Council members are disappointed with the response by the Ministry of Environment and Climate Change (MOECC) regarding the way precipitation data is incorporated into annual monitoring reports prepared on behalf of Capital Paving and Nestle Waters Canada.
In a letter to Puslinch council Mili New, director of the MOECC West Central Region stated “Neither Permit to Take Water issued to Nestle Waters Canada nor Capital Paving actually requires the inclusion or assessment of precipitation data. However, consultants who are preparing the annual monitoring reports required under many permits often find this type of data to be useful in interpreting changes in groundwater and surface water levels. lt helps the consultants to differentiate changes caused by the permitted water taking from those that are due to weather conditions. Accordingly, consultants’ assessments usually consider data gathered from one or more nearby weather stations.”
New said it is important to note precipitation varies geographically, sometimes with large variation over short distances (e.g. thunderstorms). She added, “Unless measurements are made on-site, there is no assurance that the data from any given station is an accurate reflection of on-site precipitation. Data from nearby stations does provide a point of comparison though, and is valuable from that perspective.
“And since the meteorological data is a matter of historical record, if any party wishes to use the data from a different station in their own interpretation, this is easily done.”
New stated, “this ministry’s principal interest is not in the accurate monitoring of precipitation at the sites of water takings, but rather in the accurate presentation of environmental effects of a water taking. We feel that this is generally well done in the consulting community in the context of the Permit to Take Water program.”
Councillor Ken Roth said he found the MOECC letter interesting.
“If weather changes so much within a few miles, would it not be advisable for everyone to use the same weather station,” he said.
Roth said that would allow something to compare with for the annual precipitation numbers.
Mayor Dennis Lever said the issue arises when it is pouring rain in one portion of the municipality and not raining in another, adding, “How do you pick which weather station to use?”
Roth said, “it makes more sense to use one weather station – rather than one which best suits the (water taker).”
Lever noted the township had asked the three companies involved to get together and look into it.
“We haven’t heard back from them,” he said.
Councillor Susan Fielding said it appears from the MOECC letter writer the choice of weather station is up to the water taker.
She wondered if council was putting too much stock into that factor.
Lever agreed, but said the township can still make the request to determine consistent measurements.
He said there is the question of the impact of local rainfall to groundwater versus the aquifer.
In the case of deeper aquifers, Lever said water can take upwards of a generation to reach a lower aquifer.
However councillor John Sepulis noted companies are using precipitation data to justify their operations.
Like Roth, Sepulis believed using the same data would provide consistency.
“I was disappointed with the (MOECC) letter. I thought the province would take a leadership role and help stabilize a situation where there are different viewpoints based on different precipitation data,” Sepulis said.
Councillor Mathew Bulmer suggested one area where the township could influence matters is in regard to new applications and peer reviews at that time.
“We can recommend items we would support in terms of data,” he said.
He agreed there may be legacy operations which pick and choose which data to use, “but as we go forward, we can take a lead role in all new applications.”
