August 11, 2000Dr. George J. Kraft, Director of the Water Resources Program, University of Wisconsin - Stevens Point, and Jim Krohelski of the United States Geological Survey (USGS), have addressed apparent flaws in the recently released “Great Spring Waters of America" (a.k.a. Perrier Group of America) Environmental Assessment (EA) by the Wisconsin Department of Natural Resources (DNR).
For Immediate Release
Waterkeepers of Wisconsin - 608-586-5537 or 608-253-7266 or 920-787-4808
The Perrier Group of America is proposing to pump up to 500 gallons per minute from two or more wells at Big Springs, Town of New Haven, Adams County. Also proposed is a water bottling plant of over 1 million square feet, which needs an additional 250 gallons per minute well to operate the facility, says the EA report.
“The discussion in the EA should be more forthright and state that we really don’t know to what degree pumping is affecting Wisconsin water resources and that the very limited data that is available has shown deleterious effects,” stated Kraft in a 12-page response to the EA.
In his own response, Krohelski noted the lack of a large-scale pump test and a groundwater flow model. "Without the large-scale test and the model, there is little substance in what anyone can say about the effects of pumping."
Dr. Kraft said, “The Department (DNR) makes repeated references that aquifer tests conducted to date measured no impacts on groundwater levels greater than 150 feet from the pumping well, no impacts on streamflow, and no impacts on water levels in wetlands. This is hardly surprising since the aquifer tests were not designed to measure such impacts. It is misleading and misinformative to repeatedly state that an inadequate test did not find a certain result.”
Krohelski questions the location of the test well sites as well as the test results when he states that "...the pumped wells were located too close to the spring ponds to be useful for anything other than possibly demonstrating that the wells meet the FDA requirements for spring water."
In addition, Kraft states there is misrepresentation of the impacts of groundwater withdrawal on water resources. He points out that few studies have been done in Wisconsin to examine the question of groundwater quantity and associated impacts on surface water.
“This seems to be a case of mistaking an absence of evidence for evidence of absence," wrote Kraft.
“Even without detailed study, cases of groundwater extraction impacts in Wisconsin are known: aquifer levels in places have dropped substantially (Fox Valley, Milwaukee, Green Bay, Madison), surface waters have or will be harmed (Bonduel, Wisconsin Rapids, Little Plover River), and potential links have been shown between groundwater extraction and the incidence of arsenic in wells,” stated Kraft.
He further states in his report the DNR makes an invalid effort to compare this project with 9,400 high capacity well permits currently on record.
“A more valid comparison would be an average annual volume of water pumped among different users and how many of these users are located in stream headwaters,” said Kraft.
According to Tom Jerow of the DNR, out of the 9,400 permits currently on file, less than a dozen are extracting from stream headwaters.
Perrier's proposal is to pump 24-hours a day, 365 days a year from or very near spring headwaters.
Kraft stated little discussion was given to the potential impacts of the extra 250 gpm of the bottling plant as well. “Some assessment may be needed now or in the future since this water may be diverted from the basin as wastewater. This diversion would amount to another 50% loss from the basin,” said Kraft.
Kraft made note of the contradictory wording which states “...Perrier has agreed not to challenge DNR authority to initially impose limits or subsequently require operational changes to prevent such impacts.” The EA later states, “Perrier has reserved the right to challenge the reasonableness of any such operational limits as DNR imposes, as is a permittee's right.”
The questionable collection and interpretation of streamflow data used to prepare the EA was also noted by Kraft when he pointed out it was collected too far downstream from the well-site, and was then interpreted as being lower than average. Said Kraft, “...(the) 44% flow duration is higher than average flow, not lower! This error gets compounded later in the EA.”
Kraft also states the DNR’s classification of a high capacity well permit as a Type IV action is illogical. “The department should recognize this and not defend it,” stated Kraft. “By definition, Type IV actions are ones that ‘either individually or cumulatively do not significantly affect the quality of the human environment, do not affect energy usage, and do not involve unresolved conflicts in the use of available resources.’”
As a result of Kraft’s and Krohelski's responses to the EA, the Waterkeepers of Wisconsin state the integrity of the EA has been compromised, and that Perrier’s proposal should be subject to an Environmental Impact Statement (EIS), as described by a Class 1 Action in NR 150, which recognizes the impacts of such a proposal on the natural and human environments.
The need for this action was reiterated on Aug. 2 by State Senator Robert Welch, R-Redgranite, when he requested that George Meyer, Secretary of the DNR, recommend an EIS.
Public written comment on the EA and Perrier proposal will be accepted by the DNR through Aug. 25. Comments can be sent to David A. Weitz, Public Affairs Manager, DNR West Central Region, P.O. Box 4001, Eau Claire, WI 54702-400 or for more information, call 715-839-3715.
More information on the Waterkeepers of Wisconsin group can be obtained by writing: WOW, P.O. Box 66, Briggsville, WI 53920 or calling 608-586-5537 or 608-253-7266 or 920-787-4808.