ERO - 019-8240 Capital…

ERO - 019-8240
Capital Paving Application to Draw Water at
Shantz Station Pit Site
1165 Foerster Road

We have grave concerns about the application by Capital Paving to draw water and wash aggregate at the 1165 Foerster Road address
The impact of this pit on groundwater, and now the impact of an additional application to draw water, has not been appropriately investigated
As part of the initial pit application, a hydrogeology report was commissioned by Capital Paving; it was completed by MTE who used the MECP map on file to determine where wells are located in relation to the proposed pit site; the staff at MTE did not conduct a door-to-door investigation to determine how it was that all residences adjacent to the pit site and in a 1km radius and beyond did not appear to have a well according to the MECP map; in fact, all of these properties have shallow dug, spring-fed wells which were not required to be reported (as I learned in 2021 when I placed a call to the Ministry of the Environment with my concerns that the process for documentation directs well drillers to report locations at the time a well is drilled but there was no process for reporting shallow-dug spring wells that have been in operation for over 50 years at least)
To be clear, the MECP map used by MTE to determine impact on well water is not accurate; it does not show the majority of the shallow dug wells in the immediate area
The MTE report DOES explain that shallow dug wells ARE susceptible to aggregate activity, but because they did not visit the residences adjacent to the site and within a 1 km radius, the MTE report erroneously states there are only 6 such wells in vicinity (2 of which are unmapped by MECP but are on the property of the farmer leasing his land to the aggregate company) … please see Slide 4 of these supporting images: MTE report excerpt
Our family learned of the plans for the pit and the limitations of the map used for the study when we visited a community information meeting where MTE had set up a booth; when we mentioned to MTE staff that we did not see our wells on the map they displayed, we were given a business card and told to contact MTE; at no point did MTE reach out to us directly about our wells
Subsequently, I did the groundwork myself, visiting neighbours and inquiring about the depths of their wells; some did not know the depths of their wells, but 10 did, reporting they are shallow dug wells;
Attached is a rough map I created with the info I gathered (see Slide 3 of supporting images); when I presented this information to Woolwich Township in July 2021, Council directed Capital to address the concerns and report back; instead Capital took the matter to the Ontario Land Tribunal citing an expiration of the time Council had to address the application
Also at this time, after coming across a comment by an MTE staff person in correspondence with the Township who had relayed our family concerns, I contacted Capital Paving and MTE directly; their response was to establish well monitoring devices at 2 of the wells (1057 and 1065 Foerster Rd); they still did not proactively reach out to other neighbours in the vicinity to offer well monitoring
we are not aware of the hearings or outcome at the Ontario Land Tribunal in 2023; nor were we able to present this information about the flaw in the process for the hydrogeology study due to a new law that could require a losing participant to potentially pay for the total cost of the hearing should the pit be approved which we certainly could not afford on a middle class family income (this reality of the application for aggregate process has come as a disturbing shock to us who were essentially ignorant of the ways that care and stewardship of the environment could be subverted in our province; we are still stunned and grieving as we worry about the future of our water and navigate the quagmire of communications that impact us but are not always provided to us)
Therefore, the above-the-water-table gravel pit has been approved without accurate information on community reliance on shallow dug wells in the immediate vicinity; these wells would be at certain danger if Capital were to now also be allowed to draw their requested 6,900,000 litres of water and also wash aggregate at this site which sits slightly elevated from, and within a few hundred metres of, the Hopewell Creek and related watershed, which is supposed to be monitored by the Grand River Conservation Authority
During the pit application process, the community of Maryhill requested their own hydrogeology study which was completed by two professors at the University of Waterloo. This Frind study also suggests problems with the Capital-commissioned MTE study. The Frind study can be found linked to Slide 6 or here.
It should also be noted that water table in the area is already in a precarious position, perhaps due to drought of recent years, subdivision development activity near Breslau and another operating gravel pit just 4 km away (Keiswetter Pit Wellington Road 30)?
This 2023 the St Boniface church in Maryhill was required to drill a new well, as were some of the other people of the village of Maryhill. I am guessing the exact number could be accessed on the current MECP well map.
Please find at this link (https://docs.google.com/presentation/d/1jZyV_Ag5dz8P_pET1wP_Bhwm6cAbFnF…) a series of slides showing:
Slide 1 - ERO number for Capital Application to Draw Water
Slide 2 - Screen shot of MECP map from Pg31 of MTE Hydrogeology Report
Slide 3 - Image of the map I produced to show where additional shallow wells are
Slide 4 - Excerpt from Pg 21 of MTE report that states shallow wells are susceptible and erroneously reports only 6 dug wells in area (4 from map and 2 not on map)
Slide 5 - close up shot of corner of MECP map indicating in red 4 wells missing in that area alone
Slide 6 - link to the Frind Hydrogeology report commissioned by community in response to the MTE report