Our Comments About the Pump Test

SaveOurWater.CA Backgrounder

Background

The Middlebrook site is located across the road from the Elora Gorge Park, a Grand River campground and attraction known for its limestone cliffs and river views. Communities potentially affected by this water taking include Elora, Salem, and Fergus.

Formed in April 2015, Save Our Water is a growing movement of area residents committed to the protection and preservation of the Grand River watershed. We are working closely with Wellington Water Watchers to safeguard the groundwater that our communities, our wetlands, and our river ecosystems rely on.

As the group’s Twitter hashtag ‘What’s the rush?” alludes to, provincially mandated research on the Township’s water supplies, the Water Source Master Plan and a Tier Three Assessment of groundwater resources for water-stressed communities like Centre Wellington, have not yet been undertaken. Save Our Water believes that this crucial research should be completed before the Ministry considers granting more water-taking permit for the purposes of commercial bottling in the Grand River Watershed. This will ensure that groundwater resources remain sustainable for future residents and that the right of the public to clean, sustainable water supplies come before those of private corporations.

Specific concerns are:

Population pressures:

* The township of Centre Wellington, which includes Elora, Fergus, and Salem, is slated to increase about 40% in the next fifteen years, from 27,290 to 41,350 by 2031.

* If future municipal water demands increase to between 8% and 10% of the total watershed budget, the Township’s water supply availability may be at risk.

* If Nestle were to draw water at the maximum that the permit they are seeking would allow, the 1.6 million litres taken each day would only be slightly less than the water currently used each day by the Village of Elora.

Water scarcity:

* Centre Wellington is considered a water-stressed area and the province lists the Grand River as one of the province’s 36 watersheds most vulnerable to drought and low water conditions.

* The Grand River Conservation Authority uses a scale of 1-3 to identify levels of drought. Water-taking permit holders are only not subject to mandatory restrictions unless directed by the Province at Level 3

Ground water contamination

* Local residents have expressed concern that heavy pumping from the Middlebrook well site could draw contaminated water down into the aquifer and into other wells in the region.

Provincial policy governing commercial water bottling:

* There have been calls for a review of the provincial regulations that govern commercial water bottling out of a concern that they are not designed to handle growing demands on water resources for the purposes of commercial bottling.

Save Our Water has developed the following recommendations:

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

Protection of groundwater resources is also resonating as a national issue among Canadians. In a Nanos poll commissioned by the Munk School of Global Affairs Program on Water Issues last May, 96% of Canadians said that it was important that groundwater use remain sustainable and not be exhausted by overuse; 81% that it is important that public access to groundwater be given priority over private access.

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.

Press Release: Friends of Elora Water

May 21 2015

For Immediate Release

Elora, Ontario: A small southern Ontario town has become ground zero in Canada’s battle for the right to safe clean drinking water. Local residents express outrage at news that Big Water giant Nestle is looking to export packaged water from the local watershed.

Nestle’s planned expansion into the community would see 1.6 million litres of water pumped each day from the local watershed. By comparison, this small community of 27,000 residents, uses 1.7 million litres of water from 9 well sites to meet the needs of every home, school and place of business. Big Water companies pay fees less than $4 per One Million Litres, while home owners pay over $4 per One Thousand Litres of water services.

Friends of Elora Water, a local citizen’s group, has seen its membership swell with the prospect of a sale to Nestle. Meetings have grown from a handful of concerned citizens, to a packed house for the monthly Water Wednesday Meeting May the 20th, where citizens from 8 to 80 filled the local Legion to fight for our rights to water.

With a growing on­line Facebook community of over 800 members, Friends of Elora Water’s posts have reached over 10,000 views in the past month. ( *** This post has tripled that number in less than 48 hours. )

Some residents fear increased water restrictions and unfair access to water during this year of predicted higher summer temperatures brought on by El Nino events and climate change. ” We all have water restrictions in the summer, while big companies can come in and ‘drain the well dry’ even during a drought.” commented Peter Skoggard a concerned community member.

Friends of Elora Water calls on local government to help protect drinking water as the community’s most precious resource. ” Now is a chance for our local and provincial government to led by example and protect our right to safe clean drinking water. It’s time for brave new ideas that speak to the needs of our growing community. ” said Diane Ballantyne, local High School teacher and social justice advocate.

The message received from a recent poll couldn’t be clearer, it showed that 97% of respondents opposed government’s support of companies like Nestle, operating in the community.

Friends of Elora Water asks why Centre Wellington Township has recently created a committee with representatives from Nestle, and the The Ministry of the Environment to look into the matter of water while excluding any voice of the people from Centre Wellington.

Friends of Elora Water is partnering with organizations across the province and across the country to maintain our rights to safe clean drinking water; Organizations that bring decades of experience in the science and policy of Canadian Water; Wellington Water Watchers, The Council of Canadians, and the David Suzuki Foundation.

” Together we will protect our water. The water under our feet, the water that comes out of our taps. It belongs to our future, it belongs to our children.” Founding member of Friends of Elora Water, Lindsay Bolger asks, ” If we don’t stand up who will? Will you?”

If you would like to learn more about water in our community, get involved in action taking place, or volunteer your time ­ go to www.facebook.com/friendsofelorawater Friends of Elora Water

contact: friendsofelorawater@gmail.com

Facebook: www.facebook.com/friendsofelorawater