[All] Fw: Municipal and Ministries cannot assure compliance without Data.

Thu Oct 25 20:00:46 EDT 2012

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: eco <commissioner at eco.on.ca>; "gail.jackson at ontario.ca" <gail.jackson at ontario.ca>; "catherinefife at on.ndp.ca" <catherinefife at on.ndp.ca>; "ahorwath-qp at ndp.on.ca" <ahorwath-qp at ndp.on.ca>; "tim.hudak at pc.ola.org" <tim.hudak at pc.ola.org>; "hhampton-qp at ndp.on.ca" <hhampton-qp at ndp.on.ca>; Cbentley Mpp <cbentley.mpp at liberal.ola.org>; Peter Kent P.C. M.P. <minister at ec.gc.ca>; "peter.braid at parl.gc.ca" <peter.braid at parl.gc.ca>; "stephane.dion at parl.gc.ca" <stephane.dion at parl.gc.ca>; justin duncan <jduncan at ecojustice.ca>; "environment at afn.ca" <environment at afn.ca>; "enviroinfo at ec.gc.ca" <enviroinfo at ec.gc.ca>; "david at donnellylaw.ca" <david at donnellylaw.ca>; Dianne Saxe <dsaxe at envirolaw.com>; CELA Articling Student 1 <articling.cela at lao.on.ca>; "jmilloy.mpp.co at liberal.ola.org" <jmilloy.mpp.co at liberal.ola.org>; "francis.scarpaleggia at parl.gc.ca" <francis.scarpaleggia at parl.gc.ca>; "stephen.harper at parl.gc.ca" <stephen.harper at parl.gc.ca>; "Elizabeth.May at parl.gc.ca"
 <Elizabeth.May at parl.gc.ca>; "justin.trudeau at parl.gc.ca" <justin.trudeau at parl.gc.ca>; "thomas.mulcair at parl.gc.ca" <thomas.mulcair at parl.gc.ca>; "info at gg.ca" <info at gg.ca>; "jgerretsen.mpp at liberal.ola.org" <jgerretsen.mpp at liberal.ola.org>; "mcu at justice.gc.ca" <mcu at justice.gc.ca>; "communications at oag-bvg.gc.ca" <communications at oag-bvg.gc.ca>; "nsin_risn at rcmp-grc.gc.ca" <nsin_risn at rcmp-grc.gc.ca>; Mike #509 <509 at yrp.ca>; "lberardinetti.mpp at liberal.ola.org" <lberardinetti.mpp at liberal.ola.org>; "jbradley.mpp at liberal.ola.org" <jbradley.mpp at liberal.ola.org>; "dcansfield.mpp at liberal.ola.org" <dcansfield.mpp at liberal.ola.org>; "mcolle.mpp at liberal.ola.org" <mcolle.mpp at liberal.ola.org>; "gcrack.mpp at liberal.ola.org" <gcrack.mpp at liberal.ola.org>; "bduguid.mpp at liberal.ola.org" <bduguid.mpp at liberal.ola.org>; "dduncan.mpp at liberal.ola.org" <dduncan.mpp at liberal.ola.org>; "mgravelle.mpp at liberal.ola.org" <mgravelle.mpp at liberal.ola.org>; "hjaczek.mpp at liberal.ola.org"
 <hjaczek.mpp at liberal.ola.org>; "lsandals.mpp at liberal.ola.org" <lsandals.mpp at liberal.ola.org>; "mkwinter.mpp at liberal.ola.org" <mkwinter.mpp at liberal.ola.org>; "dmatthews.mpp at liberal.ola.org" <dmatthews.mpp at liberal.ola.org>; "tmcmeekin.mpp at liberal.ola.org" <tmcmeekin.mpp at liberal.ola.org> 
Cc: "mmeilleur.mpp at liberal.ola.org" <mmeilleur.mpp at liberal.ola.org>; "sqaadri.mpp at liberal.ola.org" <sqaadri.mpp at liberal.ola.org>; "kwynne.mpp at liberal.ola.org" <kwynne.mpp at liberal.ola.org>; Tim ( MAH) Ryall <tim.ryall at ontario.ca>; "bevacquaf at washington.ijc.org" <bevacquaf at washington.ijc.org>; "beckhoffb at ottawa.ijc.org" <beckhoffb at ottawa.ijc.org>; "nevinj at windsor.ijc.org" <nevinj at windsor.ijc.org>; Mark Calzavara <mcalzavara at canadians.org> 
Sent: Thursday, October 25, 2012 8:00:20 PM
Subject: Municipal and Ministries cannot assure compliance without Data. 

Dear Hon. Prime Minister, respective ministers et al. 

Via the communications I have had with Ontario MNR's Ken Cornelisse it identifies the fact that the MNR in Ontario and local municipalities are lacking the data to reasonably perform their duty to protect water features, rare species and other issues within their jurisdictional powers leaving them potentially liable at the taxpayer's expense.  

By way of a series of correspondences exchanged with MNR staff, I found out that Ontario's MNR lacks the powers to secure hydrology data, bore hole data, terrestrial reports or the associated field notes regarding the Dufferin Quarry Project on Watts Rd. in Brant County. The data is currently in the possession of Dufferin Aggregates and this is confirmed in the correspondences as provided by Mr. Cornelisse. Neither the MNR, the City nor the public has been privy to any of these key reports to date. 

The Dufferin Quarry Pit  was approved 38 years ago and has yet to cut ground but it demonstrates overwhelming risks to water supplies, well heads, rare species and local industries.  It sits over top two critical well-head protection zones for municipal wells as recognized by the Source Water Protection Committee. This project involves huge economic and food security and public health risks. I created a power point about this here: http://www.slideshare.net/Waterloomoriane/brantwater

There is currently no mandate for proponents to facilitate transparency of data during public processes, regardless of the fact private proposals have the ability to significantly impact local. provincial and national economic systems. For example, all industries, farming and communities rely upon shared water resources but there are on occasions, private ventures which places all of these agencies at significant risk. One such example is the Melancthon Quarry Pit. 

In light of this matter I request that the Ministry of Ontario facilitate mandatory disclosure of all EA data including hydrology and terrestrial reports and other planning documents to make it the law to have this data accessible for ministry, municipal and public review regardless if it's a quarry pit, a subdivision etc. Ministry and municipal officials, NGO's and the public have the legal right to participate in the governance issues of our nation so give us the data so we can reasonably perform our civic duties as enshrined in legislation.

The system as it currently stands appears, in my view, to be slipping into a Kangaroo Court like process. Statements are said specifically to placate the public but are not being substantiated with actual data. I am approaching both provincial and federal ministers in good faith with full disclosure of my concerns because I see the same issues at both the provincial and federal levels right now. 

It is my sincere hope the government will take a look at the concerns I have expressed and give serious thought to the long term economic consequences of leaving our nation's future in the hands of businesses who rely on the views of hired engineers. 

Currently engineers in Canada have no mandatory test times or methods specified to assure their data is reasonable. There is no criteria for what is deemed outdated data, no standardized units of measurements, no 12 month creek study mandated. They can manipulate data many ways to achieve desired pro development results ie: picking data from drought years  etc. Once they sign off, have no liability risks. The MNR cannot scrutinize the data if they don't even have the access to it. Our MNR offices are under staffed and under funded. They see a rubber stamp they say OK and move on to the next approval permit because that's all they can do. The criteria to say no to various projects such as gravel pits, has yet to reasonably be defined. 

Meanwhile if an accident happens due to the poor EA data, the blame falls on the company who purchased it when the actual blame might be the fella from the engineering firm who undermined the risks. He wasn't paid to protect the public interest, he was paid to get that pipe approved and that's it.  With the current system, nobody is double checking his work because the data is out of view of municipalities, ministries and the public. Guess who stands to profit when the wells go bad? 

It's a shameful system where it stands currently. Human lives, municipal water supplies and long term economic systems that we have to day were crafted with great care by our forefathers. Don't let their pillars crumble. The public is the number one fundamental keystone to facilitate ALL public processes. Keep the science open so we can all reasonably participate to perform our civic duty in order to protect the interests of our communities and the nation for the long term. 

Below are the correspondences shared with Mr. Cornelisse for your reference. 

Yours in good faith

Louisette Lanteigne
700 Star Flower Ave.
Waterloo Ontario
N2V 2L2

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "Cornelisse, Ken (MNR)" <ken.cornelisse at ontario.ca> 
Sent: Thursday, October 25, 2012 5:53:35 PM
Subject: Many thanks

Hi Mr. Cornelisse

Thank you very much for your response. This information is greatly appreciated. It goes a long way to providing a better understanding on the overall project, how these issues are managed and the need to secure better transparency of data not only for the public but for the ministries as well. 

Water is a public resource and it only seems reasonable the data regarding water issues be made public too. I'll see what I can do to secure further data from this company.

It would be in the best interest of the proponent to allow for public scrutiny. Engineering firms hired to do these jobs tend to do so using strategies that may undermine risks. We actually don't have mandatory test times or testing protocols in place to secure these studies are reasonably done. Once these engineering firms sign off the liability transfers onto the company who purchases the data, in this case, Dufferin Aggregates. Should problems happen down the road by way of underestimating the EA risks, it's Dufferin Aggregates, not the engineering firm who might be sued for any actions done using that data. Too often firms get blame when the root flaws were not their own. And the engineers stand to profit when things go wrong. We need to secure that the initial engineering firms are held liable and accountable for the services they provide. 

I'll do my best to help make the system better. 

Louisette Lanteigne
700 Star Flower Ave.
Waterloo Ont.
N2V 2L2

________________________________
 From: "Cornelisse, Ken (MNR)" <ken.cornelisse at ontario.ca>
To: Louisette Lanteigne <butterflybluelu at rogers.com> 
Cc: "Stone, Mike (MNR)" <mike.stone at ontario.ca>; "Freeman, Linda (MNR)" <Linda.M.Freeman at ontario.ca> 
Sent: Thursday, October 25, 2012 4:29:50 PM
Subject: RE: Strange Snakes in Paris & reports needed

Hi Louisette,

Thank you for your email.  As
previously noted, this site has been licenced under the Aggregate Resources Act
(ARA) since 1974.  The original planning process included a hearing at the
Ontario Municipal Board, where a wide range of issues were adjudicated. 
There is no current “planning process” underway and MNR has no
further requirements before Dufferin Aggregates begins to operate this pit.

The aquatic and terrestrial inventory data
from the Dufferin Paris Pit monitoring belongs to Dufferin Aggregates and the
MNR does not have a copy of those data.  As a result you would have to
request those data from Dufferin Aggregates.  I did find a summary of the monitoring
results in the “Presentation” listed at:  http://www.dufferinparispit.com/en/announcements/capmeetingminutesandmaterials.asp. 
A contact at Dufferin Aggregates is Kevin Mitchell - kevin.mitchell at holcim.com.

The hydrogeological monitoring data and the
bore hole data for the Paris Pit, belong to Dufferin Aggregates.  So you
would have to request those data from Dufferin Aggregates.  Once again you
can get in touch with Kevin Mitchell to discuss the availability of those data. 
MNR does not have a copy of those data.

As previously noted, it is the operator’s
responsibility to ensure compliance with the ESA.  This same principle
applies to all landowners.

Dufferin Aggregates will be applying to
the MOE for a Permit to Take Water.  Generally speaking, the use of water
at aggregate sites is not highly consumptive.  Much of the water that is
taken (pumped) is returned to the groundwater, once it has been used to wash
the fine silts out of the sand and gravel http://www.dufferinparispit.com/en/listening/Water.asp.
 As part of the PTTW process, MOE staff will review the application,
including potential environmental impacts.  Applications for PTTWs are
posted on the Environmental Registry for public comment http://www.ebr.gov.on.ca/ERS-WEB-External/.

Regards,

Ken

Ken Cornelisse
District Water Resources Coordinator
MNR – Guelph District
1 Stone Road West
Guelph , ON
N1G 4Y2
phone: (519) 826-6849
fax:      (519) 826-4929
Email: ken.cornelisse at ontario.ca

________________________________

From:Louisette Lanteigne [mailto:butterflybluelu at rogers.com] 
Sent: Tuesday, October 23, 2012
11:10 PM
To: Cornelisse, Ken (MNR)
Cc: Freeman, Linda (MNR); Stone,
Mike (MNR)
Subject: Re: Strange Snakes in Paris & reports
needed

Hello Mr. Cornelisse 
First
off I would like to thank you for the email response sent on October 22, 2012.
The communication is very much appreciated. Please allow me to recap briefly:

September 28 2012, by
email I requested to review terrestrial reports and as well as hydrogeological
reports regarding the property of the Dufferin Quarry Pit on Watts Rd. in Paris
Ontario which was approved 38 years ago and has yet to cut ground. 

The reason why I was
trying to secure the terrestrial reports and associated field notes was to
validate if studies were reasonably conducted to monitor for Jefferson
Salamanders and Blandings Turtles. You know from my previous OMB appeal
PL071044 that I am familiar with the protocols and procedures of such studies
because I hired experts to represent such issues. I also worked with a group
who was successful at securing new studies for Jefferson Salamanders in regards
to Hidden Valley . Previously Jim Bogart, the chair
of the Jefferson Salamander Recovery team stated there were no Jefferson
Salamanders on site in Hidden  Valley but after
scrutinizing the reports we found his theory was based on tests conducted
on rotten eggs. The group I worked with helped to secured a different method of
study incorporating the use of pit traps and toe and tail clippings that found
one of the largest population of Jefferson Salamanders in Canada , on
site. 

In no
way did that matter impair my respect for Mr. Bogart. He is a wonderful man,
highly accomplished and I admire his work greatly. In this case it was just a
matter of what samples were used and what methods were incorporated. With a
different approach to testing it achieved more accurate results and that is the
point I'm making with this. 

Mr. Cornelisse, in your
correspondence to me sent on October 22 2012, regarding concerns for
Blandings and Jefferson Salamanders you stated the following:

MNR is not aware of any individuals of these species, or
regulated habitat occurring at this site.  We also note that the onsite
pond is outside of the area where extraction will occur. Dufferin
aggregates hired consultants (Marshall Macklin Monaghan) to undertake
terrestrial and aquatic inventories at the site and they will continue this
multi-season study in 2013.  No species-at-risk have been found on the
site.

The
absence of data might not negate the risks. Lack of data may indicate flawed
test times and methods similar to what took place in Hidden Valley 
for example. I want to scrutinize the terrestrial reports to make sure test
times and methods being used are optimal to study specific species because
several area residents in Brant have already spoken with me about the Blandings
turtles on site and in the adjacent ponds surrounding this project. I went to Paris Ontario 
and I spoke with the residents and the turtles are common knowledge. The area's
residents have seen them for years along this area. That's why I'm trying to
get the data. It's hard for me to believe the company has not acknowledged them
by now. If there is a recovery strategy I want to see it to find out if these
animals are being reasonably protected. Based on the feedback I've had from area
residents, they are not. 

The
potential breeding ponds they mentioned lay on adjacent lands outside the 120m
buffer zones for this pit. If there are rare species located in the untested
ponds, activities on the proponent’s land still has the potential to
encroach upon their critical habitat. Blandings turtles travel to sandy areas
to lay their eggs. The sediment type of the proponent's property may make for
suitable nesting habitat. We need to know if the proponent’s property has
the potential to serve a function for the off-site threatened or endangered
species populations. We also need to know if they will be adversely impacted by
the draw down impacts of the water taking. 

The
Species At Risk Act (SARA) provides in no uncertain language that the purpose
is to ensure that critical habitat is protected. The MNR cannot reasonably meet
this objective if the ponds on the adjacent lands, outside the 120m bufferzone,
remain untested. I would like to request that there will be reasonable studies
conducted on the adjacent ponded features outside the 120m buffer zone to
assure compliance to SARA. If the animals are in the adjacent ponded areas,
they still must have a reasonable recovery strategy outlined to comply with the
law as written. 

In Brant's Official
plan it is clear the municipality has a mandate to protect threatened
species and habitats in sections 1.8.8, section 2.2.19, in section 3.3
etc. This policy as approved by the Province recognizes the power
municipalities have in regards to this matter. Any rare species in their
jurisdiction falls under this criteria and the Endangered Species Act cannot be
grandfathered. How in good faith, is the municipality and the public supposed
to assure policy compliance by the proponent if we cannot access
the terrestrial reports to scrutinize the data? That is not reasonable. 

I want
a copy of the terrestrial report either a hard copy or PDF. I also want to
review the field notes to see where and when they studied and what methods they
used. As a member of Frogwatch and the Ontario Turtle Tally, and the Ontario
Vernal Pool Association, I glean information from these types of reports for
the sake of establishing future policy recommendations to increase the
effectiveness of EA processes. My work with Frogwatch was referenced in the report Community Engagement for Adaptive
Management in Environmental Assessment Follow-up, John F. Devlin, Series 2011
produced by the Canadian Environmental Assessment Agency. Here is the link to
the PDF copy of the report.
http://www.ceaa.gc.ca/7F3C6AF0-docs/CEFAMIEAFU-eng.pdf

On
Tuesday September 25, 2012, I requested terrestrial and hydrological reports
from the Mark Pomponi, Brant  County 's General Manager
of Development Services. He emailed Water Services Alex Davidson to find out if
they had the hydrology data and stated the reports are incomplete. Here is the
response I received. 
________________________________
From: Alex Davidson 
Sent: Tue,25-Sep-2012 10:11 AM
To: 'butterflybluelu at rogers.com'
Cc: Jayne Carman
Subject: FW: Website message

The hydrogeo work is not complete.  

The attached July 9, 2012 letter report from Conestoga-Rovers
& 
Associates was presented at the July 10, 2012 Public Works
Committee.  
We understand that further hydrogeo info will be included with
an 
application for a Permit To Take Water.  This will be posted
on the EBR 
when received by the MOE.

Regards,
Alex Davidson
Water Division Manager
Countyof Brant
_________________________________________

Mr. Cornelisse, in your
correspondence to me sent on October 22, 2012 1:59 you stated the
following: 

Dufferin Aggregates has completed a thorough review of the
property in conjunction with the site plan and licence conditions to ensure adverse
impacts to the public and the natural environment are mitigated.  This
includes compiling more than 20 years of monitoring data in preparation for an
application to the Ministry of the Environment for a Permit to Take Water
(PTTW).
You stated that Dufferin
Aggregates has completed a through review of the property in conjunction with
the site plan and licence conditions. If that is true, why
is hydrogeological data regarding this proposal not yet
complete?  Why can't I access sediment studies or bore hole data? Normally
this information is pretty straight forward but nobody seems to be able to
provide it to me. Dufferin Aggregates produces more than 18 million tonnes of
aggregated per year. I find the absence of such basic information for public
scrutiny very disturbing. They've been through these processes before. Why are
they not sharing data regarding this proposal? I am trying to prepare my
commentary for when the water taking permit request goes online and it impairs
my ability to participate if I don't have reasonable access to that information
and reasonable time to scrutinize the data to provide comment. 
Mr. Cornelisse you
stated in the email dated October 22, 2012 at 1:59pm that 
The onsite wetland is within the water table and so it is
not dependent on surface water (unlike pond W12 in Waterloo ).  So the extraction and any
changes to the surface drainage area for the pond are not anticipated to impact
the wetland to any great extent.  This area is sand and gravel and under
the existing conditions, little surface water makes it to the wetland because
much of the water infiltrates into the ground.  I also note that the
extraction will create another water / wetland feature.

Mr.
Cornelisse, as much as I appreciate these predictions, without the data to
support it is simply hearsay. All wetlands and most groundwater features are
influenced by surface water infiltration at some point to achieve that baseline
water table but to understand flow and flow rates from point A to B requires
the hydrological data and sediment composition data so we can understand both
the geological connectivity under the ground as well as the topographical
influences at the surface level. Fluvial flows throughout the Galt Paris
Moraine system generally impact the first 12 meters down so if the bore hole
data isn't at a reasonable depth beyond that then we honestly cannot predict
the impacts to aquifers or predict the true hydrogeology of the area. The
public and the municipality need to be provided with the baseline data to plan
appropriately so we can avert externalizing costs onto taxpayers over the long
term. We have the jurisdiction as taxpayers to participate in the public
process. This data is fundamental to support the claims they make regarding
infiltration rates, protection of habitats and adjacent natural features. How
can anyone state they can reasonably protect on-site ponds in the absence of
this data? I don't even see any data relative to draw down impacts. That alone
can drain the ponds in this area on and off site. Where is the mapping for
this? 

In good
faith I did visit the this website you recommended at:  http://www.dufferinparispit.com/en/index.asp and in my view, it's like reading a marketing brochure. The mandate of the CAP
is to provide, encourage and facilitate two-way communication between
local residents/regional stakeholders and Dufferin Aggregates on operations. It
is designed to educate stakeholder groups and the community on aggregate in our
society and to maintain/improve relationships with neighbours and community
organizations. 

I don't
see their advisory panel as having the jurisdiction to entertain a “do
nothing approach” if their mandate limits them to address comments
“on operations”. 

On that
website there is the absence of the scientific data again. They seem to have a
water retention pond planned but no detailed data of the pond is posted up on
the site at all. Why not? If they sincerely want to facilitate honest
communication about this project it would seem reasonable that we should be
provided with the data in order to facilitate meaningful dialogue.

I
honestly have to ask, does the MNR  have the bore hole data ? If so is it
possible that I can use FOI to request it? It is very difficult for me to
believe the province would actually proceed to allow this project to manifest
fully in the absence of this critical information when the potential risks to
this community is so enormous. I do hope the province demands the release of
this information to avert risks. 

Again
Mr. Cornelisse, I sincerely thank you for your response. Forgive me if I seem
alarmed about this matter but it is an unusual project. I got involved after
residents asked for my help and when I reviewed the general information, it
appears to be quite a significant risk for this community, water supply and
rare species. 

In good
faith I hope to learn from this process and hopefully I can help to foster a
better way to get industry to free up the data so the public, municipalities
and provinces have the knowledge enough that we can collaboratively plan
together rather than relying upon unsubstantiated predictions. Good planning
begins with good data that is shared openly in good faith. If we don't get that
first step right than we risk significant externalized costs and risks. There
are ways we can work to avoid such scenarios and it is my hope I can
incorporate some of these concepts into the Aggregate Resource Act Revision process.
This project makes a great case scenario to support the need for more
transparency of data. 

Thank
you kindly for your time. 

Louisette Lanteinge
700 Star Flower Ave.
WaterlooOnt.
N2V 2L2

________________________________

From:"Cornelisse, Ken
(MNR)" <ken.cornelisse at ontario.ca>
To: Louisette Lanteigne
<butterflybluelu at rogers.com> 
Cc: "Freeman, Linda
(MNR)" <Linda.M.Freeman at ontario.ca>; "Stone, Mike (MNR)"
<mike.stone at ontario.ca> 
Sent: Monday, October 22, 2012
1:59:58 PM
Subject: RE: Strange Snakes in Paris & reports
needed

Dear
Ms. Lanteigne,

Thank
you for your email of October 14, 2012, sent to Mike Stone, regarding the
Dufferin Aggregates Pit in Paris  Ontario .  I am responding
to your email on behalf of Mike.

Firstly,
I would like to make you aware that this site has been licenced under the
Aggregate Resources Act (ARA) since 1974.  As such there is no current
“planning process”.  However, Dufferin Aggregates has
established a Community Advisory Panel (CAP) which provides the public with an
opportunity to discuss concerns and share information. Information about the
CAP can be found at http://www.dufferinparispit.com/en/index.asp.

Though
this site has been licenced since 1974, the Licensee, Dufferin Aggregates, must
abide by all current legislation which regulates pits and quarries in Ontario including the
ARA and the Environmental Protection Act (EPA) and the associated
regulations.  They must also comply with the approved site plans and
licence conditions for the pit, as well as the Endangered Species Act. 
Dufferin Aggregates has completed a thorough review of the property in
conjunction with the site plan and licence conditions to ensure adverse impacts
to the public and the natural environment are mitigated.  This includes
compiling more than 20 years of monitoring data in preparation for an
application to the Ministry of the Environment for a Permit to Take Water
(PTTW). Upon receipt of the application, MOE will post the proposal on the
Environmental registry for public input.

I did
consult with Graham Buck, Species-at-Risk Biologist, about your questions on
Blandings turtles and Jefferson 
salamanders.  As you know, Blandings turtles and Jefferson 
salamanders are listed under the Endangered Species Act as
“Endangered” and “Threatened” respectively.  MNR
is not aware of any individuals of these species, or regulated habitat
occurring at this site.  We also note that the onsite pond is outside of
the area where extraction will occur.  Dufferin aggregates hired
consultants (Marshall Macklin Monaghan) to undertake terrestrial and aquatic
inventories at the site and they will continue this multi-season study in
2013.  No species-at-risk have been found on the site.  As with any
private lands, the landowner must comply with the Endangered Species Act and
its regulations.

The
onsite wetland is within the water table and so it is not dependent on surface
water (unlike pond W12 in Waterloo 
).  So the extraction and any changes to the surface drainage area for the
pond are not anticipated to impact the wetland to any great extent.  This
area is sand and gravel and under the existing conditions, little surface water
makes it to the wetland because much of the water infiltrates into the
ground.  I also note that the extraction will create another water /
wetland feature.

Regards,

Ken

Ken Cornelisse
District Water Resources Coordinator
MNR – Guelph District
1 Stone Road West
Guelph , ON
N1G 4Y2
phone: (519) 826-6849
fax:      (519) 826-4929
Email: ken.cornelisse at ontario.ca
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://gren.ca/pipermail/all_gren.ca/attachments/20121025/e4289e3b/attachment.html>