Puslinch approves new protocol for commenting on aggregate site plan amendments

PUSLINCH – Councillors in Puslinch voiced frustration at the Ministry of Natural Resources and Forestry (MRNF) for its authorization of a new aggregate site plan amendment prior to receiving township comments.

On June 17, Puslinch council received a report stating that the MNRF has authorized CBM Aggregates to begin Lake 3 extraction at the Roszell Pit before receiving comments from the township’s consultant, Harden Environmental.

The original reviews were completed by Groundwater Science Corp and Dance Environment Inc. and were submitted to the MNRF in late November.

The reviews showed that Lake 3 extraction was “feasible,” and the MNRF authorization and below water extraction began on Feb. 4.

However, as Puslinch councillor Matthew Bulmer pointed out, CBM’s request to move to Lake 3 extraction came to council in January, and less than a month after Harden Environmental was asked to review the request, the ministry had already authorized the extraction.

Council wasn’t able to submit any comments until April.

Senior hydrogeologist Stan Denhoed had six comments in a May 29 letter.

He said the below-water extraction from the operation is impacting the water table upgradient from the extraction area.

The magnitude of this impact is greater than originally predicted even without the extraction of Lake 3, Denhoes wrote.

He added it is necessary to re-evaluate the potential impact of lower water levels on private ponds and shallow wells south of the extraction area.

He indicated that data on groundwater conditions at some locations shows declining trends in water levels and periods of stabilized water levels between 2012 and 2020.

“This is not due to regional influences as other sites in Puslinch Township do not have a similar water level pattern,” Denhoed wrote.

While the water thresholds in some areas have not yet been breached, he warned water levels are trending towards a potential breach even without Lake 3.

“We concur with the additional ecological monitoring planned, further monitoring of water levels and evaluation of whether or not additional mitigative measures are necessary,” Denhoed wrote.

He recommended residents with shallow wells should be contacted by the licensee and provided with an updated complaint protocol.

He also recommended that the susceptibility of shallow wells and ponds to additional water level change should be evaluated.

“This is a proactive approach considering the observed decline in water levels,” Denhoed wrote.

He also said the township should be notified of any complaints of low water levels in ponds or wells.

The municipality will be sending the Harden Environmental letter from May 29 to the MNRF and CBM.

However, Puslinch council went one step further.

Bulmer suggested putting a standing protocol in place that would allow the township to object to any requests to the MNRF for a site plan amendments so that consultants have time to provide comments.

“You can see how quickly this thing went,” Bulmer said.

“We may not have time to even get it on our agenda, get it to our consultant and back again.

“It won’t take away our ability as a council to decide whether we ultimately agree with the change or not, it just puts the brakes on it temporarily so we can get our comments together.”

Mayor James Seeley said he supports the position.

“I feel this is just another example of the municipality just being some red tape in the way of the aggregate industry,” Seeley said.

“They got their approval before we were even able to get our professionals to evaluate the situation.”

He added, “It’s always easier to object and then have our professionals look at it and then refute back to the original approval.”

Bulmer said the protocol would be for any aggregate operation site plan amendments that don’t have any official timelines.

“The township objects, subject to the review,” he said.

“Explain … this will go before our consultants and council, and council will still have the opportunity to decide when it gets to our agenda, but it would be for any aggregate applications applying for a site plan amendment.

“We really don’t know if we’re supportive of it until we get the comments back from our consultant.”

Council approved the new protocol.

In the future staff will be able to make the objection to the MNRF and on the next council agenda they will include what has been forwarded to the consultant for comment.

“We’ll bring comment back to you once we receive them along those lines,” said CAO Glenn Schwendinger.

“Just so there’s a formal record that that’s what’s been done and it’s in process.”