Open-pit mining is never a “no impact” operation. Nowhere is this more evident then when observing the enormously disruptive impacts to life-sustaining water ecosystems that are produced by the industrial extraction of aggregate—whether it be to an aquifer that supports human habitation, or to wetlands and habitats that support species diversity. Water flow, capacity, and quality are all significantly disrupted by open-pit mining.
The proposed new mining operations will result in higher demands for taking-water from the Mount Nemo aquifer, because of increased de-watering, which are estimated will be 50% of the total water taken from the Mount Nemo aquifer. The impacts of these increased take-water activities, in addition to threats to the aquifer from the climate crisis, need to be fully assessed and understood. The wells near the proposed west quarry (currently golf course) are expected to see significant impacts. The negative impacts on the ecosystem of this increased level of water extraction from the aquifer must be thoroughly investigated and addressed, including 100 year historical data, and 100 year projected climate data. The groundwater and surface water availability has significantly decreased in the last century: this from historical, media and anecdotal accounts.
The hydrogeological and hydrological reports submitted by Nelson Aggregate contain worrisome inconsistencies and lacking information. First and foremost, the impacts that a warmer, drier climate will have on the aquifer and the water table are a serious concern to area residents. Several of the conclusions presented in these reports are based on past outdated research information. Future climate projections (which are readily available, supplied by the government) must be used to predict worst-case scenarios for the next 50-100 years. Climate change (drying and hotter) effects will almost certainly deplete water-levels, potentially increasing the stress on local wells. The aquifer itself will be impacted, which is something Nelson Aggregate’s studies do not deny. The aquifer is the source of the abundant and safe drinking water for local wells. Well depletion and failure mitigation must be strengthened, regardless of the effects of climate change, such that safe, abundant drinking water will never be compromised. The Nelson well interference and mitigation program is inadequate, seems to deflect cause away from the quarry, and is too conflicted.
We also have concerns with the manner in which the study measures draw-down baselines for wells. It seems that test-wells were used in order to estimate the 2.0-3.8m of “acceptable” drawdown from the local aquifer. Who decides acceptable draw-down, when a well is shallow, or already at maximum depth? The reference well, located to the north of the existing quarry, may not be an accurate representation of the real-case scenario of the impacts on wells to the south and west of the quarry. The assessment cited in the report may not accurately reflect the potential long term impacts of the proposed new pits on the wells located in these areas.
We also have several concerns with Nelson's current permit to take-water (PPTW). What happens to that permit if the plans for rehabilitation and public ownership are approved and undertaken? Who will take responsibility for the continued operation and maintenance of the water-pumping system? Since water-pumping has been a part of Nelson's current mining operation for 70 years now, there are several ecosystems that have become dependent on this man-made modification to the natural environment. This pumping cannot be terminated without risking negative impacts on these dependent wetland and watercourse ecosystems.
In the hydrogeological and hydrological reports there are claims—based on an assumption that there are no connections between surface-water / wetlands and groundwater—that there may be no negative impacts to local wetlands when groundwater is disturbed and/or removed from the ecosystem. Nelson has to provide determinative proof that this is the case.
We have very serious concerns with potential groundwater / well water contamination, which we address under ‘construction fill’ section.
On behalf of the beavers who make their home in this quiet pond on Burlington's escarpment, we thank you for writing your opposition letter. This oasis of healthy water and forest is just 2.8kms north of Burlington Springs golf course; the golf course is now a target for one of Nelson Aggregate's two new open-pit mines.