Re: Updates to Ontario’s…

Re: Updates to Ontario’s Water Quantity Management Framework, ERO 019-1340
July 30, 2020

Background:
Citizens Against Melrose Quarry (CAMQ) is a not-for-profit organization formed in Spring, 2013. Residents have long been concerned about a proposal to develop a second quarry adjacent to the existing Long’s Quarry in Tyendinaga Township, Hastings County (Quinte WQSA). A 2018 Tyendinaga Township zoning change for the second quarry was made possible by a 2012 amendment to the Hastings County Official Plan (requested in 2004). Over this time period, Tyendinaga Township also continued to issue building permits to the north of the existing and the proposed quarries. Tyendinaga Township is located about 10 km east of the urban area of Belleville, ON.

Through a 2015 Environmental Review Tribunal (ERT), CAMQ appealed a Permit to Take Water application for the Long’s Quarry (Tyendinaga Township), which was allowed in part (ERT Case No. 14-092). At the time of writing, the operator is being investigated by MECP for non-compliances, and has recently been investigated for failure to comply with current PTTW restrictions on pumping water during drought periods. The operator still retains a valid PTTW.

Groundwater in Tyendinaga Township
Residents in Tyendinaga Township have had long standing concerns about aquifer vulnerability and sustainability, as captured in the BluMetric Environmental Final Summary, p. 14. With the exception of a limited number of residences in village of Shannonville, all homes, farms and businesses in Tyendinaga Township rely on groundwater. The neighbouring First Nations community recently established a water treatment facility, but it does not service the whole territory -- leaving numerous homes reliant on trucked water or groundwater. We note that the BluMetric study authors were not able consult with the Mohawks of the Bay of Quinte as part of the current study (Body and Appendix C, p. 342).

Tyendinaga Township (Quinte Study Area) is an example of an area that relies primarily on non-permitted water takings to service its community’s water needs (private wells) and high-volume water taking permits (dewatering). In this small area, the shallow aquifer immediately surrounding the Long’s Quarry has been largely drained over the years, and aggregate stocks in the current quarry (Long’s) will soon be depleted. The idea that an expanded footprint could allow another quarry to take billions of litres of water from an area identified in the BluMetric study as “unsustainable under future conditions” (Appendix D, Table 11-1) is devastating to farms and homeowners who are “entirely reliant on groundwater and do not have access to surface water sources” (Appendix C, p. 376) or municipal water sources.

Drought/Low Water Conditions – last 5 years
To expand on the study’s conclusions for this WQSA (Body and Appendix C., p. 368; 373), Quinte Conservation has had alerts for low water conditions in 5 of the last 5 years (2016, 2017, 2018, 2019 & 2020). As your study points out, residents in Tyendinaga Township struggle with water supply in times of drought (p. 368). BluMetric Environmental makes reference to bulk water purchases in the region in times of drought (p. 377), a fact supported by a limited, informal mapping of dry wells done by CAMQ in the area of the current Long’s Quarry, October 2016. CAMQ acknowledges the limitations of this informal survey as residents are often reluctant to report low/dry well conditions due to the perception that there might be implications on future real estate values.

Given the above, CAMQ makes the following two recommendations:

Recommendation #1: Stronger Strategies for Managing Water Taking Permits in Areas Lacking Municipal Water Supplies

Given the regional variation in Ontario’s geology and hydrology our group feels that one set of rules/regulations cannot be equally applied to all regions of the province. We find merit applying ‘area based approaches’ as suggested in your Proposal Paper, p. 14.

As a caution, the Final Summary (p. 12) prepared by BluMetric Environmental describes reported water usage in the broader Quinte area, but this fails to show that 46% of the population (Dillon, 2004, p. 92) — potentially almost half the homes in the Quinte region — are completely reliant on groundwater and fall outside of reported municipal water use as “non-permitted takings” (Final Report, Appendix C, pp. 358-361). These homes may lie in close proximity to industry, dewatering activities, agricultural operations, and other industrial water users. The BluMetric study outlines indicators of water stress/local water management concerns for the Quinte WQSA and acknowledges that ‘non-permitted water takings’ are not part of the Tier 1 source protection plan (p. 377). It would seem that the Key Resources for Quinte WQSA (Table 9-1, p. 342) may not provide enough data to fully understand and assess the cumulative effects of water taking in vulnerable areas not serviced by municipal water supplies or source protection plans used for this study area. How can this significant use of unreported groundwater be reflected in Quinte Study Area reporting?

We would suggest that the ministry’s proposed actions for Goal #2 in Updating Ontario’s Water Quantity Management Framework, Proposal Paper (p. 14), also include specific guidance for managing water takings in areas that depend entirely on groundwater (lacking municipal water supplies or any source water protections).

Recommendation #2: Moratorium on Water Taking in Vulnerable Areas with No Municipal Water Supply

We appreciate that the Government of Ontario has undertaken independent study by BluMetric Environmental Inc., but note that this work appears to be largely concerned about impacts of water taking for the bottled water industry. Regardless, the findings are relevant to all permits to take water. We note from your report that the population in the Quinte WQSA is expected to grow by about 11% between 2017 and 2041 and future “sustainability of the local water resources is anticipated to be affected” (Appendix C, p. 370). We strongly urge a moratorium on all water taking permits (PTTW) in vulnerable water quantity study areas that have no municipal water supply until further study on the water balance and the cumulative effects of domestic, agricultural, dewatering and industrial groundwater usage in under serviced areas can be completed. We would also recommend that your cumulative analysis of water usage and taking for agricultural purposes include water usage for livestock — something that is missing from your current study (Summary, p. 6).

We thank you for this opportunity for rural citizens to have their voices heard. In 2014 and 2016 The Auditor General Report, requested that the ministry “address threats to sources of water that supply private wells and intakes” (Office of the Auditor General of Ontario). We truly hope that Ontario can move closer to realizing this goal.

Sincerely,

Susan Munro, Chair, CAMQ
Danielle Emon, Executive Member, CAMQ

camq2013@gmail.com
www.citizensagainstmelrosequarry.com