1. There is overwhelming…

1. There is overwhelming evidence and scientific agreement that significant climate change is underway and certain to become more severe. Climate change means amounts of rainfall and water availability are becoming increasingly variable and uncertain. Consequently this suggests 10-year water taking permits are unwise and inappropriate. These permits must be re-examined more frequently than once a decade.

2. Hamilton Golf and Country Club is a 27-hole course. Chedoke Golf Course, also in Hamilton, is a 36-hole course and it utilized less than 50,000 cubic metres of water last year. Consequently the more than 4.2 million cubic metres a year sought by HGCC are grossly exaggerated – more than 80 times as much for a smaller course.

3. Water usage in Hamilton has declined sharply since modification of water rates to charge for specific usage. The comparatively larger Chedoke golf course within Hamilton’s urban area is irrigated with municipal water. In contrast, HGCC appears to rely on ‘free’ or very low cost surface and groundwaters extracted from the surrounding environment. This is competitively unfair and may explain the gross size of the permit application by HGCC. This course has much much more expensive user rates, so certainly is more than capable of paying for municipal water.

4. Aside from the competitive issue, the practice of extracting water from the natural environment for recreational purposes needs to be re-examined in the light of both the climate crisis and the accompanying biodiversity crisis. The latter crisis is certainly being exacerbated by this extraction practice. At minimum, this extraction should carry a similar cost to that experienced by individuals and institutions filling swimming pools. The Hamilton area frequently experiences low-water and drought conditions. Recreational and profit making corporations should not be allowed to worsen those conditions.

5. The proposal doesn’t provide sufficient detail about the extraction sources including well locations, ponds utilized and specific location of extraction activities. Mapping suggests at least one of the ponds is actually part of Ancaster Creek – an in-line pond or immediately adjacent to the creek – so its takings are really additional to those identified as from the creek itself.

6. The entire golf course and adjacent woodlots are identified as an Environmental Significant Area (ESA) in Hamilton’s Official Plan. This designation is because the site “provides habitat for significant species” including vascular plants and breeding birds. “Under the OMNR Areas of Natural and Scientific Interest program this general area is considered a Life Science Area of Local Significance.” (p28, Hamilton-Wentworth Natural Areas Inventory). Additional ESAs are located along the downstream creek.

7. The golf course, despite its ESA status, does not appear to follow the guidelines of the Hamilton Conservation Authority. The HCA subwatershed report identifies three primary ecological stresses: “Insufficient riparian buffers (recommended width of 30 metres for coldwater systems) along creeks; The degradation of terrestrial habitats, and; Online ponds.” The report specifically calls for landowners to “re-establish riparian buffers where there are none and increase the width of existing riparian buffers”. Although some of Ancaster Creek flows through wooded areas on the golf course, the majority of the stream length within the property does not appear to have any buffers at all.

8. The proposed time frame for extraction is unnecessarily absolute. There is no likelihood that a golf course will irrigate 365 days of the year. Months such as November-March would be unlikely to require any water taking.

9. The mapping provided fails to show the main course of Ancaster Creek downstream of the golf course and instead incorrectly shows the creek ending shortly after exiting the golf course. This is inaccurate and significantly disadvantages downstream residents and users. There are currently major development proposals at 140 Garner Road East in the headwaters of Ancaster Creek that if implemented will degrade remaining ecological features of the creek. Downstream of the golf course there is significant work being undertaken to restore habitat and support cold water aquatic species including potential Species at Risk like Northern Sunfish. And a marsh restoration project is being advanced by McMaster University on the lower reaches of the creek. The implications of golf course water taking for these efforts should be carefully considered.