Ms. Nancy Mott-Allen

Regional Municipality of Halton Dec. 18, 2007

1151 Bronte Road

Oakville, ON

Planning and Public Works Department

Re: Review of Hydrogeology and Water Related issues of Proposed Nelson Aggregate Quarry expansion

Dear Ms. Mott-Allen and JART members,

Please find attached the Blackport Hydrogeology review of the September 2007 Golder Water Reports and addtional earlier reporting by Golder, Worthington Groundwater and Wilf Ruland.

This review was prepared at the request of PERL to assist the Joint Agency Review Team and the public in developing an appropriate level of understanding of water issues in the Mount Nemo source water area for decision making on the Nelson application.

Mr. Blackport’s findings, in consultation with Wilf Ruland, reveal major problems with the Golder reporting. These include inaccuracies on critical issues, conclusions based on these inaccuracies, insufficient reporting, contradictory conclusions, misleading data, discrepancies with earlier reports, and a lack of adequate characterization and required information.

Wilf Ruland’s time has been very occupied with health concerns of his young daughter, but he remains an advisor to PERL. Together with Mr. Ruland’s reports of 2005 and 2006, the Blackport Hydrogeology review further exposes major problems with the Nelson proposal.

PERL was not officially informed of the September 2007 new Golder reports. When we requested the reports from JART the former Chair was reluctant to share them with the public. PERL received the reports a month and a half after they were submitted to government and therefore our experts have had a short time frame for assessment.

Upon review there remains a lack of basic information, including a reliable area water balance which, we were informed in JART/PERL meeting of Jan 9^th 2007, JART has requested from Nelson since 2005. The lack of an area water balance creates an inability to predict the extent of impact of dewatering on adjacent water users and loss of base flows to surface water features. Further, there are major problems with lack of thorough karst reporting and conclusions. As the Blackport review demonstrates, there is the potential for a major karst conduit as indicated by Worthington Groundwater observations and data, and additional Golder data, not reviewed by Worthington Groundwater. Even if a major Karst conduit does not exist, there is clearly a connection between the many springs in the Medad Valley and the area of the proposed quarry expansion. The proposed expansion area is a significant part of the capture area for Lake Medad. Additionally, the critical issue of overburden conductivity has been poorly conducted with significant discrepancies between earlier and later reports. These are just a few examples of the major problems uncovered by this review. Our experts tell us we have reason to be concerned.

Mr. Blackport is available to discuss these technical findings and we would like to meet with JART experts and peer reviewers at your earliest convenience. We hope this review will be helpful in assisting JART members with an appropriate level of technical understanding of the critical water issues inherent in this application.

I look forward to hearing from you shortly to discuss meeting arrangements.

Yours very truly,

Sarah Harmer

Co-Chair

PERL

cc. JART members

Dave Webster (MNR)

Chris Neville (Papadopulos)

Ray Guther (Conservation Halton)

Ray Blackport, Blackport Hydrogeology

Wilf Ruland, Hydrogeologist

David Stephenson, Natural Resource Solutions Inc.

Protecting Escarpment Rural Land 40572 Upper Brant Postal Outlet Burlington ON L7P 4W1