The Clean Environment Commission public hearings started in Steinbach on Monday, for a project that has been proposed for Vivian, east of Anola near the Highway 15 and Provincial Road 302 intersection.
Sander Duncanson is Co-Chair of Osler, Hoskin and Harcourt's Regulatory, Indigenous and Environmental practice. He says the purpose of the hearings is to consider the environmental impacts of Sio Silica's project. He notes this project is quite different from past Clean Environment Commission hearings, such as some Manitoba Hydro megaprojects. He notes while those hydro projects impacted large areas of forest, wildlife habitat and aquatic ecosystems, the Sio Silica project has a relatively small footprint in an area that already contains extensive development and agriculture.
Duncanson says if approved, this project will consist of a number of individual wells similar to typical water supply wells, that will be drilled and operated over a period of weeks in any given area, before moving to the next area.
"These wells will be connected to some small mobile equipment and above-ground slurry lines but after the short period of extraction operations in each area, Sio will close the wells and reclaim the disturbed land allowing it to return to how it was previously," he explains.
Duncanson says the impact of this project on the surface environment will be quite minor. Sio has hired a team of expert environmental scientists to review the proposal and that team has concluded the project will have minimal or no impact on key receptors like surface water, fish, soil, vegetation and air quality.
"They similarly concluded that impacts of the project on wildlife will be negligible, due to the small amount of vegetation that will need to be cleared for this project and the fact that Sio only proposes to clear vegetation outside of the breeding bird nesting season," adds Duncanson.
Duncanson explains that Sio's wells will be designed to extract silica sand that is naturally occurring in this part of the province.
"Silica sand is a critical resource for many industries, and it is in short supply globally," adds Duncanson. "But it exists here, in a formation that's about 60 metres underground, which also contains an aquifer."
He notes what Sio is proposing to do, is drill wells that will lift up a slurry of sand and water from this formation and remove a small fraction of the total sand that is contained in it. Sio will then separate the sand from the water at the surface, running the water through UV treatment, just to make sure that the water does not get any bacteria in it. It will then reinject that same water back into the formation.
"Sio will not be putting anything underground that was not there already and the reinjected water will be reinjected with only the force of gravity," he assures. "Sio will not be adding any pressure to the injected water."
He notes the net amount of ground water that will be removed from the ground for this project will be similar to the operations of a golf course and less than a gravel quarry.
Meanwhile, Byron Williams is an attorney with Manitoba Eco-Network and Our Line in the Sand Manitoba. Speaking Monday morning, he says he cannot begin his presentation without emphasizing the importance of water and the central importance of these aquifers to the community of Vivian, to the broader region and to the well-being of our province.
"Healthy sustainable aquifers are essential for the community and the province, and the stakes in this hearing cannot be higher," he pointed out. "This is fundamentally important to the future of this region, to our client's communities and to the province itself."
According to Williams, independent experts have identified significant environmental risks with this proposed project. For example, he says Arcadis Canada Inc has noted extraction of the silica sand resource will result in a permanent change to the underground geology in the form of horizontal arrays of rooms and pillars in the sandstone geological layer.
Williams says according to KGS, the shale aquitard separating the two aquifers will be unsupported and collapse into the top of the sand extraction zone void within each sandstone production well cluster, resulting in enhanced and multiple direct interconnections of the aquifers.
Williams questions how the Clean Environment Commission can properly assess potential environmental risks when he says there has been no full-scale test of a well extraction cluster prior to licensing, no investigation of impacts related to groundwater quality in the event of the collapse of the shale barrier, no commentary from the Mines Branch in the Technical Advisory Committee process, no cumulative impacts assessment and no assessment of project implications in the context of regional groundwater plans.
"From our client's perspective and throughout this proceeding, they will be making the point that the aquifer is too important, the risk is too great and that this project should not receive an environment act license," adds Williams.