There appears to be no shortage of concerns when it comes to the Guelph Tier 3 water quantity peer assessment review.
Councillors here say they want the science to match the solutions, rather than adjusting the formula to match the results.
On June 1, risk management officer for Wellington Source Water Protection Kyle Davis updated Puslinch councillors on the Guelph, Guelph-Eramosa Tier 3 water budget – water quantity risk assessment.
He provided councillors with a number of documents within their agenda package and spent considerable time going through the latest draft report.
Mayor Dennis Lever anticipated because of the importance of the document, councillors would have a few additional questions or comments.
Davis said “on May 17, 2016, on behalf Puslinch, Guelph-Eramosa Township, the Town of Erin and the County of Wellington, we provided a review package to the Ministry of Environment and Climate Change and the Grand River Conservation Authority regarding the draft water quantity risk assessment.”
He noted consultants had been reviewing the process for the past year-and-a-half to two years. The letter signed by himself and three rural CAOs allude to the problems as cited by each municipality’s consultant.
Davis added this is the second review package … the previous one was in June 2015.
“We’re now getting into responses to responses,” said Davis.
“Some of our concerns have been addressed, while others are still outstanding … and we feel are quite significant.”
The letter stated “As you are aware, our June 19, 2015 review package raised serious concerns regarding the science underpinning the Tier 3 model especially as it relates to the delineation of the Well Head Protection Area – Quantity (WHPA Q1 / Q2) extent and significance level.”
“Our municipalities strongly request that the hydrogeological studies and/or modelling necessary to address our outstanding review comments, be completed prior to the finalization of the Water Quantity Risk Assessment.
“It is established that the Eramosa River is a karst environment and that surface water/groundwater interactions are not fully understood. It is our opinion that the current response by Matrix Solutions Inc. does not adequately address the concerns presented by our reviewers especially in regards to complexity of the Eramosa River’s interaction with the municipal aquifer and the documented surface water loss.”
Another concern raised by local municipalities is the timing by which they became involved in this study.
While the City of Guelph, GRCA and province have been working on the Tier 3 model since 2008, surrounding local municipalities were first involved only in 2014.
“This late involvement, in our opinion, has directly led to our outstanding concerns,” states the CAOs’ letter.
“This six-year delay in our municipal involvement was an oversight that the province noted in 2015. If our municipalities had been involved earlier, our concerns could have been incorporated directly into the development of the Tier 3 model and perhaps a December 31, 2017 deadline would have been feasible under those circumstances.”
Further, Davis wants to seek verification of water drawdowns which potentially impact the Aberfoyle area and an accounting for reduced municipal pumping during droughts.
Davis added Puslinch has requested a meeting with the peer review team. That is happening on June 15, Davis said.
This provincially-appointed review team looks at the technical aspects of the report.
“Our consultants will have the opportunity to present our concerns and hopefully there will be some back and forth discussion on the technical merits of those concerns,” said Davis.
Councillor Ken Roth ask if the main purpose of Davis’ letter was to extend the deadline.
Davis agreed.
“We have concerns with the deadline,” he said.
Davis said the Minister of Environment has indicated he not only wants the Guelph-Eramosa Tier 3 study, but all source water protection plans in the Lake Erie source water protection area to be completed, including policy development, by December 2017.
He stated “given that the amount of consultation that is (still) needed, we feel that Dec. 31, 2017 is an extremely tight deadline.”
Roth asked if the provincial peer team makes that decision.
Davis said its role is solely focussed on the technical concerns which have been raised. The process aspects “are really the minister’s prerogative,” Davis said.
Roth said “if each party has an expert consultant and they all have different opinions – does the peer review team decide which one is correct?”
Davis said his understanding is that the team is a review by external experts to determine if the information presented is technically and scientifically sound, before moving to the next phase.
If there are disagreements, or no agreement on all points, there is a process where the comments would be documented and responded to – but not necessarily addressed, Davis said.
Councillor Matthew Bulmer said he appreciated the tone of the letter, which he considered respectful, in light of the length of the process and the obvious frustration expressed.
He said the use of term “municipal aquifer … really helps underscore the point that a significant amount of river water being drawn into the aquifer – and we don’t know why. And that water is not being considered in the city’s assessment.”
Bulmer said another aspect he was pleased with was the translation of the number of litres of water into hectares/acres to illustrate the amount of water being drawn into the aquifer.
“It was powerful to read that (Guelph’s draw down) could affect the amount of land that needs to be protected by up to 16,000 hectares or 30,000 acres. It helps to put things into perspective.”
Mayor Dennis Lever then stated “Puslinch Township is 50,000 acres.”
“It is a significant impact,” Bulmer agreed.
He added one of the ironies is the request to change the title of the document to “Guelph and Guelph-Eramosa, yet the majority of the water taking and impact will be here in Puslinch.”
Bulmer appreciated the request to quantify the amount of water which appears to be leaving the Eramosa River.
He believed water is significant and that there is agreement from the majority of the peer review team as to what the problem is – it is just the city of Guelph which is the outlier.
Bulmer said a broader concern “in my mind it is more than the residents or the city of Guelph that are at risk by ignoring these concerns. This is an aquifer that others draw upon – not just the city of Guelph.
Davis said the loss of water from the Eramosa River appears to be a natural occurrence, related to the karst geology of the area.
He said there is an “unaccounted volume of water” going somewhere and there are differing interpretations as to where that water is going.
Davis said he was uncertain about all of Guelph’s water sources and which ones would be defined as GUDI (Groundwater Under the Direct Influence of surface water).
“What is important is that there are still questions about the science used in this study.” He said this process would eventually lead back to the permit to take water.
“Once the science is settled and an area is defined as a wellhead protection area regarding quantity – there will be policies drawn up regarding permits to take water,” said Davis.
“Our role as risk management professions is trying to reduce or eliminate the risk” and overall, this is a work in progress, Davis clarified.
Lever agreed the timetable “is indeed a cause for concern”.
He said others have expressed similar concerns in the number of “unknowns” regarding the river, in addition the well in Arkell.
‘This work needs the best available science … it seems the model is being tweaked to explain the outcomes rather than what is happening in the field,” said Lever.
“What we all want to do is avoid a very embarrassing situation if something goes wrong.”
Lever was also concerned one of the main GRCA people involved in the study, James Etienne, senior water resources engineer, will no longer be working in that position within a matter of weeks.
“Are we stuck with the same timetable, when the person with all this knowledge has moved on to a new position?” he asked. “It just seems to be too many hurdles to climb in too short a time.”
Lever is also “somewhat alarmed” that municipal approval is not really required for this. “If the township is not confident in the outcome (of this study), it could make things uncomfortable.”
In further correspondence to the township, consultant Stan Denhoed, senior hydrogeologist at Harden Environmental Services Ltd., commented on the influence of Nestle Waters Canada taking.
“Based on draft figures provided by Matrix Solutions to us on March 16, 2015, the simulated drawdown in the Gasport aquifer at County Road 34 without pumping by Nestle Waters Canada (but including City of Guelph wells, Guelph Limestone Quarry and other takers in Aberfoyle), is somewhat less than two metres.
“Therefore, even a small drawdown created by Nestle Waters Canada at County Road 34 will result in the WHPAQ1 boundary moving significantly southward.”
He added, “According to recent well shut-in measurements, the impact of Nestle Waters Canada taking is at least 0.5 metres in the vicinity of County Road 34.
“Therefore, provided that the estimate of drawdown by the City of Guelph wells and other permit holders is reasonably predicted by the groundwater model, the inclusion of the Nestle Waters Canada area of influence in the Gasport aquifer is warranted.”
