Please see attached comments…

Please see attached comments from the Lake Erie Region Source Protection Committee. Below is a brief summary of key comments:
• Pre-consultation with agencies such as conservation authorities and municipalities should be a mandatory requirement to ensure that ‘terms of reference’ for technical reports are completed or new aggregate or quarry sites or amendments to existing applications to go below the water table. This would ensure that applications include the required technical information prior to municipal and agency review and that they can be reviewed in a timely and efficient manner.
• MNRF should develop cumulative effects assessment and data collection and sharing regulations and criteria for new aggregate or quarry sites for below water table extraction. At this time, there is no mention of cumulative effects assessments in the ERO proposal.
• In 2010, a document entitled “Cumulative Effects Assessment Best Practices Paper for Below-Water Sand and Gravel Extraction Operations in Priority Subwatersheds in the Grand River Watershed” was released. The document was completed in consultation with various provincial ministries and representatives of the Ontario Stone Sand and Gravel Association. It provides a framework for cumulative impacts to be assessed in a consistent manner and to guide decisions makers, such as municipal governments and the MNRF and Ministry of Environment, Conservation and Parks with responsibilities in this area. Eleven priority subwatersheds within the Grand River watershed were identified.
• The Best Practices Paper identified the need for a comprehensive data collection and data management process. This was to be developed and maintained by MNRF in consultation with the partners to facilitate collecting the appropriate data and sharing this information with aggregate resource applicants. This data process has yet to be established and it would provide an opportunity for a transparent and open-data sharing framework to permit all external stakeholders with access to information related to below water table aggregate and quarry applications and operations.
• A requirement for applications to be consistent with provincial or local Technical Guidelines needs to be included in the ARA Technical Standards. This would include studies that identify and evaluate impacts to water or natural environment resource systems.
• Lake Erie Region staff support the identification of source protection vulnerable areas and activities and how source protection plans and policies are addressed. To better protect municipal drinking water supplies, staff recommend the Ministry consider the following:
o A water budget should be required for all applications proposing below water extraction
o Water Report requirements should include an assessment of potential impacts to sources of drinking water, in particular for proposed below water extraction (e.g., breaching of aquitard), and propose any necessary measures to prevent, where possible, mitigate, or remediate any negative impacts.
o All aggregate extraction should be prohibited in Wellhead Protection Area (WHPA) A and B, not just extraction activities by private land owners and farm businesses
o Chloride based dust suppressants should be prohibited where dust suppression is required at aggregate sites located within source water protection areas

Regards,

Martin Keller
Source Protection Program Manager
Lake Erie Region