Thank you for the…

Thank you for the opportunity to provide comments on this proposal. Wellington Source Water Protection staff are municipal staff representing the eight municipalities within Wellington County. We are the appointed Risk Management Officials and Inspectors for our municipalities and are responsible for the implementation of the source protection program and the Clean Water Act. In reviewing this proposal, we had discussions with our colleagues at Lake Erie Source Protection Region and Halton Hamilton Source Protection Region and municipal engineering colleagues within the County. We are also aware of a Township of Puslinch Council resolution passed on November 29, 2023. We understand that the Lake Erie, Halton Hamilton and Township of Puslinch comments are being provided under separate cover.

We provide the following comments:

1/ We recognize that from a municipal engineering perspective that streamlining excess soil regulations with other environmental legislation (specifically waste ECAs) is welcome while balancing protection of drinking water sources. Engineering staff agree with the exemption from waste ECAs for certain excess soil sites.

2/ From a source protection implementation perspective, municipal source protection staff agree with the comments raised by Lake Erie and Halton Hamilton in their respective comments that the exemption of certain excess soil sites from the waste ECA process takes away the ability for local Source Protection Plans to manage significant drinking water threats through prescribed instrument policies. We recommend that this exemption should not apply to sites where excess soil operations are identified as significant drinking water threat activities. This comment is similar to our recent comments on the use of EASRs for stormwater. We reiterate that groundwater dependent communities have very different circumstances than most of the GTA and unless the Province is willing to entertain changes to the Clean Water Act to allow Source Protection Plans to write shall comply policies that apply to EASRs or excess soil approvals, these ERO postings weaken protections for municipal drinking water well supplies.

3/ We share concern that a 100 metre setback from existing or planned potable wells is insufficient for salt impacted soils. Use of salt impacted soils should not be allowed in municipal wellhead protections where the vulnerability score is 10. Use of salt impacted soils should not be allowed in Issue Contributing Areas for chloride or sodium. Additionally, a greater default setback should be established from any potable well and we would be willing to participate in discussions with the Province on determining what that setback should be.

4/ We support the resolution approved by the Township of Puslinch Council from their November 29, 2023 meeting. In particular we understand that they have raised concerns about protection of groundwater resources for non-municipal users and concerns related to the proposal for aggregate re-use, liquid soil and asphalt sites. We support a greater than 100 metre default setback from any potable well and would be willing to participate in discussions with the Province on determining what that setback should be.

We trust these comments are useful. Please contact the undersigned with any questions or concerns.

Kyle Davis (he/him) | Risk Management Official

Wellington Source Water Protection | 1 MacDonald Square, Elora, ON, N0B 1S0
519.846.9691 x362 | kdavis@centrewellington.ca | www.wellingtonwater.ca
Toll free: 1-844-383-9800

Wellington Source Water Protection is a municipal partnership between the Townships of Centre Wellington, Guelph / Eramosa, Mapleton, Puslinch, Wellington North, the Towns of Erin and Minto and the County of Wellington created to protect existing and future sources of drinking water.