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Linda WhalenGeneral ManagerSault Ste. Marie Region
ConservationAuthority
Sault Ste. Marie, Ontario
August 29, 2011
Subject: Pointe Estates Technical Opinion Preparation
Dear Ms. Whalen:
In response to your email of August 30, 2011, I would like to
offer the following ap-proach for the completion of the technical
opinion in the above reference matter.
As authorized by the SSMRCA Board of Directors, I am currently
in the process of
preparing an expert opinion regarding the Pointe Estates
Development proposed byChant Construction Limited. (Chant). This
opinion is in response to the Chant Groupappeal to the Mining and
Lands Commissioner (MLC) scheduled to be heard on Novem-ber 8-11,
2011.
The hydrogeology of the area around Pointe Louis is complex. The
potential migra-tion of chemical constituents from the proposed
septic systems, the presence of theproposed development in a
wetland area coupled with the complex interaction ofgroundwater
between the proposed development, the proposed canal, the St.
Marysriver system, as well as the sole source bedrock aquifer
underlying the proposed de-velopment need to be carefully
evaluated. In addition, as I stated at the onset of this
review, it is my intention to provide an objective evaluation of
the information pro-vided by Chant as I neither advocate or condemn
the proposed development. Rather, Ihave focused my review on
evaluating if the information presented to date adequatelyaddresses
any potential risk to human health or the environment. Therefore,
it is crit-ical that all technical information, databases, maps,
and hydrologic data be compliedand presented in the opinion so that
your technical staff, the mines commissioner, aswell as Chant
Groups technical staff will have an opportunity to conduct
additionalreviews as they deem necessary.
Further to my previous comments, it is important that all
decision makers and stake-holders in this project have an
opportunity to review this information as my analysis
indicates potentially significant issues which could pose a risk
to human health and
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Linda WhalenPage 2August 29, 2011
the environment, related both to the subsurface migration of
chemical constituentsfrom the septic tanks into the shallow and
bedrock aquifers, as well as the migration of
potentially impacted canal water with the St. Marys river system
which have not beenaddressed in the Chant reports to date. Given
the nature of the appeal by Chant aswell as the potential for
future litigation, it is imperative that this review be conductedin
a complete and technically defensible manner and that it is as
comprehensive aspossible.
Given the complexity of the hydrogeology, the volume of the
material provided byChant, and the nature of the hearing
requirements, the level of effort required in thepreparation of
this document is not trivial. However, I also understand the
financialconstraints on the SSMRCA. Therefore, in order to complete
this report and to providethe SSMRCA Board of Directors with the
technical information needed to understand
the nature of the potential risks involved while maintaining
costs, I propose the fol-lowing:
1. First, to provide the enclosed invoice for work performed
through Aug. 28, 2011,
2. Second, to prepare a technical presentation to the SSMRCA
Board of Directors topresent my findings, and,
3. Third, to provide a lump sum not to exceed baseline cost for
completion of thetechnical opinion.
I propose that the preparation, and participation in, the
technical presentation be con-
ducted a no cost to the SSMRCA. Including my previous opinion
dated October 2010,this presentation will be the second deliverable
that I have provided to the SSMRCA inthis matter at no cost. As
previously discussed, this work is in addition to a
significantreduction in my standard fees for preparing the
technical report. Also, a lump sumcost for the completion of the
technical opinion will allow the SSMRCA to manage thefinal costs
for the the document preparation.
Given my current work load and commitment on other projects, I
would appreciateresolution of this matter as quickly as possible.
Thank you for involving in this project,please let me know should
you have any additional questions.
Best Regards,Frank Breen
cc: Alan McKintrick
