Centre Wellington offers comments on Nestle Waters”™ proposed pumping test

Township officials have issued a press release outlining the municipality’s comments on  Nestlé Waters’ application for a pumping test at a proposed well on Middlebrook Road near Elora.

The consultation process, which was open from Oct. 1 to Nov. 15, allowed for public consultation regarding the proposed test.

Centre Wellington consulted with the Ministry of the Environment and Climate Change (MOECC) as part of its consultation process as well as   meeting with the Minister of the Environment and Climate Change and MPP Ted Arnott on Sept. 29.

A News release issued by CAO Andy Goldie states the township “will continue to ensure that any decisions are grounded in a thorough science-based approach to ensure the long-term protection of the township’s water supply to meet our future growth requirements.”

In response to the Environmental Bill of Rights posting, Centre Wellington retained Ray Blackport, of Blackport Hydrogeology Inc. (BHI), to review the proposed pumping test protocol and monitoring program.

The township’s comments on the proposal state, “Nestlé Water’s potential water-taking activities on the Middlebrook Road site has evoked numerous emotions and concerns throughout the community.”

Concerns about adverse impacts to private wells, the township’s municipal water supply wells, shallow groundwater system, wetlands, and surface water have been raised throughout Nestlé’s consultation process with stakeholders and the community, Goldie stated.

Under the Places to Grow legislation, the County of Wellington projects that the township will grow from its current population of 28,000 to approximately 50,000 by 2041. While the township currently maintains adequate uncommitted reserve water capacity for the next five to seven years, future growth beyond this timeframe will require additional water supply wells, said Goldie.

He noted the township requests that the MOECC ensure that the pumping test process, including aquifer characterization and data analyses/interpretation/review by qualified professionals, address the questions and concerns raised by the community and the township. Goldie said, the township and BHI are particularly concerned that operation of the township’s wellfield could have significant impacts during the pumping test program depending on the agreed-upon terms of the municipal well operation.

BHI has outlined a number of questions and recommendations related to the proposed undertaking.

Goldie said the township requests that, prior to approval of the pumping test, Nestlé provide to the township and the MOECC responses to the questions raised.

In his report to Centre Wellington,  Blackport stated the application presents a summary of the proposed monitoring program, which includes: dedicated observation wells in the shallow groundwater near the Middlebrook well; selected private wells located at distances up to three kilometres from the Middlebrook well (including a private well survey); municipal water supply wells and associated monitoring wells within the township’s monitoring well network; and, surface water, wetland and shallow groundwater monitoring along Cascade Creek, Carroll Creek and the Grand River.

Blackport stated, “Given that the purpose of the pumping test is to provide information for a potential future water taking by Nestlé, in the township’s view the proposed pumping test and monitoring of the test must be of a sufficient level to ensure that the scientific assessment is sound, with respect to the potential impact from possible future water taking by Nestle, should they choose to apply for a long-term PTTW.”

Blackport noted one of the township’s concerns, if Nestle does in fact apply for a long-term permit, is to ensure there will not be interference with the township’s source of clean and safe drinking water and the ability to take its permitted volume of water.

He also stated the potential for contaminating the regional water supply aquifer system must be addressed.

“With the lateral extent of the aquitard largely unknown, combined with future changes in vertical hydraulic gradients resulting from long-term pumping and future changes in weather conditions (i.e. droughts), the township is concerned that water quality in the regional aquifer system could become impaired over time,” said Blackport.

“Chemical and microbiological testing should be conducted as part of the pumping test and this issue must be properly assessed prior to any decision with respect to a potential issuance of the long-term (permit).”

He noted the MOECC is requesting Nestle consider the possibility of increasing stress on the aquifer (i.e. increasing municipal pumping rates) during testing in order to attempt to simulate water taking under future growth scenarios.  

“In our opinion, this is unlikely to be useful as a representation of future conditions; future operating conditions are likely to be substantially different, as additional wells will be in place to accommodate future growth in the municipality,” Blackport stated.

Future use simulations

He added a pumping test cannot accurately simulate future pumping at the municipal water system, and it will be difficult to predict the location of future impacts to private well owners.

Blackport recommended the following:

– Nestle should confirm the proposed monitoring program for the pump test will be sufficiently detailed to confirm validity of interpreted geological conditions in the vicinity of the Middlebrook well;

– Nestle should conduct chemical and microbiological testing in conjunction with the pumping test and use this information to assess the potential for water quality impacts on the municipal wells and aquifer, associated with any potential long-term water taking;

– prior to approval of the temporary permit for the pumping test, Nestle should be required to work with the township and MOECC to determine the feasibility of pumping the municipal wells under a specified set of operating conditions so the municipal supply wells can be operated in a manner that aid in the assessment of potential impacts under future operating conditions.

Blackport also suggested the township should be given the opportunity to assess the operational issues posed by the simulation of these conditions and confirm they are operationally feasible.

The full text of the township’s comments can be found at www.centrewellington.ca.