23 January 2014 Dear Mr.

Bradley, I am one of the directors of the Canadian research group at the G360 Centre for Applied Groundwater Research in the School of Engineering at the University of Guelph. My colleagues and I were retained by the Enniskillen Environmental Association (EEA) in the spring of 2013 to independently review the Draft ESR for the proposed large scale hydro transformer station in the municipality of Clarington situated on the Oak Ridges Moraine. Our desktop review of that documents content was conducted from a hydrogeological perspective. We focused on the reports that were provided and reviewed other cited scientific research used to support Hydro One Inc.s ESR document (released publically in November 2012). We were not present for any of the geotechnical work done on the noted site, nor did we have an opportunity to conduct primary research for this review. One of the major concerns of the EEA is the potential impact of this proposed utility project on the quality of their drinking water supply. Following review of the Clarington Transformer Station Class Environmental Assessment Draft Environmental Study Report (Hydro One, 2012) and related documents it is our expert opinion that insufficient site specific hydrogeological characterization has been conducted to ensure the safeguarding of groundwater: 1) used by residents in the area and beyond for domestic water supply from private wells;. 2) for the protection of hydrologically sensitive features. We supported EEAs request for a higher level assessment (bump up to an individual EA) to allow the opportunity for the development of a scientifically defensible site conceptual model. This would provide the proper evidence and field data from which to base a credible and informed assessment including analysis of environmental impacts to the related ground water and the hydrologically sensitive features on this site. Essentially, our review of the documents concludes that the appropriate questions needing answers were not stated explicitly and therefore environmental impact analysis was not addressed with appropriate data for such a development on the Oak Ridges Moraine. The groundwater science has advanced markedly over the past three decades, with substantial contributions from Ontario universities and researchers using provincial and federal funding. In parallel with this, the level of professional practice in government and industry should be expected reasonably to keep pace with the science. This is a difficult challenge for government and industry, including the consulting industry. In general, it is our view (G360) that Ontario has fallen behind in this regard. The Clarington transformer station "project" serves as a good
GUELPH ONTARIO CANADA N1G 2W1 PHONE (519) 824-4120, EXT.53642 FAX (519) 836-0227

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example of the general situation in Ontario and as such could serve as a test case. It is on the Oak Ridges Moraine in an area where local residents rely on well water and is therefore worthy of more than routine consideration in the groundwater context. The local residents have done their homework with a lot of hard work in an exemplary manner. Their work along with the review by my colleagues and I at the University of Guelph has exposed quite clearly need for improvement in the framework and processes aimed at science based decision making. This can be prudently taken as an excellent opportunity for an initiative to guide development of an improved science based decision framework for environmentally sensitive projects in Ontario. We have been advised by the EEA membership that you just recently made your decision to approve the noted undertaking proposed by Hydro One Inc. under the existing provincial Class Environmental Assessment process. For the above noted reasons we would like to meet with you and your senior staff to discuss this matter to the extent that it deserves a particularly higher level of professional scrutiny. Given the very pointed and unique environmental context and potential consequent risk to groundwater this is a critical test case for all future development of this kind of infrastructure. Logically, we can ill afford to neglect the use of the best applied scientific assessment practice that is readily available right here in the province of Ontario. We must hold ourselves accountable to a higher standard of professional engineering assessment, particularly when it comes to dealing with finite natural resources like our groundwater supply. We are all aware that the public demands and rightly deserve this quality of public service and safety. We look forward to meeting with you and your staff to discuss how we may assist the ministry in advancing the process of science based decision making for environmentally sensitive projects in Ontario. Sincerely,

John Cherry Ph.D., P.Eng, Fellow of the Royal Society of Canada

GUELPH ONTARIO CANADA N1G 2W1 PHONE (519) 824-4120, EXT.53642 FAX (519) 836-0227