14. Risk and Private Rural Wells Filthy water cannot be washed Published in The Journal of Policy Engagement, Nov. 2009 Ontario Centre for Engineering and Public Policy
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16. Risk and Private Rural Wells Ten Years After Walkerton : What have we learned?
23. Thank you to the Committee of the Whole, Municipality of Grey Highlands
Editor's Notes
We are the Beaver Valley Ratepayers. I am vice-president Ed O’Neil and this is president, Cathy Little.
Thank you for giving us this opportunity to speak to you today. This is an outline of our talk.
We were incorporated in 2002.
We speak for the 125 existing homes in the Beaver Valley settlement area. These homes are along Windy Lane , Bowles Bluff Rd., Grey Rd 30, the Seventh Line and the Beaver valley Crescent Subdivision southwest of Hutchisons’ Corners. We also represent some residents below the brow of the escarpment.
At the 2008 BVRA AGM in Kimberly, members packed the hall because of concerns about the proposed Beaver Valley Village Subdivision. Again at the Beaver Valley Village public meeting, the Rocklyn Community Centre was full. Members and property owners voiced their concerns regarding this development proposal.
This is a map of the area of the proposed subdivision. The turquoise area is the Beaver Valley Ski Club and the orange area is the proposed Beaver Valley Village subdivision. The Beaver Valley Village is a 45 lot subdivision packed on approximately 7.5 hectares of a 29 hectare site. The major portion of this site consists of hazard land and wetlands. The land is in the Niagara Escarpment Plan area and designated Escarpment Recreation. Grey Highlands has development control of the area. Our people have concerns about the quantity and quality of water when new subdivisions are built. But even more concerning is the fact that peer reviewers have concerns and these peer reviewers have a lot more expertise than we do. *****We understand that there are proposals for 103 more homes. There are another ((( 53))) lots that could be developed, so we have 125 existing homes and we are going to (((more than))) double the number of homes in our area. (((CHECK THESE NUMBERS.)))DONE MOE – 45 BVV + 42BVSC + 4BVSC + 12BVW = 103 SCS – 255 (125 developed, approx. 47 approved and potential 45 BVV, 7 BVSC) potential - #95 (1) (9.87 ha), #90 (5) (18.28 ha), #142 (14) (9.6 ha), #156 (11) (7.6 ha) (total potential lots = 31) #95 – 9.87 x 3 = 30, # 90 (said 5 – 10 ), #142 – 9.6 x 3 = 29, #156 – 7.6 x 3 = 23. Real potential = 92 lots not 31 lots. Potential total – 316 lots.
The number one concern of BVRA members and local property owners is water. PAUSE FOR SLIDE The AEMOT Groundwater Management Study, Final Report, 2001 identified this area as “ on e of the most sensitive groundwater management areas in the Province “(pg 104). (((Mapping from the Study shows the site of the proposed subdivision exists within a “High Aquifer Vulnerability area” and a “Recommended Protection Area for Groundwater”))). Many residents already experience water shortages, wells going dry, turbid and contaminated drinking water. The potential for negative environmental impact on the quality and quantity of water from this proposed 45 unit subdivision is real. The Settlement Capability Study uses very complex formulas and very little well testing and concludes that we will not have problems with our water. We know differently -- we have the practical experience and we have well problems.
We assume you are tired of hearing from delegations primarily against all development, but our concerns are real. We are concerned about Groundwater uncertainty Risk of cumulative negative impact and Density We have done our homework. We have been monitoring this application since 2008, have read all the documents and correspondence. We are impressed with the process so far, particularly the work of the peer reviewers for the Municipality and the County. In additiion, the BVRA has been advised by planner, Ron Davidson and hydrogeologist, Ray Blackport. With all due respect, the proponent is focused on the bottom line: to get approval for as many lots as possible. The justification for this application is often misleading, incomplete or even wrong in some cases. The residents too, have a bottom line: to minimize the risk to the quality and quantity of potable water to local residents now and in the future.
Groundwater hydrogeology is a complex system made even more complex by the presence of karst, This is the situation in this proposed subdivision location. In the opinion of the peer reviews, inadequate knowledge of local groundwater is being used to justify this development. Local experience has been neglected. Failure to inform residents of well pump tests was interpreted as “no reports of adverse interference.” Anecdotal evidence about contaminated water, water shortages, and seasonal fluctuations was excluded in from the assessment of the availability of potable water. There is resistance against implementing a monitoring program of local residents’ wells as recommended by both peer reviews. One would think that if someone really wanted to learn about the water situation in an area, someone would ask the people who live here. We support the peer reviewer recommendations including overseeing the writing of draft plan conditions.
Read slide.
Peer reviews have consistently pointed out inadequate assessment of both the area hydrogeology and the karst topography. Marcus Buck continues to be unconvinced by the Karst Report. In the opinion of RJ Burnside, while major problems with the assessment of hydrogeology persist, most can be addressed in the conditions of draft approval either before or while development begins. Ray Blackport, the hydrogeologist who advised us, believes more work should be done to better understand the site hydrogeology .
The position of the Ministry of the Environment is clear. READ Ministry of the Environment concern about cumulative environmental impact and the appropriateness of the servicing proposed is made more relevant by the other development in the immediate area either proposed or approved. There are 103 residential lots being proposed. Servicing should be reflective of and appropriate to this context. _________________________________________________________ None of the reports that we have seen have evaluated the cumulated impact of 45 new units not to mention the 103 new units on existing well water -- quantity and quality. HAVE VERIFICATION ON HAND. (((These numbers do not even consider the 47 already approved lots and the 90 potential lots.)))
A Settlement Capability Study, completed by the proponent as a requirement of the County of Grey did nothing to change the position of the MOE. PAUSE AND READ THE SLIDE The study does not address the fundamental question: What is the most appropriate way to service a settlement of this scale in this location with identified issues in an environmentally sustainable way? ______________________________________________________ RJ Burnside raises the question whether the Ministry of the Environment has actually provided clearance to the County with respect to the Settlement Capability Study and the servicing options. Grey Highlands OP and Niagara Escarpment Plan both require that a development proposal on private services must meet the requirements of the MOE.
Filthy water cannot be washed is an African proverb which expresses a principle that guides the management of water resources throughout the world. It is more sustainable–that is, less expensive economically, more socially responsible and better for the natural environment– to maintain a pristine water supply than to treat water once it has been contaminated. It is also the title of a southern Ontario study looking at the health of groundwater in fractured bedrock soils, published in 2009.
This study concludes: “ Further source water protection initiatives are imperative to protect the health of those consuming groundwater From private rural wells especially in sensitive settings .”
After the Walkerton water tragedy, the recommendation of Justice O’Connor to protect drinking water at the source has resulted in Ontario’s Clean Water Act . This legislation requires communities to develop source protection plans on a watershed basis in order to protect their municipal sources of drinking water. Unfortunately,the timetable extends beyond 2012 and rural wells are not even on the current agenda.
WHAT HAVE WE LEARNED? The first lesson Is that humans are part of the environment. What should be clear from Walkerton is that environmental management is not just about nature, but also about human health and safety. 2. The second fundamental lesson is that we need to look at the big picture: The social, economic and environmental The community interests and Sustainability of the watershed.
The AEMOT Study recommended that participating municipalities have groundwater management plans. Grey Highlands can be commended for including in the Official Plan, acknowledgement of the importance of groundwater to the Municipality and intention to incorporate groundwater management policies into the Plan.
There is no evidence that a groundwater management plan has been used to evaluate this development proposal. Consequently, there is an opportunity for the Grey Highlands Planning Committee to honour the acknowledgement and intent in the Official Plan by implementing the peer reviewer recommendations, in order to protect groundwater quantity and quality in the Beaver Valley Settlement area.
The density of this proposal and individual servicing are incompatible. Since municipal services and communal services are deemed to be unfeasible, density of this subdivision is a key issue and must be reduced to comply with planning policy. PAUSE AND THEN READ The proposed lot size of this development is only half of the 4000 m 2 recommendation of Grey Highlands Comprehensive Zoning Bylaw 7.1.2 Provincial Policy Statement 1.6.4.4 - recommends new development of 5 lots or less on individual private services According to the MOE, a development of this size on individual services is not appropriate. Grey Highlands OP 4.9.3 d) New privately serviced residential units should not exceed 3 units per ha. _________________________________________________________________________________________ ThIs 7.5 hectare developable area with 45 homes works out to 6 units per hectare. The developer is proposing to calculate density including the wet and hazard lands. We cannot believe that this is the intent of the policy. If so, what stops the next developer from buying land with large swamps and arguing for development on 20 ft. wide lots. The statement in the hydro-g report that development consists of widely-space wells on relatively large lots is just not true.
READ The BVRA supports sustainable development. We would be willing to support this development if: the MOE approves, an independent cumulative impact study is completed for BVVSA before development, groundwater management strategies are implemented before development, the most cautious interpretation of Provincial Policy Statement, Official Plan policy and Zoning Bylaws is used in determination of density, all peer review recommendations are implemented, a reasonable enforcement plan for conditions of draft plan approval is implemented.
We have respect for council and we do understand the difficult responsibility council has, in addressing apparently competing needs. However, short-term thinking that focuses solely on economic revenue jeopardizes one of the biggest economic assets Grey Highlands has – it ’ s environment. The natural, beautiful and healthy Beaver Valley attracts people here and keeps them returning, often to move or retire here. We trust that council will take the long view and consider this application in the context of the whole settlement area and in the most cautious and most sustainable way. Long after the developers have moved on, we will be living here with the consequences of this decision.
Thank you to the Committee of the Whole for giving us this chance to address you. If you have questions, we would be happy to try and answer them for you.
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