Comment on the Source Water Protection Plan

Send your comments to the Source Water Protection Committee.

These comments will be included when they send the plan to the Ministry of the Environment for approval.

They need to hear from as many people as possible to force them to listen to the research and include aggregate operations as a threat.

The following is a template to make your submission easy. You can either add your support to our comments or you can modify them for yourself or you can create your own comments from scratch. Please include your modifications at the top so they are not missed.
There is also a more comprehensive set of comments that you can select from below the form. Simply cut and paste any part or the whole thing into the commenting section.

Thank-you for your support and concern for the future of your water.

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Further information can be found on the source water website

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Here is a more comprehensive list of comments…the TypeX version:

To: Martin Keller, Source Protection Program Manager
Lake Erie Source Protection Region

I am writing in regards to the Source Water Protection Plan and would like to make the following comments:

The Source Water Protection Plan is supposed to protect our water however activities related to aggregate operations are not listed as a threat in the plan. The Source Water Protection Plan committee has identified threats related to aggregate extraction however these have been denied. This would indicate that aggregates are more important (to whom?) than our health and safety. Since the plan is about our health and safety, then you need to justify your opinion that aggregate extraction is not a threat. We demand to see the science behind this decision and proof that it is a fact.

Although the extraction of aggregates may not utilize chemicals,the application of dust suppression chemicals is still a part of the operation. If no dust suppression chemicals are used, then how is the dust minimized to prevent those who live near an aggregate operation from being exposed to the carcinogenic dust? The dust control techniques to be utilized should be fully disclosed and protection against all threats to human health considered in the process. Dust mitigation in wellhead protection areas should be studied and regulations put in place that protect our water. If it is not a danger, then we, the public, would like to see the evidence that backs up this opinion.

Although the extraction of aggregates may not utilize chemicals, minerals and chemicals that are trapped in the soils would be released and backwashed into the aquifer through the washing process. Chemicals are created when you mix different minerals and elements together so although they may not use pre made chemicals, they would change the chemistry of the water in a totally unmonitored manner. Testing to show the chemical changes that occur in our water, if not already done, should be done to reveal the exact effects on our water in both chemistry and temperature so that we can make informed decisions regarding our health & safety.

No activity should be allowed that increases the vulnerability of an aquifer that is already highly vulnerable. If an aquifer has a vulnerability of 10 but there is 30 feet of earth above the aquifer, then stripping this layer would in fact, increase the risks. This means that it would make an already vulnerable aquifer even more vulnerable. I suggest that after the rating system that is in place, an additional range be added, say a 5 point scale that would show that the aquifer can, in fact, be increased beyond the 10 rating. The current system gives the impression that it cannot be made worse, since it already has a rating of 10. Please correct this error.

In the Walkerton report, all of the experts agree that a multi-barrier approach is required to protect drinking water. All of the material above the water table acts as a layer of protection. Aggregate extraction removes this protection and increases the threat to water contamination. Since the vulnerability rating is already 10 (source?), then removing 30 feet of material from above the aquifer will increase the vulnerability.

The pit site plan states that after extraction the site will be returned to farmland. Has any consideration been given to the increased threat that farming and the application of fertilizers and chemicals will have to the aquifer considering the protective layer has been removed?

How is it possible that an activity that changes a well to GUDI, which would require millions of dollars to increase filtration, not be considered as a threat? Where is the science that proves this to be not a threat?

E-coli is the biggest threat to water supplies and the reason for the creation of this plan. Have there been studies that show the effectiveness of unsaturated material above the water table in killing the bacteria and other contaminants before it gets to the water table? This would be important information to know before allowing the continued removal of this layer of natural filtration.

The protection of our source water must consider the possibility that we may have to rely on ground water without treatment at some point in our future. Our target should be set at making sure that we are protected in all circumstances and that the source of water is protected at all levels and is free of toxins and chemicals at the source, such as the name of the plan implies. Reliance in treatment is not an acceptable strategy.

The inclusion of airborne emission was not considered as a threat due to the existence of the protective soils above the water table. This layer will not exist in a gravel pit, especially if ponds are created. A recent application on the EBR is for a facility to emit ethanol, diethylene glycol butyl ether, sodium nitrobenzene sulfonate, and iron. The factory across the road clearly shows that emissions will travel to the aggregate operation and this material would settle on the pit floor. Has any consideration been given to this? Have any studies been carried out to prove what the effects are?

Manufacturing companies are required to mitigate risks such as having oil pans under equipment in order to catch any spills that may occur according to environmental regulations. This is in addition to concrete floors and usually in areas that are not within WHPA’s. Equipment operating on top of a WHPA should have secondary containment method in order to catch any spills that may occur such as sleeves around all fluid lines and a containment system for engines and fuel systems.

Oil pipelines through Aquifers and through rivers should be considered a major threat. The 6 hour time of travel rule suggests that a person would be present in order to notice and report a spill. With a pipeline, there would be nobody around to notice or to notify. Considering that many of these pipelines are 50 years old and the disasters that have been in the news in the last few years, pipelines have the potential to destroy the river system that is the water supply and the cleanup record should be noted as well.

I look forward to hearing back from you with regards to the above-noted enquiries. Thank you for your consideration.


Concerned Citizen