Procedures for Assessing…

ERO number

019-0556

Comment ID

35900

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Procedures for Assessing Applications for Below Watertable extraction by existing permit holders

There are many important environmental issues associated with below-watertable extraction operations that do not arise with applications for above-watertable extraction of gravel. These include:
• Exposure of large areas of water surface to airborne contaminants (not a hazard for above watertable extraction)
• Changes in direction and magnitude in subsurface water flow with effects on both upslope and downslope environmental features (ponds, wetlands, spring-fed streams)
• Changes in overall waterbalance due to increased evapotranspiration from created water surfaces
• Loss of post-extraction land surface resulting in the loss of a large range of post-extraction land uses that are possible with above watertable extraction
None of these possible environmental impacts receive attention during the review process for above-watertable applications.
The procedures for review of these environmental impacts for an application for extension to allow below-watertable extraction on an existing above-watertable licenced property should be identical to the procedures for public notification, required studies, public meetings and opportunity for public review and comment for new applications.