Re: ERO 025-1082 (Strada…

Re: ERO 025-1082 (Strada Aggregates Inc – Permit to Take Water)

Hunter and Associates provides the following comments on behalf of our clients:
Strada’s existing PTTW 3210-AKRL9C was issued on May 9, 2017 for up to 2,400 m3/day for up to 230 days with a maximum water taking restriction of 4,000 L/min (67 L/s). The existing expiry date is March 31, 2027.
We understand that all water takings between 2017 and 2024 remained below permitted volumes with the exception of October 17, 2017 when 2,438 m3/day was taken.
Strada’s October 2, 2025 Proposal for an Amendment to the existing Permit to Take Water has been increased to 5,000 m3/day with a maximum rate of 6,000 L/min (100 L/s) for a maximum of 11 hours/day and 365 days/year for the purpose of aggregate washing. The proposed period of taking is 10 years.
This Permit, as proposed, clearly anticipates increased aggregate production, perhaps under an ongoing Aggregate Resources Act Application for a Quarry.
We have the following comments related to the Tatham Report:

Technical
• No source of ‘Make Up’ water is specified to support the higher pumping rates.
• No vertical elevation datums are specified. The Applicant may be using mixed elevation datums (CGVD2013 and CGVD28:1978).
• s3.1.2 specified lower range groundwater elevations at 477.83 m asl, which appears to be an error.
• Water table data specified on Fig 6 is sparse and includes dry wells at OW14A and OW20A.
• The Applicant is proposing to extract the Freshwater Pond (Fig-7) to the top of the epikarst (weathered bedrock surface) at about 484 m asl while at the same time raising the water level to above 492 m asl.
• The existing water table is at approximately 490 m asl. Raising water tables will further increase water levels in the wetland NAT-19 on the adjacent farm to the east due to seepage through near surface granular formations.
• Overall pit extraction activities and removal of agricultural crop cover have already increased water surplus and groundwater seepage flowing out of the existing Pit Area.
• Stripping of the ‘Prince Pit’ agricultural soils and elimination of agricultural crop cover will further increase water surplus in the existing pit environment.
• This wetland emergent surplus water will recharge mainly in downgradient farm fields within Lot 10 & 11, Conc 2 and Con 3 causing agricultural crop damage and/or prevention of planting or harvesting.
• Wells OW14C, OW16C, OW18C and OW19C reflect hydraulic conditions for the on-site deep lower aquifers (Gasport), not the upper water table aquifers.
• The Applicant’s Fig-2 Water Wells should include both sides of 15th Sideroad and the Third Line, not just a 500 m Site Boundary Buffer and also, the domestic monitoring wells DW1, DW2, DW3, DW4 and DW5.
• Showing MECP Water Well Records for the Site Monitors inside the Pit Licence Boundaries is frivolous and not relevant.
• The Applicant has not provided Borehole logs for Fig-5 and Fig-6 in the Wash Pond areas.

Non-Compliance
• The ARA Complete July 8, 2010 pg 2 of 4 Melancthon Pit Site Plan as included in Appendix C of the PTTW application specifies a spot elevation of ± 493 m and a maximum depth of extraction at 1.5 m above the identified water table elevation in the general area of the Freshwater Pond (4).
• The Applicant Fig-6 shows the watertable at 492 m asl in the vicinity of the Freshwater Pond. Therefore, the corresponding maximum extraction depth allowed would be 493.5 m asl.
• The corresponding lowest LiDAR elevation (CGVD 2013) is 489.65 m asl in the Freshwater Pond Area.
• Therefore the Applicant has extracted more than 3 m below the licenced elevation and is not in compliance with its Aggregate licence.

Conclusions:
• The PTTW should include provisions for protection of downgradient agricultural lands where excess pit flows will recharge by default.
• This proposal will result in further damage to nearby agricultural fields due to re-emergence of infiltration waters and downgradient secondary recharge.
• Compensation to farmers is required for existing field damage due to increased pit secondary runoff.
• The Maximum Permitted Water Takings should not be increased at this time prior to processing of the related ARA Quarry licence application already submitted and delivery of appropriate compensation for existing damaged farmlands.