERO definition, “water takings [for a category 3 PTTW] are anticipated to have the highest potential of causing unacceptable environmental impact or interference.” The 300 homes that lie within a two-kilometre area of the quarries are highly dependent on groundwater for drinking water and/or agricultural uses. (Ontario. ERT, [205])

• Environmental Review Tribunal (ERT), Case No. 14-092, (Decision delivered by H. S. Wilkins): In a past decision on a PTTW application for the Long’s Quarry, H.S. Wilkins recommended a reduction in water taking amounts, increased monitoring and required the ‘Director to develop and include additional contingency, compliance and water conservation measures in the PTTW’ [17]. Specifically, Mr. Wilkins addressed water availability, by reducing the maximum amount of daily quarry dewatering [175, 178], and ordered a provision for water taking during low-water advisories identified by Quinte Conservation [179]. Further, Mr. Wilkins laid out a series of risk management principles and recommended that “should the proposed Melrose Quarry [be] approved, the need for a [cumulative impact study] be assessed by the Director” [207]. (Ontario. Environmental Review Tribunal, 2015)

• ORE’s cumulative impact assessment contained in Update Report No. 2 – Level 1 and 2 Hydrogeological Study, Category 2 Application, Proposed Melrose Quarry, draws upon a Cardin Plain CIA by Golder (2012) to examine the potential for cumulative effects within a 1 km radius of both quarries (p. 88-91). Note that the model for ORE’s assessment excludes ‘assumed well locations’ for a number of homes situated very close to, but just outside, the northern impact assessment boundary. Regardless, the prospect of a wider footprint of extraction leaves some residents feeling uneasy about a potentially expanded drawdown cone as the Melrose Quarry deepens.

• BluMetric Environmental, Quinte Area Study groundwater sustainability : “Groundwater [in the Quinte area] will not be sustainable in the future as a result of climate change” (BluMetric, p. 12). This BluMetric assessment cautions that both Tyendinaga Township, Stone Mills and other areas are entirely reliant on groundwater and do not have access to surface water resources (BluMetric Environmental. A Review, p. 378). They note that drought resilience of private wells varies, depending upon the characteristics of the physical properties of local bedrock aquifers (BluMetric Environment. A Review, p. 368).

We ask the Ministry of the Environment, Conservvation and Parks to ensure the following:
• Be vigilant with inspections – past noncompliances with this operator are numerous and well documented. John Pyke, Hydrogeologist, Malroz Engineering, concurs and validates CAMQ’s concerns regarding noncompliance. Previous charges have been laid, August 2021 (Attached);
• Ensure sentinel wells have been drilled as per site plan (p. 4) for C.H. Demill Holdings, Inc., License 625215;
• Confirm that ECA and PTTW are matched and in compliance – the abutting Long’s Quarry has experienced an historical mismatch between these two instruments;
• Continue to incorporate provision for Low Water Alerts in the PTTW, as per ERT 2015 decision;
• Recommend a 5-year PTTW & continued monitoring;
• Confirm that EMMP as approved by LPAT, August 2020, and referred to on site plan, p. 4 is available to the public on the Melrose Quarry website;
• Site plan, p. 4 notes ‘all wells in vicinity of quarry will be monitored.’ Please make monitoring information available to public on Melrose Quarry website.

According to Brian King (ORE), drawdowns on wells around the Long’s Quarry occurred decades ago when it initially intersected the shallow aquifer [ERT, 90] (Ontario. Environmental Review Tribunal, 2015). We understand that pumping for the Long’s Quarry has reached a steady state and chiefly pumps precipitation that accumulates in the Quarry. The request for 3,945,600 litres/365 days/year is a tacit implication that there will be additional aquifer drain as extraction for the Melrose Quarry similarly intersects the shallow aquifer in the years to come. It is hoped that modest water-taking and careful monitoring can minimize any impact on wells in a community that relies on groundwater for residential and agricultural water needs.

CAMQ Executive,
Rodney Bannister, Chair, John McFarlane, Vice-Chair
Grant Emon, Treasurer Wendy McGeachy, Secretary
Danielle Emon, Executive member cc. Sue Munro, Past Chair
camq2013@gmail.com

cc. Ric Bresee, MPP, Hastings-Lennox & Addington
Mark Boone, Hydrogeologist, Quinte Conservation

References

BluMetric Environmental. A Summary of the Assessment of Water Resources to Support a Review of Ontario’s Water Quality Management Framework, March 2019. https://prod-environmental-registry.s3.amazonaws.com/2020-06/BluMetric%…, p. 12.

BluMetric Environmental. A Review of Ontario’s Water Quantity Management Framework: Water Quantity Study Area Report. Final Report. Body and Appendix C. 2019.

Ontario. Environmental Registry of Ontario. C. H. Demill Holdings Inc. Permit to take water, 019-7489. https://ero.ontario.ca/notice/019-7489

Ontario. Environmental Review Tribunal. Case no. 14-092, September 18, 2015. https://www.canlii.org/en/on/onert/doc/2015/2015canlii59648/2015canlii5…

Oakridge Environmental Limited. Level 1 and 2 Hydrogeological Study, Category 2 Application, Proposed Melroe Quarry, Part of Lot 7, Concession 3, Township of Tyendinaga, Hastings County. Update Report No. 2. (ORE File No. 05-886). October 26, 2016.

Pyke, John (Malroz Engineering). Summary Comments on the 2019 Long’s Quarry ECA and PTTW Compliance Reports. [email] May 25, 2020.

Quinte Conservation. Quinte Region Drought Plan. Final Report, 2021. https://www.quinteconservation.ca/en/watershed-management/resources/Doc…