1. The biggest concern with this application is the lack of information provided with it. The public is handicapped to make comments without knowing in some detail where the aquifer flows, the locations and depths of the wells being monitored for the test or the designated possible zone of influence of the Middlebrook well.
2. We request that Nestlé’s Permit to Take Water to conduct pumping tests at the former Middlebrook Water Co. be delayed due to gaps in data on the aquifer and an incomplete understanding of how drawing from the Middlebrook well at the current allowable rates could impact resident and municipal wells as well as wetlands and other local features.
3. We request that Nestlé monitor wells for two weeks prior to the Middlebrook pumping test in order to provide better groundwater baseline data plus a commitment from Nestle to assure transparent data collection, with the results of the monitoring made available for public review at the same time the data is presented to Nestlé, the MOECC and the Township of Centre Wellington. Nestlé should also provide for an independent third-party assessment of the test results.
4. Since this is a confined aquifer with dimensions and zone of influence not known, negative impacts in wells could occur where not expected. Therefore Nestle should be required to put a large notice in the papers for several weeks to inform residents of the date of the tests and contact information, in order that they can report any unexpected change in waterlevel in their wells occurring at that time.
5. A Well Protection Plan should be in place BEFORE the test to deal with private wells that may have effects as a result of the test. A bond or insurance product could be in place to protect the private well owners and farmers in the area. This must include all those affected and not just those whose wells are monitored.
6. An adequately long period should be established for the pumping test to establish equilibrium conditions in waterlevel both in the well and in the aquifer affected by pumping, and also in the water quality being pumped from the well.
7. Was the decision about which wells to monitor for the test based on sound science?
Since little high quality data exists for this aquifer, have an adequate set of wells been identified for waterlevel sampling during the pump test to identify the full extent of the zone of influence created by the pumping?
8. The water quality testing conducted during the period of the pump test should include all the indicator constituents needed to establish any change in water chemistry created by the pumping. In particular, since Nitrate-nitrogen has been identified as a
problem constituent in nearby GRCA wells in the past, NO3-N should be tested throughout the test.
9. Since this zone has been determined to be highly vulnerable to contamination, the test should be designed to be able to monitor for contamination in the groundwater around the well.
10. For this test, Nestle will be pumping 1.6 million litres of water a day for 14 to 30 days or longer if required, and the discharged water will be piped into Cascade Creek just prior to its falling into the Gorge at a section of the Grand River noted for its brown trout habitat. What damage will this water, suddenly discharged suddenly into the creek or river do to fish habitat, to spawning areas, to overwintering fish and reptiles and to the river ecosystem in general? Some form of insurance should be in place to pay for any damage or rehabilitation that needs to take place as a result of the test. This condition should be imposed if the pump test goes forward.
11. The water from 360 feet below ground and under pressure will be oxygen-depleted and high in nitrogen. What will the water level be in the river at the time of the test? Will this oxygen-depleted water be harmful to fish.
12. A wetland ecological assessment of changes resulting from the test will not be able to be reliably done at this time of year.
13. The preamble of the Environmental Bill of Rights states that the people of Ontario have as a common goal the protection, conservation and the restoration of the natural environment for the benefit of present and future generations. Our water sources must be valued and protected from such consumptive permits where up to 100% of the water leaves the watershed. The pump test is the preamble to this result and should be denied.
14. When Gord Miller was Environmental Commissioner he said “Our present course puts our ecosystems, our biodiversity, our health and parts of our economy at serious risk of deterioration and catastrophic events.” That is why we need to change this present course and consider climate change and the rapid projected population growth in Centre Wellington. We do not yet have a Water Use Master Plan in Centre Wellington. We know we must expand our current capacity as this growth occurs. The province cannot designate this area in the Places To Grow Legislation on the one hand and then endanger the resources needed for that growth on the other. The pump test should be denied on this larger principle.
15. The pump test as it is proposed should be refined to take into account existing more-detailed data about the flow of surface water and groundwater in the region around the Middlebrook well, particularly in the Salem wetland area, which may be the recharge area for this well.
15. Currently no geological and hydrological models exist to represent this aquifer and for the pump test data to be plugged into. The pump test will therefore have to provide the data to develop these models in order that these can be used to extrapolate future impacts on homeowners wells, on municipal wells and on wetlands. And so the test and well monitoring will have to provide the highest quality information. As it is proposed in the application, the test will not provide this information.
16. WHAT’S THE RUSH? Let’s do the proper research and science on the aquifer and a complete study of local water needs before permitting this pump test.