Draft Permit to Take Water

The comment period for the Draft Permit to Take Water (PTTW) has now ended.Thank you to all who submitted their comments.

Together We Will Succeed!

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Draft Permit to Take Water

Below you will find a template letter for submitting your comments to the Ministry of the Environment (MOE) regarding the Draft Permit to Take Water (PTTW) on the Environmental Bill of Rights (EBR) Registry. The deadline for submissions is June 6, 2008.

To Submit using this on-line form simply scroll down to the bottom of the page, fill in the required fields and add any additional comments you may have, then click "Submit". Your submission will include the text in the template letter. A copy will be sent to; your email address, the MOE, the Minister of the Environment - the Honourable John Gerretsen, and our local MPP - the Honourable Ted McMeekin.

If you prefer to write your own comments, feel free to use the basic points from the text below and send your comments to:

Section 34 Director
Ministry of the Environment, West Central Region
119 King Street West, 12th Floor
HAMILTON, Ontario
L8P 4Y7

Fax: 905-521-7820

Email: MOEWCR.Permits@ontario.ca and please copy FORCE at info@StopTheQuarry.ca<

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Template Letter

June 6, 2008

Section 34 Director
Ministry of the Environment, West Central Region
119 King Street West
HAMILTON, ON
L8P 4Y7

Dear Director,

Re: EBR # 010-3469 – Draft Permit to Take Water

St Marys CBM Proposed Pumping Test

We are writing so that you will add our concerns to the public record and take them into consideration as you consider the draft Permit to Take Water (PTTW) for St Marys CBM. St Marys plans to test its unproven and theoretical Groundwater Recirculation pumping System (GRS) to try to reduce the unacceptable negative impacts of their proposed quarry development on our communities.

Stop the Quarry

In our area, groundwater is the only source of potable water. The Carlisle municipal drinking water system and the private individual and communal wells for homes, schools, farms and businesses all use groundwater as the source for drinking water and other uses. We have had both documented quantity and quality challenges for years. The Clean Water Act promises protection for Wellhead Protection and recharge areas. It is based on the principle of prevention first. Technical experts to the MOE have recommended that this land use – quarrying below the water table - not be allowed so close to a municipal wellhead protection area. The Greenbelt Plan prohibits new or extensions to existing lake-based water systems. Water is one of the key reasons this proposed development makes no sense here. For this reason as well as, because there are no appropriate haul routes, because of the impacts on our communities, and because we should be protecting the fragile natural features and agricultural lands of the Greenbelt, we have called on the McGuinty provincial government to Stop the Quarry.

Put Source Water Protection First

In response to the Walkerton tragedy, the McGuinty government has established Source Protection Committees (SPCs) and authorities to protect our drinking water sources from existing and future development threats. The substantive work of these organizations is just beginning. If we are to take the SPC and source protection planning process seriously, we have to believe that MOE and the government take it seriously too. It is premature and would be putting the "cart before the horse" to issue this PTTW now. Let the source protection process work proceed first.

Mimic More, Model Less in a Test

We have said that in our view, as communities, before the overall development application should proceed for municipal and provincial approvals, we would expect a legitimate field test of the proposed GRS at an appropriate point in time. Yes, we are concerned about the potential for negative off-site impacts of the overall development and potentially the tests and we have documented that. We are equally concerned about whether the testing, as now proposed, is truly a meaningful field test.

It is increasingly unclear what the short term limited volume tests will mean. Even if the tests are declared a "success" by St Marys, MOE's Director questioned the scale based on the test described in the application at the April 16 public meeting and commented that the proponent would have a long way to go to convince MOE that this system will work. Other experts have come to the same conclusion and question whether the test can really be evaluated as simulating full depth quarry drawdown and mitigation conditions. Why subject our communites to the potential risks associated with these tests when the usefulness of these test have been challenged?

Keep the Test Process Transparent

The transparency of the test process is very important. One of the biggest surprises for our communities in the draft PTTW was the lifting of the embargo on summer testing and its lack of transparency. We were given assurances by MOE and City officials at the April 16 public meeting that there would be no summer testing and it was explained by one city official during the Q&A session why fall testing was a better time to test when the aquifer was most "stressed" after summer conditions. Not many days later, in a behind closed door meeting, with no community representation, and no transparency, the summer embargo was lifted. Having St Marys pump millions of litres of water out of the aquifer when Carlislians are subject to water restrictions and barely have sufficient water in the evening to bathe children and brush teeth hardly seems fair. We also wonder how the test will be treated if Conservation Halton and the Hamilton Conservation Authority issue low water warnings and call for usage cutbacks as they did last summer and fall.

Thank You

We ask that a PTTW not be issued at this time. The risks are too great and the usefulness of the tests are unclear. We thank you for consideration of our concerns. Our letter also supports the submission, and report prepared by the community's expert hydro-geologist, being sent in by FORCE on behalf of our community.

Sincerely,