Despite being characterized as “low risk,” many of the activities proposed for exemption pose known and foreseeable risks to private wells, municipal source water, groundwater-fed streams, wetlands, and downstream surface waters, particularly when considered cumulatively and under increasingly volatile hydrologic conditions. The Ministry’s assertion that these exemptions will not impact protection of human health or the environment is unsupported and contradicted by established hydrogeological science.
ORA’s concerns apply equally to the supporting Appendix, which relies on categorical assumptions of ‘low risk’ without evaluating groundwater connectivity, cumulative effects, or climate-driven hydrologic change.