Brief to EBR on Source Water Protection

2003-09

Concerning Source Water Protection

Ashfield Colborne Lakefront Association (ACLA)
Mailing Address: ACLA
Box 277, Goderich, ON
N7A 3Z2

To
Dawn Landry, Policy Adviser
Strategic Policy Branch
135 St. Clair Ave. West, 11th floor
Toronto, Ontario, M4V 1P5

Re: EBR Registry Number: PA04E0003 -- White Paper on Watershed-based Source Protection Planning

The Ashfield Colborne Lakefront Association (ACLA) is a loosely organized umbrella group for twenty-one beach associations along the Lake Huron shoreline from Amberley to Goderich. The Association represents approximately 600 mostly seasonal and some permanent residences along the lakeshore. Environmental issues are of primary concern to the association and its members. ACLA is in the fourth year of an extensive stream testing program in cooperation with the Maitland Valley Conservation Authority.

We welcome the initiative the government has taken to implement Source Water Protection and generally like the open and consultative nature of the planning process. We trust that all information generated by the planning process will be available to the public without having to resort to the Freedom of Information Act.

• We believe that Source Water Protection must take primacy to all other acts -- specifically the Nutrient Management Act. Unfortunately the Nutrient Management Act treats all areas uniformly which ignores the fact that certain regions pose considerably more risk to groundwater contamination than others. For example the manure loadings in the Maitland watershed are the highest in Canada and it is already a high-risk area.
• We would like to offer a suggestion pertaining to the public consultation process. Given that our membership is largely seasonal and quite often does not subscribe to local papers, we hope that sufficient funds will be set aside to create websites specific for each planning area. Or to put it differently, all documents, maps and other material should be available in electronic format for access through the Internet.
     As lakeshore residents we have a vital interest in source water protection since groundwater can have significant impact on surface water -- in our case, our beaches. As well many of our members in common with rural residents in general draw drinking water from private wells which may be vulnerable to groundwater contamination.
     The seasonal nature of residents is not unique to our area on Lake Huron, but is widespread throughout the Province along the shores of the Great Lakes and in the traditional cottage areas north of Toronto.
• When grouping Conservation Authorities to work together during the planning process, we would urge that particular attention be paid to similar land use patterns within each watershed. Feedback in this regard from individual conservation authorities in this regard should be given due consideration. In our area the Maitland Valley Conservation Authority, the Ausable Bayfield Conservation Authority and the Saugeen Valley Conservation Authority share common agricultural land use without very large urban areas.
• We view the requirement for 100% agreement by local municipalities of draft source water protection plans with some skepticism. Our concern is that the legislation will be rendered ineffective with this requirement. A mechanism should be established whereby the Ministry could override local resistance.

Submitted on behalf of the Ashfield Colborne Lakefront Association by: