The Permit to take Water …

The Permit to take Water (PTTW) has some overlap with activities related to waterpower projects as it applies to surface water features. However, the PTTW also requires the proponent to fully assess the potential impacts to the groundwater regime not just for for the operation of the facility, but importantly, also the construction. In obtaining the PTTW, the proponent must assess the impact in a variety of areas, such as on nearby irrigation reservoirs or municipal or private groundwater supplies. In the very recent past, I have been involved with a Lakes and Rivers Improvement application with the MNR. Under the LIRA application, specific concerns about groundwater impacts such as those above were not raised, however, for that project, any potential groundwater impacts, specifically those for significant dewatering operations for the construction operations, would still still be addressed through a PTTW, should the water taking volumes justify.

It would seem reasonable to retain the PTTW needs for any project, regardless of the potential PTTW overlap with certain portions of other permitting processes. Eliminating the PTTW need from the aspect of the operation of a waterpower project may not fully address the groundwater safeguards provided through the PTTW process and related studies for dewatering during construction.