It seems water taking operations in Puslinch are having an impact on the wellhead protection area for Guelph’s municipal water supply.
Further, reports from source water risk management official Kyle Davis and Harden Environmental Services indicate water taking may be subject to policies for “significant threats” under the Clean Water Act.
On Sept. 16 Puslinch Township councillor Susan Fielding noted that Davis has voiced serious concerns on the delineation of wellhead protection areas.
Among the information reviewed by Puslinch councillors was the Wellington County municipal peer review of a Water Quantity Risk Assessment Report (Tier 3) for water systems of the City of Guelph and Guelph-Eramosa Township.
In his comments, Davis stated the peer review indicates serious concern with the delineation of the Well Head Protection Area.
“We also continue to have concerns that additional data needs to be included to ensure the Tier 3 report and model is an accurate representation of field conditions and based on the best available science,” said Davis.
He noted his understanding is that the province’s technical rules do not allow a Risk Management Measures Evaluation Process project to alter the extent of a Well Head Protection Area or its significance level once the Tier 3 report has been accepted.
Based on that understanding, Davis said the peer review requests that concerns be addressed prior to an acceptance of the Tier 3 report.
“Our municipalities look forward to continuing our collaboration with the GRCA, City of Guelph and the province to ensure that the Tier 3 report includes the best available science in which to support the protection of groundwater resources,” said Davis.
He stressed “this is an important report that has long-term impacts for city and county residents and as such, our municipalities will continue our involvement in the review of the technical work and in development of water quantity policy.”
Township consultant Stan Denhoed of Harden Environmental also responded to the tier three report and local area risk assessment for the city of Guelph and the communities of Rockwood and Hamilton Drive in Guelph-Eramosa.
“We have reviewed this report on behalf of Wellington Source Water Protection and have focused our attention mainly on issues related to the Township of Puslinch,” stated Denhoed.
During a meeting earlier this year, Wellington County had expressed concern about the “significant risk” assignment to the City of Guelph Well Head Protection Area.
“In response, on April 21, 2015 we received a chronology of events resulting in the assignment of the ‘significant risk’ level from the Grand River Conservation Authority,” Denhoed noted.
He added “approximately two thirds of Puslinch Township falls within the (Well Head Protection Area).”
He said, “This is not only because of water taking within the City of Guelph, but also because of water taking in Puslinch Township and Flamborough Township.”
In addition, Denhoed pointed out there are several holders of permits to take water in the area that will be deemed as “significant threats” to the water quantity available to Guelph’s municipal system.
He noted the inclusion of a significant portion of Puslinch in the Well Head Protection Area, mainly because water taking by Nestlé Waters Canada will result in the enforcement of new policies developed by the Source Protection Committee.
“These policies are presently unknown, but as can be seen in the … Source Protection Area proposed policies, they may not be inconsequential.”
As such, Denhoed said it is important the extent of the Well Head Protection Area be as accurate and scientifically defendable as possible.
Denhoed stated “the water taking by Nestlé Waters Canada and another commercial water taking in the City of Hamilton (formerly Flamborough Township) have a significant impact on the size and shape of the (Well Head Protection Area) for the City of Guelph.”
“This results in a significantly larger portion of the Township of Puslinch falling within the (area) than would occur just from the City of Guelph water taking.”
He noted there are potential employment lands within the protection area (wet and dry uses) along the Highway 401 corridor that will be subject to Clean Water Act policies that would not have been if the commercial water taking was not occurring.
“It is therefore crucial that the inclusion of the area of influence of the Nestlé Waters Canada well and other water takings be carefully assessed prior to finalization of the (Well Head Protection Area),” stated Denhoed.
He added environmental engineers with Matrix Solutions confirmed the model predicts the Nestlé Waters permitted water taking alone is having a significant influence on the size and shape of the Well Head Protection Area in the Aberfoyle area.
An analysis shows that without Nestlé Waters Canada, the area would shift some 4,400 metres north.
Denhoed said the policy implications of this to Puslinch is that all existing water taking and future operations will be classified “significant threats” to Guelph municipal wells (including Nestlé Waters Canada, ConCast, Mini Lakes, Royal Canin, Mill Creek Campground and all aggregate washing) and thus subject to policies for threats under the Clean Water Act.
Denhoed explained Guelph’s Arkell well obtains water from the overburden aquifer and does not necessarily represent a threat to wells in the bedrock Gasport aquifer.
Similarly, water taking from the Gasport aquifer near Aberfoyle will not affect the safe draw down of Arkell well 1. This would allow for a moderate risk level for the remainder of the Well Head Protection Area and thus only future water taking will be subject to the new policies.
Denhoed noted the vast volume of water stored in the pit ponds near Aberfoyle are not considered in the model. There is an estimated 12 million cubic metres of water stored in pit ponds south of Highway 401, plus those north of Highway 401.
Denhoed estimated this amount is several times greater than the volume if Puslinch Lake. Therefore, permitted water taking from the ponds should be carefully evaluated before deeming them a significant threat to the City of Guelph water supply, he said.
After reading the documents, Fielding suggested the information has far reaching impacts and is something that should be looked into.
Mayor Dennis Lever pointed out it is still early in the process and some of the issues had been brought up previously by Davis.
Councillor Matthew Bulmer said he was initially concerned the source water protection process would take another year or two, but “seeing issues such as water taking permits” he now understands.
Bulmer said the process is a challenge for the city and Puslinch – “and there is no process to deal with this at the moment.”
He stressed, “This is significant to our residents and businesses and needs to be dealt with.”
Councillor Ken Roth agreed there appears to be a lot of grey areas when it comes to acceptance of the report.
“At the same time, I think we are on the right track for our protection,” said Roth.
Lever said “currently the science isn’t confirmed, the process is not confirmed and the impacts are certainly not confirmed.”
