DeCorso Enterprises Limited - Permit to take water

Comments were received from the City of Guelph, Township of Puslinch, and Wellington Source Water Protection. Municipalities recommended that the Permit to Take Water term length be limited to a 5 year duration, and that the Permit include conditions that require the permit holder to adjust water takings with respect to low flow advisories under the Ontario Low Water Response (OLWR) program. Finally, the addition of water quality monitoring at the proposed well source was recommended to quantify nitrate migration among multiple aquifer units in the region.

Ministry response

These comments and recommendations were considered in the permit decision. In determining the length of permit terms, the ministry utilizes an adaptive management approach and assesses a variety of risk factors pertaining to the surrounding environment and other users of a water resource. This adaptive management approach ensures that permits can be amended, reduced, or suspended at any time before the expiry date, if information is received indicating that a permitted water taking is negatively affecting the environment or causing interference with other water supplies.

In addition, there are several permit conditions in the permit which account for contingencies in the event that an impact to the environment or other water users is identified. The ministry will employ the adaptive management principles to this permit. Under this approach, the ministry can amend the terms of this permit at any time, in response to information received regarding changing environmental conditions. The ministry is satisfied that this water taking continues to be sustainable at the present time.

With respect to low flow advisories under the Ontario Low Water Response (OLWR) program, the OLWR Program employs a collaborative approach to manage surface waters during drought and has not been applied to groundwater takings, as groundwater resources generally respond to drought on longer timescale as compared to surface water resources. The ministry would generally support Permit to Take Water requirements under low water conditions in cases where such requirements could be associated with a particular water management objective or outcome. In general, such permit conditions have been applied to water takings for which a stream or river is the primary source, and where information exists to suggest that there are specific impacts of concerns during low water conditions. In this case, the ministry is not aware of any known impacts to flows in local watercourses or streams resulting from the permitted water taking. The ministry will consider reduced water takings as well as increased monitoring under low water conditions where such conditions help manage an identified risk associated with the taking.

Finally, based on the information the ministry has reviewed, the ministry is of the opinion that there is no technical merit to conducting nitrate monitoring at the subject site. Any attempt to quantify nitrate migration among multiple aquifer units would require a regionally-based monitoring program with support and input from local municipalities, source protection authorities, and other agencies as required, as it would not be possible to manage nitrate contamination from non-point sources at the site scale.