Subject: Comment re: Strada…

Subject: Comment re: Strada Aggregates - Permit to Take Water Amendment (Melancthon Pit) - Oppose / Request Denial or Deferral

I am an affected landowner (we actively farm 1356 acres of land in the area north and west of the pit 886 owned and 470 rented)

Position
Deny the amendment. At minimum, defer any decision until full technical documentation is posted publicly and independently reviewed, and until a cumulative effects analysis (pit + proposed quarry) is completed.

Grounds
1) No Demonstrated need.
Strada has stated no change in operation yet seeks a higher allocation. If operations are unchanged, why is more water required? What has their usage been over the past 5 years?
2) Category 3 risk without evidence.
This is a Category 3 taking. Where are the hydrogeological studies, and well-interference assessments to justify a "no impact" on nearby wells and water table?
3) Source of water & pond specifics are unclear.
The application references a "pond" but does not specify which pond or its construction, the pond's original fill source, losses or connections to the aquifer identified on that site both in the previous application and the current application. A complete water budget should be completed.
4) Cumulative effects with the current quarry application.
Strada is also pursuing a quarry with a stated transfer on the order of ~ 6.6 million L/day (as filed). If this amendment increases the pit washing allocations ahead of the quarry decision the combined daily draw at this location will be very large. MECP must evaluate cumulative takings and prevent double permitting.
5) Increased allocations, especially in the summer reduce irrigation security and raise well-interference risk. Has a drought and climate-stress scenario model been completed?
6) How is this level of water taking monitored and governed?
7) 10 years is too long of a term. Reduce the term so that it will be evaluated and reapplied for if their business operation changes from a pit to a quarry.
8) Have they demonstrated alignment with Clean Water Act source protection policies, highly vulnerable aquifer mapping, conservation authority guidance and agricultural water-use priorities. As these documents are not publicly posted the comment period should be extended until they are.

Request
- Deny the amendment OR
- Defer comment period to allow public posting of technical documentation and proof that the increase is necessary at this time.