How the Proposed Commercial Water-taking Impacts our Municipal Water System

Talk at the May 9 Community Information Evening

For the next few minutes I will share with you information you may or may not know about a serious problem in our own backyard. This is the local story occurring underneath the radar that the public needs to know.

I’ll begin with what you likely know. Our township is facing several water challenges. Besides Nestlé’s purchase of the Middlebrook well, there is the Township’s shocking new population target announced in May 2016. The province and the county determined that we are to double the number of residents in Fergus and Elora by 2041. Very few communities in Ontario face this accelerated growth rate.

Two years ago, concerned residents hired their own hydrogeologist to undertake a through investigation of Nestlé’s impact on the township’s water system. The residents chose Garry Hunter, a civil engineer, who was instrumental in stopping the Mega Quarry near Shelburne.

Garry’s initial focus was Nestlé’s request for a permit to take 1.6 million litres per day, a rate approximately equal to the combined daily rate of three of Centre Wellington’s best municipal wells. After further research, he realized he should focus – not on the Middlebrook well – but on our township’s water infrastructure.

His first report issued in May 2016 predicted that several of our 8 municipal wells are incapable of pumping to their permitted amount; that these wells will not support our forecasted growth, meaning we need additional new wells; that the reliance of one in eight residents on private wells within the urban boundary restricts how much the township can draw down the water level when operating its wells; and that Nestlé’s water-taking at Middlebrook will directly compete with Centre Wellington’s expansion of its municipal water system.

Our County Councillor Shawn Watters will confirm that finding suitable sites for new municipal wells is a huge undertaking for this community. It can take upwards of eight years to get a single new well online and cost up to $4 million before the water is finally flowing. Centre Wellington has a history of difficulties in finding sites for our municipal wells.

In the late 1990s, Shawn was a township councillor on the committee charged with finding a new source of water for Centre Wellington. Eventually the well was constructed behind the racetrack on the Cottontail Trail. Shawn, for those who had been following the problem, has stated all along that water is an underlying issue in our community, yet few have been listening, until now!

So here’s the story most of you haven’t heard. Where does the water come from for our wells? Under our community the water flows north to south through cracks and fissures in the deep bedrock, and this direction determines where best to locate a new municipal well.

Municipal wells, situated upstream of their southern counterparts, interfere with the southern wells’ ability to draw water.

Extending our well system further south from Fergus is not feasible due to the City of Guelph’s well capture zones, which extend now north to Swan Creek at the south end of Fergus. We will be competing with Guelph for water if we go south. In fact the town tried a test well south of Fergus near Highway 6 and Second Line and found that there wasn’t enough capacity there for a Township well.

Logically, the best locations for future municipal wells are to the east of Fergus and west of Elora.

However, east of Fergus in some locations the ground is too unstable for a high production well, and there is a history of water quality issues associated with deeper wells and increased pumping due to the bedrock conditions near Fergus.

The best location for future Township water and very good water is west of Elora, but here Nestle blocks our expansion. High capacity wells require a minimum 2 km. separation to prevent well interference. So, with Nestlé at the Middlebrook well 2 km down the road, this wipes out from the equation the whole area west of Elora as a possible source for new municipal water.

So here’s another fact – we the taxpayers and municipal water users will have to pay more when the town has to go further afield for good water sources, or has to pay to treat poorer quality water to bring it up to standard.

Our township’s water manager Colin Baker and the township’s hydrogeologist Ray Blackport support this assessment of the situation. They agree the ‘easy’ water has already been found, and by easy water they mean water close to the municipality and easy to obtain without constraints. Finding new sources of groundwater now becomes more difficult.

Garry’s report revealed another inconvenient truth, that our current infrastructure for drinking water with or without growth, or Nestlé, already faces challenges.

Some of our wells have issues with quality, and others with capacity. Elora’s three wells interfere with each other, particularly the well by Jeffersons and the well on the Cottontail Trail, despite these wells being more than 2 km apart. Mutual interference and interference with private wells mean that these two wells cannot pump continuously at a high rate at the same time.

Some of our wells are now registering chloride from road salt, indicating that surface water is beginning to leach into our deep aquifer in those locations.

Fergus’s five wells have their challenges. The one near the high school can only pump at 50%; otherwise sediment gets in. The well at the north end of Gartshore, shows deterioration of water quality with increased pumping due to elevated sulphur. So that well is used only as much as it’s needed.

The oldest Fergus well, beside Groves hospital, has some trichloroethylene contamination from old industry, requiring air stripping remediation of this water before it’s used as drinking water.

So, the township provides us with excellent water, but this is a tricky and costly system to maintain. It’s not an easy system.

The Hunter report must be a signal to the province, to the county and to the municipality that our situation here is serious – that under any scenario Nestlé’s water taking is a huge risk for our municipal water system and our wallets.

Another inconvenient truth we have discovered is the negative financial impact of Nestlé’s presence in our community. Our County and Township are focused on increasing their access to tax money, and while Nestlé may be good for the County’s pocket, it is not good for ours.

Nestlé currently pays approximately $38,000 in property taxes for the Middlebrook property. This will be dramatically reduced when they remove the building and put in a small well house. Then they will be paying less in taxes than many of us present here tonight, while extracting enough water every day that could service 2,700 homes. By comparison, these homes would generate over $2 million in property taxes for the Township alone.

We the taxpayers have to understand that if we have to pipe water here from further from town this will be an enormous cost. This work will be funded out of our water bills, so very clearly the residents are going to be paying so that Nestlé can take and export our water.

The first Hunter report provided the facts needed to bolster the efforts of Save Our Water and Wellington Water Watchers, who together:

  • contributed to the Province’s decision to deny Nestlé a pump test permit
  • persuaded the Province to authorize a scoped Tier 3 study
  • encouraged the township to submit a bid for the Middlebrook well
  • emboldened the province to slap a 2 year moratorium on the bottled water industry, and,
  • instigated the township’s moving forward with its Water Supply Master Plan.

So the province and the township are listening.

Garry has continued with this project for two years and now has a substantial new report ready to go. The advance results are in.

All of this has been an eye-opener for a lot of people, our council and mayor included. Whereas the deterioration and repair of our roads and bridges is visible to all, what happens underground is another story. We take our water system for granted. We turn on our taps and expect water to come out. We don’t appreciate what is involved in ensuring this happens.

It is important that we residents understand these challenges with our water system, and understand that Centre Wellington’s ability to service its growth will be put in serious jeopardy by Nestlé’s commercial extraction at the Middlebrook well. When we all know and understand where our drinking water comes from and how it gets to our taps, then we understand why we have to protect our precious sources of water.

The Province has to understand that they can’t have it both ways. The Province cannot target this community for 100% growth in the next 23 years, while also permitting a municipal-scale extraction by a private industry, putting our drinking water system at risk.

It can make no sense to our council or to the province or to anyone to permit competition between a township mandated to grow and an exploitative commercial water-taker at the edge of town.

We know that democracy is not a spectator sport!

Nestle and Centre Wellington

We know that democracy is not a spectator sport!

We are not up against just any business. This is Nestle! The challenge for us is who controls the ground water we depend upon…the people of Ontario or a foreign corporation?

In the end, it is our community, our wells, farms, industry, businesses and future growth that will be hurt. If Nestle gets a permit to pump water here, we could experience the water nightmare that other parts of the world are in now!

Let’s talk Nestle.

Vittel France is running out of water and blaming Nestles’ 28 years of water taking. We do not want that to happen here!
Erin is having trouble finding a new well! Nestle is there to “help”…This could be us too!

Nestle is one of the biggest bottlers of water with over 100 plants in 34 countries and always hunting for more! By their own admission, they waste at least 30 per cent of that water they take in the bottling process itself.

They have been pumping with an expired permit in California for 30 years at about 1 billion gallons a year. California is in a multiyear drought. Yet a Nestle executive said,” If I could increase it, I would!”

Nestle’s deep well in Pakistan caused the water level
to drop leaving the local village with dirty,
dangerous water sickening the villagers. When this came to light, Nestle kept right on pumping.

This is NOT the kind of business we want in our
Community, one that has such a bad reputation, is a threat to our local water system, negatively impacts aquatic ecosystems, and contributes to the plastic pollution that is choking our planet.

Here is the predatory, strong-arm company we are dealing with:

When Osceloa Township in Michigan voted NO to Nestle’s plan to triple their water taking because it would stress the township’s water system, Nestle sued the township. While they were suing those people, Nestle’s message was, “We want to be part of the community, we want to have conversations.” Lawyer up and See you in court! Some conversation!

This is the way they treat a host community! This could be us! They choose small rural communities but they picked the wrong one here!

Thank you for your support thus far. But we are not done yet!

Nestle executives here claim to be an open book, but when our technical team asked for a report on the Middlebrook well, they did not share it. They also chose to firm up their offer when the township bid on the property.

Other communities have beaten back Nestle and we can too! We will not be bullied, bankrupted or manipulated. We need policies that lock out a company that would privatize the water a community needs!

We are NOT a willing host community to Nestle! We are going to ask our Council to put that in a resolution for the province. Come to the May 28 Council meeting to support a resolution.

Let’s talk Provincial Politics.

To his credit, Ted Arnott, who was our opposition Environmental Critic, told the Legislature that Ontario must do more to reduce greenhouse gas emissions and confront climate change. Let us support him with that view but tell him he needs to go further. Let him know that plastic waste like Nestle water bottles are part of an ecological time bomb that scientists warn us is “as dangerous as climate change”.

Please tell Ted Arnott to choose his priorities: profits for a foreign corporation or the needs of his community.

Centre Wellington relies solely on ground water. We cannot afford to have it shipped away daily never to return! The province cannot ask us to double in size and then give a permit to take away the water!

It is time for Ted to walk the talk and make some tough decisions. We know that if a decision had been made 3 years ago, the science would have been totally wrong!

The decisions we ask for today will determine the future of this community, the future generations and all of Ontario. Precedents are set here. The rest of the province will be vulnerable to water taking unless we draw the line here!

Tell Ted Arnott, and John Hurst of the Liberals, and Diane Ballantyne of the NDP and Dave Rodgers of the Green Party that this is not about any business. This is about Nestle. This company puts our community at serious risk! We need to see better provincial legislation that protects water.

Let’s talk the municipality!

Our councillors voted unanimously to support water as a public trust. Let us support them in that position and hold them to that.

We citizens are asked to conserve water. Conserving water does not mean giving 1.6 million litres of water a day to Nestle!

Our water rates may skyrocket if we cannot find easily accessible, good quality water. Economic development does not happen without water! Quality of life suffers terribly without good water!

If the township does not consent to this water taking it carries huge weight with the province.

We need to know where each candidate both provincially and municipally stands on this issue. Let them all know about our sincere concerns about available, accessible water. Let them know we do not support privatization of water! Ask questions, get answers and vote accordingly for the provincial candidate and municipal ones in the fall election.

We must be clear on this. No public private partnership deals! No deals or compromise at all!

Tell our mayor, our councillors and all candidates running for both the provincial and then the municipal elections to stop this threat! Ask if they are going to accept this risk or stand up and oppose it!

The bottom line is who controls our water. It is time to act! Have a Ted talk with Mr. Arnott, question John Hurst, Diane Ballantyne, and Dave Rodgers. Find out their party platforms if they have one.

Let them know what a vital issue this is here. Ask them where their party stands on privatization of water. Ask every candidate their party’s position and their personal view on the rules for permits to take water. Ask our mayor and council and future municipal candidates their positions too. They could start with the Not a Willing Host resolution to get that message to the province.

We are all in this together. Figure out what you can do to stop this Nestle take over. We need your help and your voices! It’s on!

Dante: “the hottest places in hell are reserved for those who, in times of great moral crisis, maintain their neutrality.” We do not have the luxury of neutrality. Neither do our politicians!

The next few months are crucial! All of us need to keep up the pressure. Send a letter, an email, make a phone call and make an appointment with a candidate for a talk tomorrow! Let’s help our Council get the message to the province!

This is a DO IT NOW time for our community!

Why new regulations for water bottlers are still flawed

The Ministry is going through this process of creating new policies and regulations for water bottlers and we could end up with something less satisfactory than we had before!

On April 21, 2016 the Ministry of the Environment and Climate Change announced new procedures and guidelines that apply to water bottling permit renewals. The new requirements were established, in the Ministry’s words, “to enhance water security in Ontario, by ensuring the wise use and management of groundwater in the face of climate change and increasing demand due to population growth.” But these new regulations are still not good enough.

  • Aspects of the new regulations are worthy of support:
  • The permits will now be for a maximum of five years, not ten.
  • Climate change and drought conditions will be part of the assessment.
  • Mandatory decreases in the volume of water-takings will be triggered by drought levels.
  • The water bottler’s operation will be more transparent, with all data from monitoring water levels and all mitigation actions taken from unexpected impacts (e.g. lower water levels in private wells) to be posted on a website for public review.

However, there are serious omissions, and new issues have now arisen with these new guidelines. The following are some of these concerns:

  • Science for the application will be undertaken by the applicant. Work that was previously the responsibility of the Regional MOECC office is now downloaded onto the applicant. This will reduce the cost in public tax dollars of the administration of the water management program, but we have serious concerns that these proponent-driven science reports will not be disinterested and unbiased studies. They need extensive third-party oversight.
  • Consultation with First Nations has been downloaded to the applicant. This change is huge. A consultation process is necessary; Save Our Water agrees with that. But if the applicant does the consulting, and the Ministry is not part of this process, what does this look like? This changes the conversation. For one thing, it puts a burden on First Nations to have the relevant information and expertise with which to consult, while the applicant has full-time highly paid professionals. The Ministry still agrees that it has a legal duty to consult with first Nations, but where has this process gone? They now oversee the applicant’s consultation process.
  • Consultation with municipalities has also been downloaded. A new mandatory pre-submission discussion between the permit applicant and Ministry staff prior to the PTTW application allows for an opportunity for the Ministry to advise that such an application would not be accepted in any case, for example within the boundaries of a municipality targeted for accelerated growth. Following that, however, a ministry-municipality consultation process has now become an applicant-municipality consultation. This allows for the applicant to enter into negotiations with the municipality. Again, this is not a disinterested consultation. This is pressure.
  • Climate Change considerations are not stringent enough. Considering that a level 3 drought has never been officially reported even when the situation has warranted it, specifically during the serious droughts in 2012 and 2016, how often will the mandatory decreases in water-taking be triggered? We feel that during droughts serious enough that a watershed is experiencing several months with only about a quarter of the rainfall expected, the 20% mandated decrease in water taking is an inadequate reduction. Further, there are more aspects to climate change than drought and temperature. The new guidelines do not take into account high intensity rainfall events, whereby water flows directly into creeks and streams, storm sewers and rivers rather than replenishing groundwater. Given the high uncertainty of the future, we would like the Ministry to consider other climate and weather variables and to follow precautionary principles.
  • Potential impacts to ecosystems are left to the applicant’s assessment. With these new guidelines there is no improvement in the section on impacts to ecosystems. This may be the most significant concern. Potential impacts on ecosystems require provincial oversight, and the MNR should be involved in a collaboration to protect ecosystems. Consideration of a single threshold flow in a river, to the exclusion of other ecologically relevant considerations is not a satisfactory approach to quantifying ecosystem needs. An allowable 10% reduction in stream flow is not acceptable. Strong sustainability principles acknowledge the lack of knowledge about the functioning of complex natural systems. Strong sustainability proponents also recognize that the uncertain state of knowledge about ecosystems makes it very difficult to judge what are critical thresholds. We must re-define water use based on a finite supply and inclusion of all freshwater ecosystem needs. This is not for the applicant to measure!
  • Watersheds need protection. Since ecosystems are tightly linked to the watershed catchment of which they are a part, we need better policies to protect watersheds. Currently, and under these new guidelines, the Ministry takes into account impacts of water uses in local sections of the watershed, but not the cumulative effects of all threats to the watershed as a whole. Considering that the vast majority of water permit holders are clustered in the densely populated parts of Ontario, these threats to watersheds are accumulating. The Grand River Watershed has over 700 active Permits to Take Water, with permits constantly being issued, renewed and expiring, including significant municipal water takings. Both Ontario’s Environmental Commissioner and the Ministry of Natural Resources have advised that better assessment is needed at the watershed level. We need policies for water permits that take into account the cumulative impacts of all water uses within a watershed.

We need a water management process that sets a gold standard in water protection, a management process that considers groundwater as part of a freshwater system connected to rivers, lakes and wetlands with ecological purposes, and not simply as a water supply for human needs.

Save Our Water Requests New Policies for Water-Taking Permits

Save Our Water and Wellington Water Watchers, with the assistance of Ecojustice, submitted the following ‘Application for Review’ to Ontario’s Environmental Commissioner.

We requested a review of the need for new policy changes that would protect the environment by improving Ontario’s water management system and strengthening climate change resiliency.

The application stressed the need for new policies on these issues and others:

  • consideration of climate change uncertainty in decisions on permits to take water
  • prioritizing uses of water
  • improving accountability in water permit renewals
  • ensuring financial resources for Ontario’s water management system through increased charges.

Read more

Nestlé’s proposed water taking could undermine Centre Wellington’s growth strategy. Hunter Report #1

The township’s water is already at risk, according to a study of the township’s wells and water use.  Prepared by Hunter and Associates Environmental and Engineering Consultants, and submitted to the Ministry of the Environment and Climate Change on May 13, 2016, the report reveals vulnerabilities in Centre Wellington’s municipal water system which could be further stressed by Nestlé’s planned commercial extraction.

Drawing on monitoring records, historical well records, water level records and other township documents, the report identifies that we have a problem here even without Nestle. The Township’s infrastructure for drinking water already faces a variety of challenges.

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Save Our Water and Wellington Water Watchers put forth comments on Nestle Waters Short Term Pumping Test

REGISTRY # 012-4935

This submission is from Save Our Water and Wellington Water Watchers.  As residents concerned about the water issue in our area we are writing to submit our concerns about this application for a Permit to Take Water to conduct a pump test at the Middlebrook Well.

Our comments are both technical and general, and on the weight of these concerns and unknowns we believe the permit should be denied or deferred.  We are asking that the pump test be delayed until the new, improved policies are in place and, if the permit is granted, we are asking for specific conditions.   The first section documents our concerns and recommendations.  The second documents the conditions we would like to see applied, should the application for pump test be approved.

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