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Your Voice is Needed!

As you may be aware, Gartner Lee Limited has submitted a Permit to Take Water (PTTW) Application to the Ministry of the Environment (MOE) on behalf of St Marys Cement in support of their plan to field test the proposed Groundwater Recirculation System (GRS) on the proposed Flamborough Quarry site. The Ministry of the Environment is asking for public comments.

Call to Action

We encourage you to take action on this matter. Please make your voice heard.
Comments will be accepted by MOE until December 1st, 2006.

The information on where to send your comments is shown below. Please ensure that you reference the EBR Registry Number (IA06E1293) in your comments. To make it easy, the attached template letter has been prepared. It contains a full discussion of the issues referenced below in the background information. Feel free to use it or to write your own using its basic points.

We should prepare ourselves for some form of testing to proceed at some time. It would be unusual for at least some level of information gathering not to be permitted. However, given the intrusiveness and potentially irreversible aspects of the tests as proposed, we are asking as a community that the MOE allow other source water protection work and work on the application to proceed first. Then if and when testing is permitted, the scale of the testing should be addressed and the range of tests performed be limited based on the results achieved on the specific site.

Your voice will help to ensure our community's requests are granted. Take action right away and send in your comments by e-mail or fax before the deadline.

Send Comments to:

PTTW Coordinator
West Central Regional Office
119 King St. W, 12th Fl.
Hamilton, Ontario, L8P 4Y7
Phone: (905) 521-7587
Fax: (905) 521-7820

Email: Cora.Sheppard@ontario.ca and please copy FORCE at info@StopTheQuarry.ca
(Depending on your email program, clicking on the email link above may fill in portions of the email automatically.)

Background Information

The Permit to Take Water application requests permission to take water at a rate of 8,800 litres per minute, 24 hours a day (for a total of up to 12,700,000 litres / 2,800,000 gallons per day) for a period of 20 days. By comparison the new enhanced Carlisle Municipal Water System has a maximum rate of approximately 3,000 litres per minute or 4,320,000 litres / 950,000 gallons per day. The application is requesting to take almost four (4) times that amount.

The application was submitted on October 4th and because of the level of concern surrounding this application on October 12th the Ministry posted the application on the Environmental Registry. (View a copy of the EBR posting) for public comment. The original deadline for comments was November 13th but that deadline has now been extended until December 1st, 2006.

FORCE has obtained the documentation in support of the application from St Marys Cement and has had it reviewed by our community's expert Team. The following concerns have been identified:

  1. Should field tests as intrusive as those being proposed here be conducted before there is evidence that they are likely to succeed? The studies provided as supporting documentation by Gartner Lee state that there is "little clear evidence" that these systems have 'succeeded in their objective" and they confirm that there are "No examples of the use of recharge wells as a mitigation measure for quarry dewatering". And beyond that, why should intrusive tests be conducted into the community's aquifer when a number of other matters such as transportation remain unresolved? Isn't "the cart being put before the horse" .
  2. The Volume of Water to be removed from the aquifer is significant and there is concern that there could be impact on existing water users.
  3. The Volume of Water to be discharged into Mountsberg Creek is also significant and there are concerns over the potential environmental impact on the Creek from changes in Flow Rate, Chemical Composition, and Temperature.
  4. If Aquifer Recirculation does occur, how will the quality of water in the aquifer be protected from potential Surface Contaminants and Changes in Temperature which could lead to bacteriological impacts?
  5. The proposed tests include some procedures such as aquifer fracturing that would be irreversible and could possibly impact existing ground water flows. How will existing water users be protected from potential changes in water quantity and quality?
  6. What will the testing mean? Even if the tests are declared a success by St Marys, the dominant mode of failure in this class of systems is caused by plugging up and bedrock dissolution over the long term. These short term tests will do nothing to address these well documented issues. Also, how will these tests performed now account for the seasonal changes in groundwater conditions?
  7. There are a series of tests being proposed. Each of them becoming more invasive into the groundwater aquifer. These tests should be gated by independent experts such that unless certain criteria are achieved during the early tests, the later tests with potential irreversible negative impact would be restricted.

For more information please review the FORCE website posting on this matter.

Your voice will help to ensure our community's requests are granted. Take action right away and send in your comments by e-mail or fax before the deadline.


Together We Will Succeed!