Summary of Recommendations

Summary of Recommendations and Issues in the Briefing Document, “Issues Related to the Middlebrook Well Permit To Take Water“

by: Athol Gow

Recommended Actions in the Document:

  1. The Ministry of the Environment should hold off on a decision on the new Permit To Take Water (PTTW) application for the Middlebrook well until both a Tier 3 Water Quantity Risk Assessment (WQRA) and a municipal Water Supply Management Plan for the Township of Centre Wellington have been completed.
  2. The water‐taking permit applicant (Nestlé) should be required to conduct a carefully documented well‐pumping test that should include private wells and continuous recording of water level data at all wells. The water level data collection should start two weeks in advance of the pump test and continue after it is over to better gauge the impact on local wells of removing water from the Middlebrook site.
  3. A thorough environmental study should be conducted to demonstrate that water‐taking from the Middlebrook well will not have an impact on plants, wildlife or nearby aquatic ecosystems.
  4. A requirement that, if a PTTW for the Middlebrook well is granted to the applicant, a provision be added that places restrictions on water taking during droughts.
  5. A full assessment of the Middlebrook site for potential well and aquifer contamination issues

Summary of Issues:

Water Security:

  • All the studies and reports consulted in the Briefing Document stress that strong management and protection of groundwater is necessary in order to ensure current and future water supplies.
  • Groundwater comprises 70% of water demand in the Grand River watershed.
  • The population of the Town of Centre Wellington (TCW) is slated to grow by 40%, from 27,290 to 41,350 people by 2031.
  • If future municipal water demands increase to between 8% and 10% of the total watershed budget, the Township’s water supply availability will be at risk.
  • The Middlebrook well’s aquifer recharge area may lie within a zone designated in August 9, 2015 the Township Official Plan for future water supply taking for a future Elora well.
  • The creation of a Water Source Master Plan, required by the Province, allows municipalities to identify and protect future water supply areas; when a municipality makes such a policy, the MOE Director will not approve water taking in a designated supply area.

Technical/Environmental Viability

  • Independent hydrogeologist Hugh Whitely prepared a detailed assessment on the Middlebrook well water‐taking proposal. His concerns include:
    • The need for technical reports accompanying the Middlebrook water permit application to provide more information on the aquifer, includingthe flowrate and capacity, the thickness and porosity, the zone of influence created by removing water, the source of water replenishing the aquifer and the time frame in which this occurs.
    • The monitoring of water levels and quality during the pumping test as well as monitoring requirements if a PTTW is granted. It may take a long time for adjustments in equilibrium water levels in the upper aquifer to appear, and the influences of pumping, given the confined nature of the aquifer, could occur a long way from the pumped well.
    • The potential connection of the Middlebrook well to the wetlands in adjacent lots and the possibility that pumping over a long period would reduce water level in the wetland.

Problems with Drought:

  • A report by the Grand River Conservation Authority has indicated that the Township of Centre Wellington is among a number of municipalities in the Grand River watershed that are considered to be water‐stressed.
  • The entire Grand River watershed has recently experienced low levels of groundwater.
  • The Grand River is listed as one of the province’s 36 watersheds that are most vulnerable to drought and low water conditions.
  • Nestlé attempted to remove a mandatory requirement to cut back on water taking during drought conditions but backed down when challenged in an Environmental Review Tribunal.

Contamination Risks:

  • The 5‐acre Middlebrook site is in a high zone for contamination from surface pollutants because:
    • There are relatively thin layers of protective clay and other material over the limestone bedrock, which itself contains cracks and fissures.
    • There are high levels of nutrients in the surrounding soil due to adjacent livestock operations.
  • The TCW prepared a 2008 report in which the Middlebrook site was rejected as a potential municipal well due to environmental concerns.
  • The Middlebrook site is only 5 acre in size, which does not provide a significant buffer with respect to agricultural run‐off. By contrast, Nestlé’s well in Erin is a 188‐acre site and is rented to organic farmers, to reduce the risk of pesticide or livestock nutrient contamination.
  • lan MacRae wrote a letter which was submitted separately from the Briefing Document. MacRae, whose father had the Middlebrook well drilled, and who lived in the adjacent farmhouse until recently, reports a history of repeated contamination events on the Middlebrook site.