Title: Urban vs Rural…

Title: Urban vs Rural distinctions necessitating a MECP regulation on construction dewatering that addresses each

The MECP proposed change of unlimited groundwater taking for construction dewatering should be altered such that it takes into consideration the significant differences of urban centres serviced by lake water and sewers vs rural areas serviced by groundwater and no sewers:

Therefore it is recommended that MECP's EBR Policy posted on EBR 019-6853 be altered:

- allow for unlimited water taking for construction dewatering in a urban centre providing potable water to its community via municipal Lake water, with support from a geotechnical engineer. The geotechnical engineer will assess if ground settlement beyond normal ranges is expected to occur following review of a hydrogeologist's zone of influence assessment; hence two professionals a hydrogeologist and a geotechnical engineer should be signing off as QPs on an EASR that the construction dewatering is acceptable and has acceptable measures in place.

- Not provide unlimited water taking for construction dewatering to occur in rural areas or urban areas serviced by groundwater for potable water to its community. Unlimited construction dewatering may impact potable water sources (quality & quantity) for domestic/commercial/industrial uses and may impact agricultural uses by drawing water away from aquifers that may be connected. Under the Province's Safe Drinking Water Act, precautions are expected to be taken to ensure potable water is not contaminated or threatened including the quantity of groundwater and this includes appropriate MECP guiding protective policy/regulations.