Beverly Golf and Country Club Limited - Permit to take water

The City of Hamilton provided the following comments:

1. We are aware that this is a renewal without new takings, however it is our opinion that MECP shall use due diligence in their approval process especially in the context of climate change emergency (as declared by the City of Hamilton) and the presence of long term monitoring data. The initial radius of influence delineated at the time the Permit to Take Water (PTTW) was issued should be calibrated based on the current data to determine potential impacts to nearby groundwater users.
2. A number of private well owners specifically along Concession 2 West utilize a shallow overburden aquifer for their water supply, with well depths typically around 10 metres below ground surface. The hydraulic connection between the overburden and bedrock aquifers is unknown, but based on local water well record logs, there is a lower likelihood of a hydraulic connection between the overburden and bedrock aquifers.In contrast, well owners along Inksetter Road and Highway 8 (Flamborough) have wells installed predominantly in the upper bedrock, likely using the same hydrostratigraphic unit as used by applicant for the large takings within their PTTW. Given that the upper/fractured bedrock interface has the potential to be highly transmissive, the radius of influence from water taking could extend larger distances.
3. If not already conducted, a door-to-door water well survey of properties within the radius of influence should be undertaken. If the radius of influence does not take a conservative approach, it is recommended to extend the survey to properties beyond the proposed radius of influence to validate the hydrogeological conceptual model. Given the typical depths of wells from local water well users as well as small private lots could access similar hydrostratigraphic units for water supply, the susceptibility of potential interference issues could arise.
4. Groundwater level monitoring of properties on private wells should be regularly monitored during periods of water taking to ensure no interference issues arise.
5. An impact mitigation plan should be established. Triggers related to low water conditions on site and Watershed Low Water Conditions (as established by the local Conservation Authority) should be included in the monitoring requirements to ensure that if reached a clear plan for next steps and required actions are formalized if not already completed.
6. The property entirely falls within a Significant Groundwater Recharge Area as determined by Source Protection mapping. As a result, water efficient irrigation practices and water re-use initiatives is strongly encouraged.

Following is the ministry's response to those comments:

1. The zone of influence of three wells have not been delineated because the taking is less than 50,000 lpd and three wells are included in the permit for administrative reasons. No monitoring was required or any groundwater monitoring data is available.
2. The groundwater taking at this site is from a deeper depth (bedrock) compared to the private water supply from the shallow overburden. The private water supply wells are unlikely to be hydraulically connected with the bedrock aquifer though this has not been confirmed. Given the nature of groundwater taking (relatively small amount and seasonal) and rural land use setting, the taking from the bedrock aquifer at this site is not expected to negatively effect the private bedrock wells in the area.
3. As outlined above, the zone of influence has not been delineated and a door to door survey is required to identify receptors prior to well testing in order to predict impact on the receptors as a result of taking. The groundwater taking at this site is less than the regulatory mandated threshold and a door to door survey is not required to validate the conceptual hydrogeologic model as it does not exist. There is no history of water well quantity interference complaint due to taking from three bedrock wells at this site.
4. No history of water quantity interference complaints in the surrounding wells and none is expected considering the site history and nature of taking. There is no need to institute a groundwater monitoring program.
5. Low water conditions or advisory does not apply to the groundwater taking as the wells are completed in the confined to semi-confined bedrock aquifer (deduced from well records). The Ontario Low Water Advisory program is a voluntary program run by the Conservation Authority and MNRF and was not intended to be part of MECP compliance.
6. This question was deemed not relevant to the groundwater taking.