Citizens for Safe Ground…

Citizens for Safe Ground Water
1790 Witmer Road
Petersburg, ON N0B 2H0

November 1st, 2019

The Citizens for Safe Ground Water is a NPO in Wilmot Township currently engaged in protecting our community from potential threats to our ground water quality and safety. We live in the Region of Waterloo in which approximately 80% of our drinking water still comes from the ground. The Region of Waterloo’s “Waterloo Moraine” is arguably the region’s most valuable natural resource. And as a rural township with a variety of roads with many factors to consider we have some significant concerns with the proposed changes.

1.)Strengthening protection of water resources (more robust application process for existing operators to go below the water table, and more public engagement)

While in theory this could have some benefits; taking the application process out of the hands of the local municipalities loses touch with local community needs and safety. An appeal is costly to the municipality and therefore less likely to occur.
Leaves local community safety less represented as the only option to appeal is in a costly, inaccessible (for many) LPAT setting.

The financial burden of an appeal process can make it achievable for a municipality to protect their community safety and well being.

Local municipalities have the best understanding of needs of their communities.

Keep application process in the hands of local municipalities

2.) Depth of extraction

We support that the duplication of municipal zoning bylaws relating to the depth of extraction should be simplified. Municipalities should be the only body to vertically zone. The municipalities zoning should inform the ministry and the aggregate license.

If it is determined that municipalities can not vertically zone, then every application must be processed as a below the water table application with the appropriate studies (as these studies will not be required when/if the operator amends to go below the water table at a later time)

3.) Clarify how haul routes are considered under ARA.

Municipalities have the greatest understanding of the physical constraints (i.e. vertical and horizontal curves, sight lines, hidden driveways, and shoulders) of their roads as they relate to the safety of their community, recreational use of their roads, and the character of adjacent lands.

We are concerned about safety issues without sufficient control of the municipality over heavy truck haul routes.

Thank you for your time and consideration to this.