Harden Environmental Services’ senior hydrologist Stan Denhoed is offering a number of comments on behalf of Puslinch Township to the province in regards to the proposed Ontario Regulation “Taking Groundwater to Produce Bottled Water.”
In his report, Denhoed offered three main points:
– he supported the need for increased understanding of regional groundwater flow systems and therefore agreed with the Ministry of the Environment and Climate Change initiative to study aquifer systems in Ontario on a regional or aquifer basin wide scale;
– at the same time, Denhoed argued there is no scientific merit in a sector-specific moratorium, and
– if there are regions in Ontario affected by drought or declining water levels then Denhoed suggested all future permits to take water should be put on hold until such time that the aquifer system study has determined an appropriate aquifer basin yield.
Local perspective
Denhoed noted Puslinch is 100 per cent reliant on private groundwater taking for residential, commercial, industrial and institutional use.
Nestlé Waters Canada has its primary pumping well in the township, which is used for its water bottling facility and is currently taking approximately two million litres per day from the aquifer.
The highest density of groundwater use in the township occurs within the area of influence of that well.
“Despite drier conditions in 2016, the water taking by [Nestlé] has not threatened the ability of local residents or industry to take water as usual,” Denhoed stated
“There have been no complaints lodged with the [Ministry of Environment and Climate Change] or the township in 2016 in regard to water shortages.”
Denhoed adds Puslinch “has been monitoring ambient groundwater conditions (quality and quantity) for two decades in the overburden and Guelph formation aquifers and there is no indication of declining water levels.”
Municipal versus private water taking
Denhoed observes that Puslinch falls within the Well Head Protection Area – Quantity (WHPA-Q1) of Guelph and Cambridge.
As such, private water taking in the township will be subject to plans and policies developed by a local source water protection committee.
“It is possible that private taking for industrial/commercial use in Puslinch could be restricted in favour of municipal takings for industrial/commercial uses in the adjacent cities. This would be a disadvantage for future employment growth in Puslinch,” he said.
“Water taking by the adjacent municipalities taking water from the same aquifer have similar effect on groundwater levels. A water bottling or beverage manufacturer in one of the nearby municipalities taking water from the Goat Island/Gasport Aquifer will have the same impact.”
Denhoed feels the proposed moratorium is “an example of bias towards groundwater-based municipal systems with no scientific rationale in support.”
He stated if such a moratorium is necessary, then any increased taking by water bottling facilities in Guelph, Cambridge and Hamilton (for example) using bedrock aquifer based water sources, should also be curtailed.
Denhoed added “the township is surrounded by municipal groundwater taking, including Freelton, Carlisle, Cambridge, Kitchener, Waterloo, Guelph and Rockwood. The volume of water extracted from the Goat Island/Gasport Aquifer is not insignificant and for the most part, is not returned to the aquifer.”
Pumping tests
Denhoed stated the purpose of a pumping test is to evaluate the groundwater resource capability of an aquifer and is the main physical tool used by hydrogeologists.
“There is no scientific merit in not collecting scientific data if it can be done safely. Should prioritization of water taking eventually disallow the use of groundwater for water bottling at a specific location, the scientific knowledge gained by the testing will be needed to support that decision,” he said.
Denhoed stated the information that could be gained by the proposed pumping test in the Middlebrook well in Elora, would be invaluable for the Tier 3 study currently underway.
He noted that if the province ultimately prioritizes municipal taking over bottled water taking, the knowledge gained by such a pumping test can be used to support municipal taking (a test is required in any event).
Drought/climate change
Denhoed suggested only climate change resulting in less water available to the aquifers should be of concern to the province.
Permits are already subject to decreased water taking in response to drought conditions under the Low Water Response program administered by the MOECC.
Summary
“If groundwater resources in the province of Ontario are in peril, then the Township of Puslinch supports a total ban on the issuance of any new permits to take water until the peril can be evaluated and remedies determined,” he said.
“This includes any increased taking of groundwater within municipal systems to service industrial/commercial uses.”
Denhoed stated, “Targeting one industry (and only those with individual permits within that industry) representing a small percentage of water taking in the province during a time of serious, real, groundwater threat, should one exist, does not have any scientific merit.”
Further he stated, “The scientific evidence obtained locally does not suggest any imminent threat to water resources in the Township of Puslinch despite significant takings from multiple sectors. There are existing tools available to the MOECC to suspend or reduce water taking in the township should issues arise.”
He added, “Moratorium or not, the Township of Puslinch welcomes additional scientific study into groundwater resources.”
Mayor Dennis Lever said, “When I read through this (report) I think he did a pretty good job of capturing council’s concerns.”
Councillor Matthew Bulmer indicated he believes Denhoed touched upon all the major points. He said there are also some additional points council might want to consider in light of the Cambridge water environmental assessment.
Bulmer stated, “Perhaps growth has been over-allocated to areas dependent on groundwater.” He suggested growth needs to be modified to the capacity of groundwater resources to accommodate that growth.
“We don’t see that happening in our neighboring municipalities,” he said.
Bulmer suggested that perhaps the province should be asked to re-examine the growth which has been allocated to various municipalities – “instead of looking for ever-increasing water from their neighbours.”
Lever agreed.
“In fact, I’ve heard two distinct messages coming from our neighbouring municipality,” he said.
He explained one message is that Guelph does not want the growth assigned to it, while the second is that the city wants all the water it can get to accommodate that growth.
Lever said Denhoed was specific that the decisions need to have the science behind them.
“I would hope that the province would seriously consider funding the group based out of the University of Guelph,” Lever said. “With their resources, they are more than capable of doing all of this … but they need the financial resources.”
Councillor Susan Fielding said she considers Puslinch a reasonable voice on this issue.
“There seems to be a lot of propaganda. No matter what happens, I think we have taken a very reasoned and balanced stance in all of this,” she said.
Councillor John Sepulis said he considers the moratorium biased, favouring areas with municipal wells.
“To me if there is a moratorium, all of the bottling facilities in Guelph should be affected as well …” he said.
Bulmer agreed there is a role for municipalities to play in protecting groundwater resources.
He too was concerned with Guelph comments that municipal water taking should have priority over agricultural and aggregate uses. Bulmer said it was interesting to read that the Ministry of the Environment already has the tools it needs to deal with the problem.
He agreed there may be parts of the township where the aquifer is dropping, but that does not appear to be the case in the area where there is a water bottling facility.
Lever said Denhoed had also expressed concern about the Guelph-Eramosa Tier 3 water study and the accuracy of the model.
