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My View: The community that could
Community Case - Hydrogeology
As a community, we know that our drinking water is fundamental to our health and quality of life. Therefore, the protection of water quantity and quality is a major tenet of the Community Case against the St Marys Cement Group CBM (formerly Lowndes Holdings Corp.) application. We believe that the City of Hamilton and related agencies and the Province of Ontario have a clear and absolute duty to protect our drinking water and to protect it at its source - in the very groundwater that flows in the aquifer within the watershed located in our communities. These water sources provide us with the water we use personally to drink, cook, bath for personal hygiene, and do laundry, among other functions. They also supply area farms and agricultural enterprises for livestock, irrigation, and other uses as well as serving area businesses. And, when we talk about water, we are also talking about surface waters too - the Provincially Significant Wetlands and streams and creeks found on the proposed quarry property and on contiguous lands.
It only makes common sense that a proposed aggregate development, of the scale planned, that would extract from below the established water table would have impacts on water and water features. The key questions are: whose job is it to ensure our water is protected, what laws and policies come into play, what are the impacts that could be expected from such a development, how significant would the impacts be and is it possible to manage the impacts? The documents found below form the Community Case regarding hydrogeology in response to the proponent's application, to date.
In July 2005, FORCE submitted 4 documents to the City of Hamilton, its Peer Review Team, and CART in response to the proponent's Preliminary Hydrogeology Report. They included:
- A cover letter from the Chair and Spokesperson which outlines the fundamental importance of
water and two key principles: environment first and certainty. By environment-first, we speak
to the need for decision-makers to take a precautionary approach where the risks are great,
difficult to estimate or predict, and are challenging to mitigate. By certainty, we speak to
surety for all stakeholders - in this case, certainty that area municipalities, residents,
farms, and other businesses will have a sustainable groundwater water supply upon which they
can count for quality and quantity into the future.
Hydrogeology Cover
Letter July 2005 (84 KB)
- FORCE’s interpretation of the laws and policies against which we believe the application
and its potential impact on our water should be reviewed in order to uphold our principles of
environment-first and certainty. We conclude that the Province of Ontario and the City of
Hamilton (and related agencies) have a clear and absolute obligation to protect drinking water
where it begins, at the source.
Hydrogeology Regulatory
Environment (161 KB)
- Analysis by INTERA Engineering Ltd. which speaks directly to FORCE’s concerns about the
specific methodology used and the conclusions drawn in the proponent’s Planning Report and
Preliminary Hydro-geological Assessment. INTERA concludes that the proponent's methodology -
using unsealed monitoring wells - does not meet industry standards. As a result, the drawdown
estimates provided are not credible. The real impact on residential and municipal drinking
wells as well as the Provincially Significant Wetlands, creeks and streams will be significant.
The proposed mitigation measures will be ineffective.
INTERA (Raven) Report
(70.3 KB) Figure1 - Carlisle ESA
(175 KB) Figure 2 - Carlisle Wells and
WHPAs (127 KB) Figure 3 -Quarry
Hydrogeologic Cross Section (38 KB)
- A non-exhaustive listing of additional omissions, gaps, and inconsistencies in the
proponent’s Planning Report and companion technical reports which relate to water.
Hydrogeology Gaps (66 KB)
Later in July, the proponent tabled a revised hydrogeology report - the Draft Level 2 Hydrogeology Report. INTERA Engineering Ltd. has critiqued that analysis as well. The November 2005 Hydrogeology Cover Letter (99 KB) and FORCE Review of Draft Level 2 Hydrogeology Report (192 KB) find that the proponent's Draft Level 2 Report validates the concerns raised in the initial FORCE submissions given the proponent's own consultant's Gartner Lee Limited conclusion that development of the quarry without mitigation would have a significant and unacceptable impact on local residential water supply wells and the Provincially Significant Wetlands. As well, the capture zone for the Carlisle municipal wells would change with unknown quality and quantity impacts. The INTERA analysis demonstrates further how even the Draft Level 2 Report underestimates the potential impacts and how the proposed mitigation plan is conceptual only and unproven in terms of successful long term application at quarries of similar size and hydrogeologic setting.
Similar hydrogeology concerns and additional complementary ones can be found by reviewing submissions from the Province of Ontario, from other municipal governments and agencies (who form CART - the Combined Agency Review Team), and from the City's Peer Review Team. These materials can be accessed from Government & Agencies selection on the main menu bar.
In addition to our Community Case and resource materials found on the website, FORCE has and will continue to prepare and distribute periodic information flyers to keep the community informed on key issues. The potential impact on the Carlisle municipal wells is one example of the water issues that could result from the proposed development. A document Your Water and the Proposed Carlisle Quarry was distributed during November 2004.
Supporting Documentation:May 2009
FORCE ARA Objections - Hydrogeologic Review - Intera Engineering Ltd. (105 KB)