Strada Aggregates Inc. - 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 relationship between the requested increase and a separate proposal for aggregate extraction below the water table at the site
• the rationale for the greater volume of water requested, including inconsistencies in the proposed rates and days of taking
• potential impacts on private wells, on municipal and agricultural water supplies, and on nearby wetlands, ponds and watercourses, including during drought and in combination with other water takings in the area
• the potential for the water taking to affect the quality of groundwater
• the adequacy of monitoring and reporting
• concern that the Category 3 application represents an unacceptably high environmental risk
• the length of the permit term

The Ministry’s technical review determined that the water taking does not pose any significant risk to nearby wells or surface water features. The increased volume is to support aggregate washing associated with above-water-table extraction, and projected production and operations over the Permit term. The rate, hours and days of taking authorized in the Permit were revised during review to address some inconsistencies in the application. The Permit authorizes water taking only for aggregate washing, with a very limited volume for on-site dust suppression, and does not authorize any dewatering of the site. Extraction of aggregate below the water table is the subject of a separate application under the Aggregate Resources Act which remains under review by the Ministry of Natural Resources; any water taking associated with below-water-table extraction would require the Permit Holder to submit a new Permit to Take Water application supported by a new hydrogeological assessment.

The water taken under this Permit is recirculated on site, with only a small portion being “consumed” in the process. The wash pond draws from shallow geological deposits that are not connected to the deeper aquifer used by most private wells and municipal supplies in the area, and the Ministry does not anticipate that this taking will affect nearby surface water features considering all available monitoring data. The Permit requires that annual monitoring reports, prepared by a qualified professional, be submitted for the duration of the Permit to allow for adaptive management and provide continued oversight. The Permit also compels monitoring of groundwater quality to provide further baseline data, as well as contingency measures; no discharge of water taken to the natural environment is authorized except in accordance with an Environmental Compliance Approval issued by the Ministry.

Regarding the classification of the application as “Category 3”, the Category 3 designation in itself should not be interpreted to indicate that a particular proposal poses an unacceptable risk to the environment. Rather, it indicates that the proposed activity did not meet eligibility requirements for Category 1 or 2 proposals and, as such, required a supporting technical study to be submitted and reviewed by Ministry staff.

The Ministry is satisfied that the monitoring, reporting, and contingency measures included in the conditions of the Permit are protective of local water resources and surrounding water users.