Wellington Common Elements Condominium Corporation No. 214 - Permit to take water

Comments relevant to the water taking proposal were considered as part of the review of the application. The main concerns raised were regarding the following:

• the location of the water taking within a draft Wellhead Protection Area for Water Quantity (WHPA-Q), and the potential for future implications under the Clean Water Act
• the need to maintain groundwater monitoring and reporting to assess potential impacts to groundwater levels
• recommendations related to water conservation programming and potential measures under low water conditions
• recommendation to decommission unused wells no longer in service
• recommendations related to well disinfection, notification of sodium exceedances, and evaluation of the on-site treatment system

In consideration of these comments, Ministry technical staff has determined that the proposed water taking is not expected to cause interference with nearby wells or natural features. The replacement wells were assessed and found to operate sustainably within the existing groundwater conditions, and the overall risk to other groundwater users or receptors is considered low. As part of ensuring long-term aquifer protection, ministry staff have also included a condition requiring the closure of any wells that are no longer in use, to prevent potential pathways for contamination.

With respect to low water response conditions, the Ontario Low Water Response (OLWR) Program is intended to apply to regulated and non-regulated surface water users and employs a collaborative approach to manage surface waters during drought to avoid unnecessary environmental and economic impacts. The OLWR Program was not developed to apply to groundwater takings, as groundwater resources generally respond to drought on a longer timescale as compared to surface water resources. These wells are completed in a confined aquifer that is not hydrologically connected to shallow surface water features, and as such, the OLWR Program would not apply.
Groundwater monitoring and reporting requirements included in the previous permit will be carried forward to ensure continued oversight of the taking. These conditions support adaptive management and will enable the Ministry to respond appropriately should conditions change. 

Recommendations related to well disinfection, sodium exceedances, and treatment system evaluation fall outside the scope of the Permit to Take Water program. However, the applicant has been made aware of these recommendations. The permit also includes a standard condition reminding the Permit Holder of their responsibility to comply with all other applicable legal requirements and approvals beyond this instrument.

The proponent has also been made aware of the draft WHPA-Q and the City of Guelph’s draft water quantity policies that may affect future land use or water taking considerations once finalized under the Clean Water Act.