The Sarjeant Company Limited - Permit to take water

39 submissions were received on-line through the Environmental Registry website, and an additional 3407 submissions were received by e-mail (of which 3,373 contained very similar content).

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:

• There were comments received regarding potential impacts to the pristine nature of local aquifers, as identified in an academic study, Shotyk, W., Krachler, M., Chenz, B. and Zhengy, J. 2005. Natural abundance of Sb and Sc in pristine groundwaters, Springwater Township, Ontario, Canada, and implications for tracing contamination from landfill leachates, J. Environ. Monit., 2005, 7, 1238–1244. The ministry’s review has determined that the pristine aquifers identified in this study are not at risk from this proposed water taking. The water taking proposed is from a surficial and unconfined aquifer, where the aquifers subject to this study are confined, separated from the upper aquifer by an aquitard. An ECA (reference No. 6719-C5CN72, ERO Number 019-4550) is required to establish the washing facility at the site, which includes monitoring conditions to monitor the quality of water in the sedimentation ponds and the clear water pond. Those ponds will also be required to be lined with a silt/clay liner, or synthetic liner.

• Stakeholders are concerned that the aggregate washing activities will impact water quality in aquifers and result in quality interference issues with local private wells. Waverley Pit #2 will only use water with no additives in their washing process. The silt and sand contained in the used wash water settles to the bottom of the settling ponds, which will be lined, as discussed above. Therefore, the ministry is satisfied that the operation is unlikely to adversely impact the groundwater quality.

• There were comments regarding the potential for quantity impacts/interference with private wells. Based on the ministry’s technical review (considering the anticipated radius of influence realized from the proposed water taking from Pond A; the distance from the source to existing private wells; and/or the relative elevation of private wells to Pond A) no impacts to private wells are anticipated as a result of water taking from Pond A. However, as a precautionary measure, the permit requires Sarjeant to monitor water levels in on-site monitoring wells, and off-site private wells.

• A concern identified the potential for land subsidence because of depletion of the aquifer. The ministry’s review considered this and identified that water takings at aggregate operations in Simcoe County are sustainable, and there have been no examples of land subsidence because of these water takings, including at existing neighbouring aggregate operations.

• Stakeholders have requested the cumulative effects of the proposed water taking be considered. The ministry’s review did consider the potential impacts of this water taking in consideration of other major water takings in the area, including nearby aggregate operations with similar aggregate washing facilities. Considering the separation in distance, elevation and stratigraphy, the cumulative water takings of the Waverley Pit #2 and the neighbouring Teedon Pit will not interfere with one another and is unlikely to adversely impact the water quantity or the water quality of other users in the area.

Additionally, comments were received identifying that there should be a ban or moratorium on aggregate operations in Waverley Uplands, Township of Tiny and Alliston Aquifer. The Ministry of Northern Development, Natural Resources and Forestry (NDMNRF) is the lead regulatory oversight body for aggregate sites under the Aggregate Resources Act and oversees the review of applications for approvals for pits and quarries.

Duty to consult

Comments were received identifying that the ministry has not adequately consulted with Indigenous Communities. The ministry provided notification of this application for Permit to Take Water to:

• the Beausoleil First Nation
• the Chippewas of Georgina Island First Nation
• the Chippewas of Rama First Nation
• the Metis Nation of Ontario.

Notifications were sent on April 12, 2021, and May 13, 2021. Notifications provided information on the proposed water taking and requested community feedback including any questions, comments or concerns with respect to the proposed water takings.

Responses to notifications were received from two communities:& the Metis Nation of Ontario (from the Georgian Bay Traditional Territory Consultation Committee (GBBTTCC) and the Chippewas of Rama First Nation:

• The GBTTCC identified concerns should the water taking impact ecosystem rights and services that support harvesting. The ministry responded on July 23, 2021, providing information from the ministry’s review identifying that impacts to the ecosystem services were not anticipated. No further comments were received from GBTTCC.

• The Chippewas of Rama First Nation inquired if measures were in place to address issues associated with drought, what environmentally significant features are located in the vicinity of the site, and to confirm that priority be given to domestic water supply. The ministry responded on July 23, 2021, providing information from the ministry’s review, identifying that no impacts were anticipated to local natural heritage features and well users, and discussing the ministry’s adaptive management approach to address unforeseen conditions such as drought. No further comments were received from the Chippewas of Rama First Nation.