Comments received were reviewed and where appropriate were considered in the ministry's decision whether or not to proceed with this proposal. In this case, comments were consistent with concerns within the ministry and as a result terms and conditions were added.
These conditions do not represent all conditions imposed on the instrument holder but rather those that are directly in line with comments received.
The comments received through EBR and the public meeting held by the proponent and his consultant on February 21, 2002, were 114 individual comments and 3 petitions with a total of 130 signatures.
The comments of the different individuals can be summarized and categorize into the following concerns:
Of technical nature:
1. There was not enough information on the characteristics of the aquifer, such as, extent, depth, thickness, hydraulic connection to other aquifers in the area.
2. Unknown long term effect of the proposed taking on neighbouring wells, wetlands, tributaries to the Grand River and to the water resources in the area.
3. Lack of information on the existing hydrologic cycle for the area (water budget), thus, the sustainability of the proposed takings unknown.
4. Inadequacy of the pumping tests and monitoring.
5. Inconclusive field data.
6. Unknown impact of the proposed takings on the existing lowering trend of the water levels in the area.
7. Unknown impact of the taking on the water quality in the area.
8. Concerns that the Middlebrook Well is under the influence of surface water.
9. The proposal should conform to the findings, conclusions and recommendations of the municipal groundwater management study. Conditions of the permit to reflect adherence to findings and municipality's interests.
10. Whether or not the Middlebrook Bottling Co. will submit to water restrictions that are imposed on the municipal wells during drought periods.
11. Requesting that a protocol for resolution of water well interference be included in Permit.
12. Requesting monitoring of well water levels, ground and surface water quality and surface water levels and baseflows.
13. Requesting that the PTTW is always conditional on continuous assessment of the monitoring impacts.
Of general nature:
A. Water is a public trust (resource), thus; the permit should not be issued for water bottling purposes (financial gain).
B. Requesting the Ministry to change policy to prioritize water uses and to utilize that policy to issue PTTWs.
C. Requesting the Ministry to protect the groundwater resource and to administer it responsibly.
D. Objecting to the Ministry funding municipal groundwater management studies and permitting water withdrawals for bottling purposes.
E. Requesting the area be designated for the purpose of water supply for the public under Section 33(1) of the Ontario Water Resources Act.
F. Opposing proposed takings on the basis that the Ministry does not have an inventory of the groundwater resources for the area or the province.
G. Opposing bulk water takings leaving Ontario.
H. Because the community has been subject to severe water shortages, permitting water takings for bottling and exports is frivolous and irresponsible use of the groundwater.
I. The municipality's Official Plan should be responsible for regulating water bottling and other uses of water.
J. The Middlebrook Well is used as back up during fire emergencies, thus, the well belongs to the community.
K. The proposed water takings will endanger future municipal takings and water resource availability for future growth (residential, commercial and industrial).
L. The daily proposed takings are equivalent to the daily takings of Elora with a population of 3,000 people.
M. Objecting to other environmental implications of the water bottling industry: garbage creation in the form of plastic bottles, noise pollution, air pollution and deterioration of public roads.
N. Inadequate public consultation both through the EBR and through the public meeting held by the proponent.
The technical review of the permit application typically includes the assessment of the concerns expressed in points 1 to 8.
The requests described in points 11 to 13 will be addressed in the Permit.
The rest of the comments are outside the scope of the review.
Rosa C. Stewart